South Downs Local Plan

Home , BBC Sussex, Colemore

South Downs National Park Authority South Downs Local Plan Submission Consultation Statement Statement in accordance with Regulation 22 of the Town and Country Planning (Local Planning) (England) (as amended) Regulations 2012

Plan submitted on 27 April 2018

Contents

Page Introduction – What is this document? 1 Local Plan overview 1 Preferred Options media campaign – impact and exposure 2 Who did the SDNPA consult? 3 How did the SDNPA consult? 4 Results of Preferred Options consultation 9 Results of the Pre-submission consultation 13 Conclusion 13 Appendix 1 - Full list of consultees at Options stage 14 Appendix 2 - Full list of consultees at Preferred Options stage 19 Appendix 3 - Summary of main issues raised by representations 33 at Preferred Options stage and how these have been taken into account  General comments 35  Chapter 1 – Introduction 43  Chapter 2 – Spatial Portrait – The National Park Today 47  Chapter 3 – Vision and Objectives 51  Chapter 4 – Core Policies 55  Chapter 5 – A Thriving Living Landscape 91  Chapter 6 – People Connected with Places 149  Chapter 7 – Towards a Sustainable Future 175  Chapter 8 – Strategic Sites 231  Chapter 9 – Site Allocations 239  Chapter 10 – Development Management Policies 269  Chapter 11 – Implementation and Monitoring 337  Inset maps 339  Appendices and Glossary 343 Appendix 4 - Summaries of main issues raised by representations 347 at Pre-submission stage pursuant to regulation 20  Preamble and Chapter 1 Introduction 349  Chapter 2 Vision & Objectives 353  Chapter 3 Spatial Portrait and Spatial Strategy 355

 Chapter 4 Core Policies 358  Chapter 5 A Thriving Living Landscape 367  Chapter 6 People Connected to Places 399  Chapter 7 Towards a Sustainable Future 417  Chapter 8 Strategic Sites 487  Chapter 9 Sites and Settlements 493  Chapter 10 Implementation and Monitoring 566  Appendices & Glossary 567  Policies Map 569  Sustainability Appraisal 572

iii

Introduction – What is this document?

1. This document sets out how the South Downs National Park Authority (SDNPA) has undertaken consultation in preparing its Pre-Submission Local Plan (SDLP), and a summary of representations made to the Pre-submission Local Plan when it was published for an 8 week period in September 2017. It provides an overview of all stages of the consultation, but in particular focuses on the consultation on the Local Plan Preferred Options (LPPO) that took place in the autumn of 2015. It addresses:

 Which bodies and persons were invited to make representations during the preparation of the Local Plan. (Who was consulted?)

 How these bodies and persons were invited to make those representations. (How were the public and other stakeholders consulted?)

 A summary of the main issues raised. (How many responses were received on the chapters in the LPPO and what were the main issues raised?)

 How those issues have been addressed. (How have the main issues raised been taken into account?) 2. This statement has been prepared in accordance with Regulation 22(1)(c) of the Town and Country Planning (Local Planning) (England) Regulations 2012 (as amended), as one of the submission documents.

Local Plan overview

3. The South Downs Local Plan: Preferred Options was published for public consultation under Regulation 18 of The Town and Country Planning (Local Planning) (England) Regulations 2012. The consultation was launched on 2 September and ran for 8 weeks until 28 October 2015. 4. Local Plan policies have been formulated in consultation with local communities, building on extensive engagement on the Partnership Management Plan (PMP) and the State of the Park Report. The views and input of the local community are vital to us and we have undertaken a considerable amount of public engagement, particularly with the town and parish councils. The Authority also benefits from the active engagement with a number of local groups including the South Downs Land Managers’ Group and the South Downs Partnership, who give us a wide range of views from people who live, work and develop in the National Park. 5. The first formal round of public consultation on the Local Plan was on the Options Consultation Document in spring 2014. The evidence based document ‘Progress from Issues and Options to Preferred Options’ sets out all the issues and options consulted on, the main issues raised and how these main issues were addressed in the formulation of the Preferred Options. 6. The Preferred Options Local Plan was the second formal round of public consultation. Over 1500 individuals and organisation were notified directly at the launch of the consultation, and the consultation was publicised using a range of methods. As part of the consultation, 5 public roadshows, 3 parish workshops and a number of meetings were held with key partners. It is estimated that over 500 people attended the public roadshows. As part of the publicity for the events, there were over 40 pieces of broadcast, online and print coverage, including ITV Meridian and BBC News online, a BBC Sussex radio interview with the Chief Executive of the SDNPA, publicity on Facebook, Twitter and the SDNP Forum.

7. A final chance for stakeholders and the public to make formal representations on the final draft SDLP was provided for an 8 week period starting on 26 September 2017. This stage of the process is primarily intended for participants to identify issues of Plan ‘soundness’ or legal compliance. Therefore publicity was not as extensive as for earlier stages. Nevertheless, a number of helpful comments were made at this stage which has helped to further improve and refine the SDLP. These are shown in a Schedule of Changes which form part of the Submission Local Plan, and, subject to examination, will be incorporated into the final Local Plan.

Preferred Options media campaign – impact and exposure

8. During the consultation period we had a total of 16,756 page views to all Local Plan related web pages, broken down these include:

 6,409 page views on the Preferred Options consultation landing page;

 4,355 page views on the Local Plan landing page;

 1,115 page views on the Roadshows & Paper Copies page; and

 918 page views on the What’s in the Local Plan page. 9. We decided that Facebook presented the best way to promote a Local Plan promotional film to very specific audiences across the National Park. From this we achieved a total of 22,751 views. The majority of these were through mobile devices (phone/ tablet). The film was also viewed 472 times on YouTube which includes people watching it through the SDNPA website, Forum, Twitter and finding it through other means. Our other social media activity focused on three aims:

 raising general awareness about the consultation;

 promoting specific consultation events; and

 reminding people that the consultation was due to close on 28 October. We posted a further 16 times on Facebook about the consultation – using stills from the film with links through to the media release and directly through to the consultation page. These achieved a total of: 24 likes, 15 shares and 23 clicks through to the link (either the media release or directly through to the consultation page). An online forum was set up on the website to generate discussion. The initial posting announcing the public consultation received 167 official views, the chaser postings received 129 and 139 official views and the short film on the making of the short film received 64 official views, but we know from google analytics that unofficial views (from non-members) generally treble this number of views. We utilised Twitter to further publicise the Local Plan. We put out 22 tweets over the course of the consultation achieving:

 20,979 impressions;

 305 engagements;

 57 retweets, 2 replies and 14 favourites; and

 101 clicks through to the link (either the media release or directly through to the consultation page). We posted stills from the Local Plan film onto our Instagram account to further promote the consultation. Our post using the still of the tree from the Local Plan film is the most popular image we have shared on Instagram to date – gaining 116 likes. We posted three stills altogether, gaining a total of 155 likes. We also promoted the Local Plan through local newspapers and broadcasters. We achieved a total of 42 pieces of broadcast, online and print coverage for the consultation. Our main press push was at the start of the consultation. Our embargoed media release, sent out two working days before the start of the consultation to make sure that story was covered in the weekly publications on the first week, achieved 36 pieces of coverage including ITV Meridian and BBC News Online.

Who did the SDNPA consult?

10. There have been three main stages of consultation: the Options consultation in Spring 2014, the Preferred Options consultation in Autumn 2015, and the Pre-submission consultation in Autumn 2017. 11. At the Options consultation, a range of organisations were contacted, and there was wide publicity to encourage members of the public from across the National Park and surrounding areas to participate. Further details of how the consultation was conducted are given below. A list of those specifically invited in writing to participate at this time is provided in Appendix 1. 12. At the Preferred Options stage, a wide range of organisations and individuals were directly invited to participate. A list of organisations and individuals who were contacted at Preferred Options stage is provided in Appendix 2. 13. At the Pre-submission stage, previous participants were invited to make representations, including ‘specific’ and ‘general’ consultee bodies as set out in regulations. 14. In addition, there has been continuous dialogue with both specialist stakeholder bodies (see the Duty to Cooperate statement), and community representatives. The SDNPA has been particularly proactive in having informal dialogue with Parish Councils, particularly where the relevant parish has been identified as having capacity to accommodate some housing growth to be allocated in the SDLP.

How did the SDNPA consult?

15. The following section sets out details of consultation and engagement in relation to the South Downs Local Plan. 16. Options Launch of Issues and Options

- Issues and Options Consultation ran from 28 February 2014 to 30 April 2014 - Notification of consultation sent to all County, District and Unitary Authorities (Chief Exec)

- Notification also sent to all Planning Policy and Housing Teams providing info on consultation and how to respond

- Notification of Issues & Options consultation sent to all parish councils

- Copy of Issues and Options consultation document sent to all Parish Councils and 8 weeks provided for feedback with request to promote to their respective communities and encourage them to respond to SDNPA (e.g. parish newsletters)

- Posters sent out to Parish Councils (March 2014) highlighting the local plan process One to One meetings with Towns and large Parishes (September / October 2014)

- Meetings held with the towns and larger parishes in the National Park

- One to one meetings held with Alfriston, Amberley, Corhampton, Ditchling, Droxford, Easebourne, East Meon, Fernhurst, Findon, Hambledon, Lavant, Lewes, Liss, Midhurst, Petersfield, Petworth, Rowlands Castle, Sheet, South Harting, Twyford, West Meon

- Meetings focus on SHLAA sites proposed and SDNPA assessment of those sites, Point of Interest Data (used to prepare the settlement facilities study)

- Meetings run through the Options consultation results and possible areas for policy development Options workshops (October / November 2014)

- Three Parish workshops (West Sussex 23/10, East Sussex 4/11 and Hampshire 12/11) - East Sussex 18 attend, West Sussex 41 attend, Hampshire 43 attend

- Workshops present Options Consultation results - Workshops present SHLAA info where relevant

- Workshops present the Point of Interest data for verification from parishes to inform the Settlement Facilities study

Meetings with Statutory Bodies, estates and other key stakeholders

- South Downs Partnership – 25 November

- (see Interim Duty to Cooperate Statement for details of meetings with Specific Consultee Bodies)

17. Preferred Options (sites & settlements) 2 September – 28 October 2015 General promotion of preferred options consultation

- Preferred Options Consultation runs from 2 September 2015 – 28 October 2015

- Notification of preferred options consultation sent to all County, District and Parish Councils

- Posters sent to all parish councils to promote consultation events (August 2015)

- Postcards & bookmarks circulated at all SDNPA public events, train stations, super markets, leisure centres, schools (August 2015)

- Attend key events across National Park, such as Mela, urban seafront events - Static displays erected at SDC, Area offices, libraries, District / County Council offices

- Social media campaign (including twitter, facebook and SD Forum) - Children’s drawing competition at consultation events

- South Downs 2032 video (online and at events) to assist responders to understand the context of the SDLP, the issues, constraints etc

- Deposit copies of local plan (Preferred Options) placed in 58 key locations (mainly libraries and Council offices)

Public Roadshows

- 3 x public roadshows held (1 in each county) - Roadshows run from 3-8pm, ES 8/9/15, WS 16/9/15, Hants 21/9/15, Park Wide 12/9/15 - Roadshows are run as drop in events

- Broad Spatial Areas map (Spatial Diagram) - Park wide board showing sites and settlements across the National Park

- Large display boards show proposed allocations (housing, employment, G&T) as well as settlement policy boundaries and NDP areas where relevant

- Additional board also offers the opportunity for attendees to propose alternative housing, G&T and Local green spaces

- Thriving Living Landscape, People Connected with Places and Sustainable Futures boards present the chapter areas under this heading, with the policies contained in these chapters

- Officers on hand to provide clarification / answer questions

- Feedback area at each roadshow for people to provide written response on the night - Response forms available to collect and take away

Parish Council workshops

- 3 x parish workshops to which all Parish Councils were invited along with district councillors who represent wards within the National Park

- Hampshire 9th September 2015 (48 attended), West Sussex 10th September 2015 (76 attended), East Sussex 22nd September 2015 (35 attend)

- Parish Council workshops present the same material as was presented at the Public Roadshows, but events are only open to Town, Parish, District and County Councillors

Specific and general consultees

- All specific consultee bodies received written notification of the consultation with details of how to view the consultation materials

- A number of other key bodies also written to Stakeholder workshops

- Stakeholder workshops held with English Heritage, Natural England and Environment Agency Key Stakeholder engagement

- One to one meetings held with Lewes DC, Chichester DC, East Hants DC, Winchester CC, ESCC, WSCC and HCC

- Joint Authority meetings held with Arun, Adur, Worthing, Horsham, MSDC, BHCC, Eastbourne & Wealden Advised of consultation in writing

- Clinical Commissioning Groups, Utility providers (inc. mobile phone providers), Coal Authority, Theatres Trust, Marine Management Organisation, Local Nature Partnerships, Ministry of Defence, Civil Aviation Authority, Newtork Rail, Highways Authority, Homes and Communities Agency

- Written correspondence with relevant MP, and meetings with MPs where possible 18. Annual Town and Parish Council meetings (Sites and Settlements)

- The SDNPA hosted Annual Parish Meetings for Town and Parish Councils in Autumn 2016, which were also used to carry out further consultation on the Local Plan preparation

- The purpose of this round of workshops was to update on progress since the preferred options consultation and set out the revised sites and settlements proposals

- Town and Parish Council were presented with proposed allocations for Gypsy and Travellers, Housing and Local Green Spaces (incorporating feedback from the preferred options consultation)

- Opportunity to propose new local green spaces and provide local input and information relating to the proposed allocations and designations

- Hampshire parishes 14th November 2016 (68 attended), West Sussex 23rd November 2016 (66 attended), East Sussex 21st November 2016 (9 attended)

19. New Site allocation meetings with key Parish Councils Following the Annual Parish meetings in November 2016, some new site allocations came forward which the SDNPA discussed with Town and Parish Councils at 1-to-1 meetings, these include the following parish councils:

- Alfriston

- Buriton - Cheriton

- Coldwaltham - Easebourne

- Findon - Kilmeston

- Midhurst - Sheet

- South Harting - Stedham - Kingston near Lewes

Results of the Preferred Options consultation

20. The Preferred Options Consultation Document included 11 chapters and 80 draft policies, alongside a set of Inset Maps, Appendices and a Glossary. Respondents were offered the opportunity to comment on all parts of the document and were asked the following:

 Do you support, object or wish to make comments on this section of the Local Plan? (Options were Support, Support with Changes, Object and Have comments)

 Please give details for your support or opposition or make comment.

 What improvements or changes would you suggest?

21. In total, 400 stakeholders responded to the consultation. They made over 2600 individual comments. 22. Over 60% of respondents provided an answer to the first question stating that they either supported, supported with changes or objected to the part of the plan or policy they were commenting on. Of those respondents 77% either stated their support or that they supported the policy or section with changes. 23% stated their objected to the policy or section. This is shown in Figure 1.1 below.

Figure 1.1 – Overall support/objection to policies or sections of the Local Plan

Object 23%

Support 39%

Support with changes 38%

23. There were differences in the levels of support for different sections and policies. Figure 1.2 below provides a summary of the responses to the first question across the chapters of the Local Plan. It should be noted that the overall numbers of respondents varies by chapter, so this provides a simplistic comparison of levels of support. 24. The remaining respondents (approximately 40% of the total) either selected that they had comments or responded via email or post with comments without specifically answering this first question. Within these comments the respondent may have indicated support or objection to the policy without specifically stating it. 25. Whilst the responses to the first question (shown in Figure 1.1, and Figure 1.2 below) shows a generally positive level of support, particularly for some parts of the Local Plan, it was important that the outcome of the consultation was transparently presented, and that full analysis was made of the comments to understand the various points and concerns being raised. Summaries of the responses were therefore prepared, and are available as an online resource on the National Park Authority’s website www.southdowns.gov.uk. 26. In revising the Local Plan following consultation, the full responses made at Preferred Options stage have been carefully considered. Whilst many changes have been made as a result of the consultation, there have been other suggested changes and comments that the National Park

Authority cannot agree to. Appendix 3 sets out summaries of the main issues raised by representations, and how these have been taken into account.

Figure 1.2 – Levels of Support for, or Objection to, the Chapters of the Local Plan

Introduction

Spatial Portrait - The National Park Today

Vision and Objectives

Core Policies

A Thriving Living Landscape

People Connected with Places

Towards a Sustainable Future

Strategic Sites

Site Allocations

Development Management Policies

Implementation and Monitoring

Inset Maps

Appendices

Glossary

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Support Support with changes Object

Results of the Pre-submission consultation

27. In response to the Pre-submission consultation, a total of 2,520 individual representations were made pursuant to regulation 20, by a total of 568 organisations and individuals. Summaries of main issues raised in those representations are given for each policy or part of the Local Plan in Appendix 4.

Development briefs

28. Four development briefs have been prepared for draft allocations in the Pre-Submission Local Plan. The development briefs were subject to public consultation in March/April 2018. All the comments received on the development briefs will be considered by the NPA and changes made to the documents as appropriate. The draft versions of the briefs are included in the core document library and the final versions will be added to the library when they are finished.

Conclusion

29. The preparation of the South Downs Local Plan has involved extensive consultation. A wide range of bodies and individuals have been invited to participate. The Options consultation in Spring 2014 provided opportunity for stakeholders and the public to shape the direction of the Local Plan at an early stage of preparation. At the Preferred Options stage, stakeholders and the public were asked their views on the first draft of the Local Plan. There has been continuous dialogue with local communities via Parish Councils, and with key bodies through the Duty to Cooperate, throughout the preparation of the Plan. 30. A range of methods have been used to maximise involvement in the Local Plan’s preparation. This included extensive media publicity, close working with parish councils to reach local communities, and a number of roadshow events providing opportunity for the public and stakeholders to speak to planning officers directly. 31. The South Downs National Park Authority has taken into account all responses received during these consultation phases. A summary of the main issues raised at Preferred Options (Regulation 18) stage, and how those issues have been addressed in the local plan, is provided in Appendix 3. A total of 2,560 individual representations were made pursuant to regulation 20, by a total of 568 organisations and individuals. Summaries of main issues raised in those representations are given for each policy or part of the Local Plan in Appendix 4.

Appendix 1

Full list of consultees at Options stage

Adur District Council Black Down & Hindhead Colden Common Parish Supporters of the National Council Adur District Council and Trust Worthing Borough Council Coldwaltham Parish Council Boarhunt Parish Council Albourne Parish Council Colemore and Priors Dean Bovis Homes Ltd Parish Meeting Alciston Parish Meeting Boxgrove Parish Council Comer Homes Aldingbourne Parish Council Bramber Parish Council Compton and Shawford Parish Council Alfriston Parish Council Bramdean and Hinton Ampner Parish Council Compton Parish Council Alice Holt Community Forum Bramshott and Liphook Coombes Parish Meeting Parish Council Amberleigh House Limited Corhampton and Brighton & Hove Clinical Meonstoke Parish Council Amberley Parish Council Commissioning Group Cowdray Estate Angmering Estate Brighton and Hove City CPRE Hampshire (South Angmering Parish Council Council Downs & Central Group) Arun District Council Buriton Parish Council CPRE Sussex Arundel Chamber of Burpham Parish Meeting Cuckmere Valley Parish Commerce Bury Parish Council Council Arundel Town Council Callstone Ltd Denmead Parish Council Barlavington Estate Chawton Parish Council Ditchling Parish Council Barratt Homes Cheriton Parish Council Droxford Parish Council Beauworth Parish Meeting Chichester District Council Dudman Group of Beddingham with Glynde Companies Chichester Society Parish Council Duncton Parish Council Chidham and Hambrook Bellway Homes (Wessex) Parish Council Eartham Parish Meeting Limited Chidham with Hambrook Easebourne Parish Council Bepton Parish Council Chilcomb Parish Meeting East Chiltington Parish Berwick Parish Council Council CLA Bignor Parish Meeting East Dean and Friston Clanfield Parish Council Bignor Park Estate Parish Council Clapham Parish Council Binsted Parish Council East Dean Parish Council Coast to Capital LEP Bishops Sutton Parish East Hampshire District Council Coastal West Sussex Council Clinical Commissioning Bishops Waltham Parish East Lavington Parish Group Council Council Cocking Parish Council East Meon Parish Council

East Sussex County Council Hampshire Alliance for Kings Worthy Parish Rural Affordable Housing Council East Tisted Parish Council (HARAH) Kingsley Parish Council Eastbourne Borough Hampshire and Isle of Council Kingston Near Lewes Parish Wight Wildlife Trust Council Eastbourne, Hailsham and Hampshire County Council Seaford Clinical Kirdford Parish Council Commissioning Group Hamsey Parish Council Lancing College Ebernoe Parish Council Harting Parish Council Lancing Parish Council Elsted and Treyford Parish Hassocks Parish Council Langrish Parish Council Council Hawkley Parish Council Lavant Parish Council English Heritage Headbourne Worthy Parish Leconfield Estate Enterprise M3 Council Lewes and District Seniors' Environment Agency Henfield Parish Council Forum Exton Parish Meeting Heyshott Parish Council Lewes District Council Falmer Parish Council High Weald, Lewes Havens Lewes Town Council Clinical Commissioning Farringdon Parish Council Group Linch Parish Meeting Fernhurst Parish Council Highways Agency Liss Parish Council Ferring Parish Council Hillier Nurseries Limited Lodsworth Parish Council Findon Parish Council Historic England Long Man Parish Council Firle Estate Home Builders Federation Lurgashall Parish Council Firle Parish Council Homes and Communties Lyminster and Crossbush Fittleworth Parish Council Agency Parish Council Four Marks Parish Council Horndean Parish Council Lynchmere Parish Council Friends of Lewes Society Horsham and Mid Sussex Madehurst Parish Meeting Clinical Commissioning Friends of Seaford Head Group Marden Parish Meeting Froxfield & Privett Parish Horsham District Council Marine Management Council Organisation Houghton Parish Meeting Fulking Parish Council Marine Maritime Hurstpierpoint and Sayers Organisation Funtington Parish Council Common Parish Council Mayfield Market Towns Ltd Goodwood Estate Iford Parish Meeting Mid Sussex District Council Graffham Parish Council Itchen Stoke and Ovington Midhurst Town Council Greatham Parish Council Parish Council Milland Parish Council Green Village Investments Itchen Valley Parish Council Mobile Operators Hambledon Parish Council Kilmeston Parish Council Association

National Grid Rowlands Castle Parish Stedham with Iping Parish Council Council National Trust RSPB Steep Parish Council Natural England Scorrish & Southern Energy Steyning Parish Council Newhaven Town Council Seaford Town Council Stopham Parish Meeting Newtimber Parish Council Selborne Parish Council Storrington and Sullington Newton Valence Parish Parish Council Council Selmeston Parish Meeting Stoughton Parish Council NFU South East Region Shedfield Parish Council Streat Parish Meeting Northchapel Parish Council Sheet Parish Council Stroud Parish Council Otterbourne Parish Council Singleton Parish Council Surrey County Council Owslebury Parish Council Slindon Parish Council Sussex Community Rail Parham Estate Soberton Parish Council Partnership Parham Parish Council Sompting Estate Sussex Wildlife Trust/ Patching Parish Council Sompting Parish Council South Downs Network Peacehaven Town Council South Downs Land Sutton & Barlavington Managers Parish Council Petersfield Town Council South Downs Society Swanmore Parish Council Petworth Parish Council South East LEP Tangmere Parish Meeting Piddinghoe Parish Council South East Water Tarring Neville Parish Plaistow Parish Council Meeting South Eastern Hampshire Plumpton Parish Council Clinical Commissioning Telscombe Town Council Group Polegate Town Council Thakeham Homes South Heighton Parish Poling Parish Meeting Thames Water Council Portsmouth Water The British Horse Society South Stoke Parish Council Poynings Parish Council The Santon Group Southcott Homes Limited Pulborough Parish Council The Theatres Trust Southease Parish Meeting Pyecombe Parish Council The Wiggonholt Southern Gas Networks Railfuture Association Southern Water Redrow Homes Ltd The Woodland Trust Sport England Ringmer Parish Council Tichborne Parish Council St. Ann (Without) Parish Tillington Parish Council Rodmell Parish Council Meeting Trotton with Chithurst Rogate Parish Council St. John (Without) Parish Parish Council Rottingdean Parish Council Meeting Twyford Parish Council

Upham Parish Council Willingdon and Jevington Parish Council Upper Beeding Parish Council Winchester City Council Upwaltham Parish Meeting Wisborough Green Parish Council Village Green plc Wiston Parish Council W L West & Sons Ltd Woodmancote Parish Waitrose Ltd Council Walberton Parish Council Woolbeding with Redford Warnford Parish Meeting Parish Council Warningcamp Parish Worldham Parish Council Meeting Worthing Borough Council Washington Parish Council Waverley Borough Council Wealden District Council West Chiltington Parish Council West Dean - The Edward James Foundation West Dean Parish Council West Lavington Parish Council West Meon Parish Council West Sussex County Council West Sussex Cycle Forum West Sussex Local Access Forum West Tisted Parish Meeting Westbourne Parish Council Westhampnett Parish Council Westmeston Parish Council Whitehill Parish Council Wickham Parish Council

Appendix 2

Full list of consultees at Preferred Options stage

Organisations SDNPA Arundel Town Council Bignor Park Estate 1 Elder Cottage, Asda Stores Ltd Bignor Park Limited Nepcote, Findon Association of National Billingshurst Parish A.M Harriott & Son Park Authorities Council Action in Rural Sussex Association• of Binsted Parish Council Community Rail Adams Hendry Bishop's Sutton Parish Partnerships Council Adur District Council Avington Park Bishop's Waltham Parish Adur District Council and B&H Local Access Forum Council Worthing Borough Council Bachelor Monkhouse Black Down & Hindhead Supporters of the Age Concern East Sussex Barcombe Parish Council National Trust Albourne Parish Council Barlavington Estate Blagden Farm Alciston Parish Meeting Barlavington Boarhunt Parish Council Farms/Milkminers Aldingbourne Parish Bovis Homes Ltd Council Barlavington Parish Council Boxgrove Parish Council Alfriston Parish Council Barratt Homes Bramber Parish Council Alice Holt Community Forum Beauworth Parish Bramdean & Hinton Council Ampner Parish Council Alton Town Council Beddingham and Glynde Bramshott & Liphook Amberleigh House Parish Council Parish Council Limited Bell Cornwell LLP Brian Campbell Amberley Museum and Associates Heritage Centre / Sussex Bellway Homes (Wessex) Gardens Trust Limited Brighton & Hove's Wildlife Forum Amberley Parish Council Benfield Hill Wildlife and Conservation Group Brighton and Hove City Angling Development Council Board Bentley Parish Council Brighton and Hove Open Angmering Estate Bepton Parish Council Space Group Angmering Parish Council Bereleigh Estate Brighton Society Arquiva Berwick Parish Council British Horse Society Arun District Council Bicycles Campaigns and British Telecom Newsletter Arundel Chamber of Broadband Vantage Commerce Bignor Parish Meeting

Bryan Jezeph Consultancy CLA Council for British Archaeology - South East Buncton Farmers Clanfield Parish Council Branch Burgess Hill Town Clapham Parish Council Country Land and Council Clifford Dann LLP Business Association Buriton Parish Council CMYK(Planning & Countryside Alliance Burpham Parish Meeting Design) Sussex Bury Parish Council CNA Wessex Region Cowdray Estate Butterfly Conservation CNP CPRE (lewes District) Cable and Wireless Coast to Capital LEP CPRE and Friends of Withdean Park Callstone Ltd Cocking Parish Council CPRE Hampshire (South Camerons Surveying Ltd. Colden Common Parish Downs & Central Group) Council Campaign for National CPRE Sussex Parks Coldwaltham Parish Council CPRE Sussex Campaign to Protect Countryside Trust Rural England Colemore & Priors Dean (Hampshire) Parish Meeting Crawley District Council Carter Jonas Comer Homes CTC Right to Ride CBRE Limited Community Action - Cuckmere Valley Parish Hampshire Council Chailey Parish Council Community Action D&M Planning Ltd Chawton House Hampshire Daniel Watney LLP Chawton Parish Council Community First East DEFRA Cheriton Parish Council Hampshire Denmead Parish Council Chestnut Planning Compton & Shawford Parish Council Department of Transport Chichester District Council Compton Parish Council Dev Plan Chichester Society Conservators of Diocese of Chichester Ashdown Forest (CoE) Chiddingfold Parish Council Coombes Parish Meeting Disability Initiative Chilcomb Parish Meeting Corhampton & Disabled Ramblers Meonstoke Parish Ditchling Parish Council Churches Together in Council Sussex DMH Stallard Corhampton and CKA Architectural Meonstoke Parish Dockenfield Parish Consultants Limited Council Council

Downlands Eastleigh Borough Fieldfare (Winchester and Council East Hampshire) Local Drinking Ginger Action Group Ebernoe Parish Council Droxford Parish Council Findon Parish Council ECE Planning Droxford ParishCouncil Firle Estate Eco-Logically Dudman Group of Firle Parish Council Companies Elsted and Treyford Parish Council Fittleworth Parish Duncton Parish Council Council English Heritage Eartham Parish Meeting Floyd Matcham English Heritage South Easebourne Parish (Hampshire) Ltd East Council Forestry Commission English National Park East Chiltington Parish Authorities Association Four Marks Parish Council Council ENPAA East Dean & Friston Frensham Parish Council Parish Council Enterprise M3 Friends Families and East Dean Parish Council Enterprise M3 LEP Travellers East Hampshire District Environment Agency Friends of Beacon Hill / Council ESCC Local Access Beacon Hill Management East Lavington Parish Forum Group Council Exton Parish Meeting Friends of Bevendean East Meon Parish Council Down FACE/Plumpton College East Sussex County Friends of Blakers Park Fair Oak and Horton Council Heath Parish Council Friends of Green Ridge / East Sussex Disability Keep the Ridge Green Falmer Parish Council Association Friends of Hollingbury Fareham Borough East Sussex Downs and and Burstead Woods Council Weald Primary Care Friends of Lewes Trust Farnham Town Council Friends of Lewes Society East Tisted Parish Farringdon Parish Council Council Friends of Moulsecoomb Fernhurst Parish Council Wild Park Eastbourne Borough Council Fernhurst Society Friends of Seaford Head Eastbourne District Ferring Conservation Friends of Sheepcote Group Council Valley Ferring Parish Council Eastergate Parish Council Friends of Three Cornered Copse

Friends of Waterhall Hampshire & Isle of Heyshott Parish Council Wight Wildlife Trust Friends of WCP Highways England Hampshire Alliance for Friends of Wild Park Hillier Nurseries Limited Rural Affordable Housing Friends of Withdean Park (HARAH) Historic England Friends of Wolstonbury Hampshire and IOW HLF Law Wildlife Trust Friends, Families and HN Butler Farms Ltd Travellers Hampshire and Isle of Wight Wildlife Trust Home Builders Froxfield Parish Council Federation Hampshire Association of Fulking Parish Council Local Councils Homes and Communities Agency Funtington and District Hampshire County Village Hall Management Council Horndean Parish Council Committee Horsham District Council Hampshire Local Access Funtington Parish Council Forum Houghton Parish Meeting Fusion Online Hampshire Police Hoyle Farm Game and Wildlife Hampshire Police and Hurstpierpoint & Sawyers Conservation Trust Crime Commissioner Common Parish Council Gentian Partnerships Ltd Hamsey Parish Council Hut Therapy Whole Gilbert White Museum Hants Countyside Access Food B&B Glynde Estate Harting Parish Council Hutchinson G3 UK Ltd Goodwood Estate Haslemere Parish Council IDE Planning Gosport Borough Hassocks Parish Council Idsworth Farms Council Iford Parish Meeting Hastings Borough Grace Eyre Foundation Council Itchen Stoke & Ovington Graffham Down Trust Parish Council Havant Borough Council Graffham Parish Council Hawkley Parish Council Itchen Valley Parish Council Grant Consultancy Hazeley Estate J&H Robinson (Iford Greatham Parish Council Headbourne Worthy Farms) Ltd Green Village Parish Council J.R Sykes Farms Investments Headley Parish Council JC Nicholson & Son GVA HEINE PLANNING John Muir Trust Hambledon Parish Henfield Parish Council Council Kebbell Development Ltd Henry Adams Kilmeston Parish Council

Kingsley parish Council Marden Parish Meeting New Village Hall Committee Kingston Parish Council Marine Management Organisation Newhaven Town Council Kingsworthy Parish Council MatPlan Limited Newtimber Parish Council Kirdford Parish Council Mayfield Market Towns Ltd Newton Valence Parish Lancing College Council Medstead Parish Council Lancing Parish Council NFU South East Region Messrs R and W Brown LanDesign Associates NHS Brighton and Hove Mid Sussex District Langrish Parish Council CCG Council Lanson Consultants NHS Coastal West Mid Sussex Ramblers Sussex CCG Laughton Parish Council Midhurst Town Council NHS Eastbourne, Lavant Parish Council Mill Farm Lurgshall Hailsham and Seaford Learning through CCG Milland Parish council Landscapes NHS Guildford & Mobile Operators Leconfield Estate Waverley CCG Association Lewes and District NHS High Weald Lewes Moulsecoomb Forest Seniors' Forum Havens CCG Garden Lewes District Council NHS Horsham and Mid n/a Sussex CCG Lewes Footpaths Group National Farmers Union NHS Local Area Team - Lewes Town Council National Grid Surrey and Sussex Linch Parish Meeting National Trust NHS North East Liss Parish Council Hampshire and Farnham National Trust, Sheffield CCG Local Access Forum Park Garden NHS North Hampshire Local Nature Partnership National Trust, South CCG Downs Lodsworth Parish Council NHS Property Services- Natural England Long Man Parish Council Strategic Estates (Sussex) NCDA Lurgashall Parish Council NHS South Eastern Neame Sutton Limited Hampshire CCG Lyminster and Crossbush Parish Council Network Rail NHS West Hampshire CCG lynchmere parish council New Alresford Parish Council Nordic Walking for M&V Stent Heath New Forest NPA Madehurst Parish Meeting

Norfolk Estate Petersfield Infant School Ramblers Association - Hampshire Northchapel Parish Petersfield Town Council Council Ramblers Sussex Area Petersfield's Northease Farm Neighbourhood Plan Rapleys LLP Northend Farm BN5 9TL Petworth Parish Council RebeccaWare Not applicable Petworth Town Council Redrow Homes Ltd O2 UK Ltd Philip Hide Racing RG Riddell & Son Old Alresford Parish Piddinghoe Parish Council Ringmer Parish Council Council Plaistow Parish Council Robinson and Co Old Farm Partnership Chartered Town Planinfo/DPDS Planners Open Spaces Society PlanningSphere Rodmell Parish Council Orange Personal Plumpton College Communications Ltd Rogate Parish Council Plumpton Parish Council Otterbourne Parish Romans Land and Council Polegate Town Council Development Ovingdean Residents and Poling Parish Meeting Ropley Parish Council Preservation Society Portsmouth City Council Rother District Council Owslebury Parish Portsmouth Water Rotherfield Park Council Rottingdean Parish P.A Wyatt Poynings Parish Council Council P.F Hanbury and son Preshaw Estate Rowlands Castle Parish Parham Estate Pro Vision Planning & Council Design Parham Parish Council RSPB Pulborough Parish Parish Council Council Rural West Sussex Partnership Parker Dann Charter PV Projects Town Planning Rushmoor Borough Consultants PW Taylor & Partners Council Pyecombe Parish Council Parson's Farm Rydon Patching Parish Council RA Dallyn & Sons Saltdean Railfuture Peacehaven Town Savills Council Railway Land Wildlife Scotia Gas Networks Persimmon Homes Trust Seaford Town Council Peter Estates Ltd Ramblers Association

SELBORNE PARISH South Downs Partnership St. Ann (without) Parish COUNCIL Meeting South Downs Partnership Selborne PC (East Hampshire St. John (without) Parish Association of Town and Meeting Selmeston Parish Council Parish Councils) Stanmer Preservation SGN South Downs Partnership Society / Brighton Urban Shedfield Parish Council (Natural England) Wildlife Group Sheet Parish Council South Downs Society Stansted Park Foundation Shoreham Parish Council South Downs Stedham with Iping Parish Society/South Downs Council sigma planning services Partnership Steep Parish Council Singleton Parish Council South East Hampshire Stephens and Son (Farms) Federation of Small Slindon Common Ltd Residents Association Businesses Steyning Parish Council Slindon Parish Council South East LEP Stopham Parish Meeting Smiths Gore South East Protected Landscapes Stopham Vineyard Ltd Soberton Parish Council South East Water Storrington & Sullington Sompting Estate Parish Council South Heighton Parish Sompting Parish Council Council Stoughton Parish Council South Downs Access South Stoke Parish Streat Parish Meeting Forum Council Stroud Parish Council South Downs Advisory Southampton City Strutt & Parker Forum Council Strutt and Parker South Downs Land Southcott Homes Limited Management Group Southease Parish Meeting Surrey County Council South Downs Land Surrey Hills AONB Managers Southern Planning Practice Ltd Sussex and Surrey South Downs Land Associations of Local Managers Group Southern Water Councils South Downs Local Sparsholt College Sussex Archaelogical Access Forum Sport England Society South Downs National ssa planning Sussex Area Ramblers Park SSE Sussex Community South Downs National Development Park Authority St Nicholas Green Space Association/Sompriti Association South Downs Network

Sussex Community Rail The Lynchmere Society University of Brighton Partnership The McLaren Clark University of Chichester Sussex Ornithological Group University of Portsmouth Society The National Trust University of Sussex Police The Petersfield Society Southampton Sussex Police & Crime The Royal Automobile University of Sussex Commissioner Club Motor Sports University of Winchester Sussex Wildlife Trust Association Limited Upham Parish Council Sussex Wildlife Trust/ The Santon Group South Downs Network Upper Beeding Parish The Showmen's Guild of Council Susssex Wildlife Trust Great Britain Upper Beeding Parish Sustainability Centre The Stud Farm Council neighbourhood Swanmore Parish Council The Theatres Trust Plan T24 Search & Rescue The Wiggonholt Upwaltham Parish Association Meeting Tarring Neville Parish Meeting The Woodland Trust Venthams Farm Partnership Telscombe Town Council Thomas Eggar LLP Village Green plc Terence O'Rourke Thorn Farm Virgin Media Terrestria Limited Tichborne Parish Council Vodafone Ltd Tetlow King Tichborne Park Estate W D Passmore & Son Tetlow King Planning Tillington Parish Council W L West & Sons Ltd Thakeham Homes T-Mobile W&W Comm Thames Water Tourism South East Association The British Horse Society Transition Chichester Waitrose Ltd The Camping and Transition Town Lewes Walberton Parish Caravanning Club Trotton with Chithurst Council The Charleston Trust Parish Council Walking Friends The Coal Authority Turley Portsmouth The Common Parish Turley Associates Walsingham Planning Council of Sutton & TWEAK Warnford Parish Meeting Barlavington Twyford Parish Council Warnford Park The Estate Office UK Power Networks Warningcamp Parish The Gilbert Estate Meeting

Washington Parish Westmeston Parish Yew Tree & Idsworth Council Council Farm & Idsworth Park Woodlands Waverley Borough Whitehill Parish Council Council Yokehurst Farm Wickham Parish Council Weald & Downland Youth Hostel Association Willingdon & Jevington Open Air Museum Parish Council Weald and Downland Winchester Area Open Air Museum Community Action Wealden District Council Winchester City Council West Chiltington Parish Winchester College Council Winchester District West Dean Association of Local West Dean - The Edward Councils James Foundation Winchester District West Dean College Council West Dean Parish Wisborough Green Council Parish Council West Lavington Parish Wiston Estate Council Wiston Parish Council West Meon Parish Woodmancote Parish Council Council West Sussex Woolbeding with Conservatives Redford Parish Council West Sussex County Worldham Parish Council Council Worthing Borough West Sussex Cycle Council Forum Worthing College West Sussex Local Access Forum WPB West Tisted Estate WSCC Local Access Forum West Tisted Parish Meeting WYG Westbourne Parish WYG Planning and Council Environment Westhampnett Parish Council

Individuals

Margaret Abbs Russell Cleaver

Dr Pietro Acciarri Derrick Coffee

Test Agent Alan Collett

Mr Simon Ainley Claire Cook

Ashe Geoff Cook Mr Jody Ashfield Mrs Gill Cooper Mr Simon Auty Mrs Gloria Cooper

Ayling Paddy Cox Ms Frances Bassom Mrs Allyson Crew

Val Bateman Eric Croft

Richard Bates Dallmeyer Mr Simon Bennett Bob Damper Clare Bennett Mr&Mrs P Dimmer Simon Bennett Joanna Dixon Cllr Nick Bennett Miss Susan Doman Mrs Val Bentley

Michael Blencowe Sue Dunkley

Mrs Marjorie Earle Halfway Bridge Mr Nevill Brooke Elliott

Michael Elliott Brooks-Fisher Elliott Brown Ellis Brown Ms Louise Ely Bob Brown Ms annie evans Nigel Brown John Evans Sir Brian Brown Farrands Brownsell Firth Gillian Carroll Tiffany Francis Mr Cheesewright Mrs Helen Freeston

Mr Colin Child Mike & Freeston Helen Mr Crawford Christie Mrs Lucy Clark Mike Gadd

clark Mr Andrew Gibson

Gareth Giles Clark Mr Peter Clarke Teresa Gittins

Tony Clarke Mrs Stella Goddard

John Claxon Mr Nigel Greenwood

Colin Hall Trudy McGuigan

Harold Hall Melson Helen Hamilton Mr Stephen Miles Andy Hannaford monckton

Mr Roger Hargreaves Remony Moser

SP Needham John Harmer Mrs Caroline Neville Mr Colin Harris Gemma North William Hartnell O'Brien- Michael Haughton Twohig Graham Heap Mr J Olphert Mr John Hernon Mr Peter O'Sullivan MARK HIPSEY Mr Lawrence Paine Angela Hopwood Mr John Palmer David Hutchinson Mr Tom Patton

Rebecca Pearson David Hutchison John Peart Richard Johnson Richard Pelly Glynn Jones Sarah Peskett Graham Joseph Mr Ian Phillips Josephi Stephen Prior Mr Christopher Josephi Claire Proctor Gill Kellett Mr David Pugh Pauline Kneen David Pugh La Hive Pullen Rebecca Landsberger Ms Deborah Richards

James Lepage Richard Ritchie

Mr Martin Lester roberts

Mr John Liddle Lynne Roberts

Eileen Lintill Rodwell

Mr Alex Lock Annabel Ross

Helmut Lusser Amanda Scott Prof F.J Maillardet Mrs Frances Sedgwick

Harold Makant John Shepherd Ann Markwick Mrs Susan Shone

MS Sheila Marshall Jack Slaughter

Mrs Karen Matthews Stephen Smart Mr Duncan McGregor Mr Toby Smith

Mr Paul Steele Waltham

stephenson Mrs E M Walton OBE

Mr Colin Stepney Mrs Sue Ward Mrs Gill Stevens Mr Mark Ward

John Stockdale Simon Ward Mr Geoff Watchorn Mr Bob Stoyle Julia Waterlow Strudwick John Webberburn- John Styles Maxwell Dr Jill Sutcliffe

LINDA WELLS Andrew Swayne Dr Andrew Tate Victoria Weston Mr Frank Taylor Mrs Hilary Westwater

John Templeton Mrs Pearl Wheeler

Chris Todd David White

Topp Rachel and Whitfield Quentin Mr Andrew Triggs John Wickens turnerhawkes Ron Wilder

Diana van der Klugt Williams Mr P Wilsdon John Vannuffel Mr Nicholas Wilson Martin Vasey Richard Wilson

Appendix 3

Summary of main issues raised by representations and how these have been taken into account

General Comments

Reg 22 (1) (c) (iii) There were a total of 86 general comments on the Local Plan. These are summarised below. National Agencies Portsmouth Water welcomed the publication of the Local Plan. Natural England request a policy on protecting soils. They also comment that there is a need to ensure that the balance of policy consideration is not weighted towards landscape designations over other equally important considerations and duties such as statutorily protected wildlife sites, species and biodiversity. Historic England comment that there are many cases of damage being done to historic assets throughout the National Park. They note that the State of the South Downs Report was produced in 2012 and some of the evidence may now need updating e.g. heritage assets at risk. In relation to the Duty to Co-operate Historic England note that they are required to cooperate with local planning authorities on strategic cross-boundary matters. They report that they are a member of the South Downs Partnership and are active in a number of ways with the Authority. Borough, City, County and District Councils Lewes District Council supports the majority of the Local Plan and consider that the general approach reflects the approach set out in the Lewes Joint Core Strategy. Winchester District Council congratulate the Park Authority on the document but comment that its size, complexity and layout does not allow for easy interpretation and application of policy. Key areas of concern are: • Some evidence documents are still in preparation and cannot have been used to inform policy preparation. • No policies map. • Not possible to assess whether the ‘preferred’ approach is the best when considered against reasonable alternatives. • Lack of site allocations. • Interpretation and assessment of concepts such as dark skies and tranquillity. • Lack of consistency – references to ‘small scale’ and ‘modest’ but no explanation as to what this means.

Adur and Worthing Borough Councils welcome the publication of the Local Plan and accompanying Duty to Cooperate Statement, they confirm that there has been ongoing cooperation between the Authorities and suggest some further detail that could be incorporated into an update to the Duty to Cooperate Statement. Horsham District Council confirm that both Authorities have engaged constructively and that the Horsham District Local Plan has incorporated a number of amendments to ensure that development outside the park boundaries does not conflict with the key purposes of the park. They welcome ongoing dialogue as the plan progresses and comment that Horsham occupies a key location where the park is at its narrowest, and contains a series of settlements that serves a proportion of the park’s population.

Wealden District Council consider that the Local Plan comprehensively addresses the issues facing the National Park. They considered that, in relation to issues impacting Wealden District, the Local Plan provides a good balance between protecting and enhancing the unique qualities of the National Park whilst recognising the need for development that is sustainable and appropriate to the Parks future. East Hampshire District Council requests that further monitoring of permissions by the SDNPA is undertaken within 400m of the Wealden Heaths area. They also ask that the SDNPA cooperates with them in order to provide monitoring information for East Hampshire as a whole. Mid Sussex District Council confirm that have no concerns about the policies and proposals within the plan. Eastbourne Borough Council welcome the publication of the Preferred Options. They support the majority of the aspirations and policies. • The identification of an Eastbourne HMA covering land within the Eastbourne Borough and Wealden District local authority areas is supported. Parish and Town Councils Buriton Parish and Liss Parish Councils consider that the plan is long and complicated; the message is lost in the detail, the diagrams are complicated, the language is general and open to interpretation etc. Liss Parish Council also comment that the thematic organisation of the plan is difficult to follow giving the impression it is organised around sustainability inputs rather than steering and controlling development. Finally they consider that the Local Plan needs to explain the relationship between it and the East Hants Joint Core Strategy in terms of housing figures more clearly as they are based upon different timescales. Bury Parish Council support the plan and recognition of the distinct character of villages in the scarp slope. However they consider the consultation period should be longer. Barlavington Parish Council consider the plan is balanced more in favour of development than protection of the National Park. Steep, Seaford, Droxford, Warnford, Lynchmere and East Meon Town and Parish Councils are generally supportive of the Local Plan, the range and quality of policies and evidence base. East Meon Parish Council confirm that their Neighbourhood Plan will allocate land with the objective being to accommodate 15 homes. However, this will have to have regard to the constraints imposed by the landscape. Lynchmere Parish Council consider there is a lack of good design criteria within the plan and it should be given as much consideration as landscape. They support development of brownfield sites and consider priority should be given to affordable and starter homes. The Parish Council considers that SDNPA needs to take more account of the infrastructure needs of parts of the National Park and they comment that the Syngenta Site needs to make provision to meet the increased demand in services. Midhurst Town Council make a range of comments about the needs of Midhurst town, including smaller and affordable homes, cycleways, signage. They consider that the plan does not make sufficient reference to health and education or the need for urban tree planting.

East Dean and Friston Parish Council ask that the Local Plan refers to giving support for local Village Design Statements and for Neighbourhood Plans. It would help if the hierarchy of plans can be made explicit and cross referenced. Owslebury Parish Council comment that smaller parishes should not be left out of the scope of the Local Plan. They are concerned that Owslebury has been overlooked and there is no mention of their Parish Plan within the document. They highlight the impact of development in neighbouring authorities and the impact they have in particular traffic. A number of comments are made from a range of people and organisations, not just Parish and Town Councils, about the use of the phrase ‘unacceptable adverse impact’. It gives rise to the question of what an ‘acceptable adverse impact’ might be? and it is felt to be inappropriate. Other minor points raised by Parish and Town Councils include a range of typo’s and a need for a list of abbreviations / acronyms. Other Organisations CPRE Hampshire, CPRE Sussex, Friends of the Earth Brighton & Hove, Friends of Lewes Society, Ricardo plc and the Upper Itchen Valley Society broadly welcome the Local Plan, including its scope and detail. Wiggonholt Association, CPRE Hampshire, Sussex Wildlife Trust and Hampshire & Isle of Wight Wildlife Trusts consider that placing Development Management policies after Allocations diminishes their importance. The plan would be more user friendly is they followed directly from strategic policies. Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trusts (joint response) would like to see this plan act as an exemplar for using an ecosystems services approach. However they consider that it is unwieldly and difficult to follow. It contains large amounts of introductory and supplementary text, often not reflected in policy wording. It is unclear what weight that supplementary text holds and they are concerned about ambiguity. Ricardo plc also comment that the plan contains a lot of jargon and subjective wording and West Sussex Local Access Forum generally welcome the plan but find it difficult to read. Friends of the Earth Brighton & Hove note that there is no policy on cumulative impacts. They also consider that more emphasis should be given to developing previously-developed land rather than greenfield land. Ricardo plc, who are a member of the South Downs Partnership, comment that more is needed within the plan on the economy and employment. The links to LEPs, devolution and economic strategies should be stronger and clearer and business tourism should be addressed. They ask what performance indicators will be used to measure success. The South Downs Society consider that an emphasis on the importance of protecting land in agricultural use for reasons of food security and managing/reducing food miles is absent from the plan. The South Downs Local Access Forum asked whether pollution caused by soil erosion can be covered. The Upper Itchen Valley Society have concerns about the development of 8 affordable homes in Itchen Abbas given the limited and expensive bus service.

Five Villages Cycling Forum comment on the importance of taking a holistic approach to the provision of facilities for residents and tourists. They also consider that the plan is silent on how changes in neighbouring areas can be made to enhance access to and enjoyment of the National Park Fittleworth and District Association are seeking clarification as to whether mineral applications will need to take into account the South Downs Local Plan transport policies. Lavant Residents for the Relief Road consider that the plan should acknowledge that some parts of the National Park are of a higher quality than others. A blanket application of restrictive policies will over time be seen as unjustified. They consider that the Local Plan should contain a statement recognising that the variety of landscapes across the National Park and its relatively built up character and history requires proposed developments to be considered on the basis of the community benefits they may deliver, the site specific landscape or other National Park qualities that might be affected and the scope for ameliorating any impacts. The Garner Group consider that the uniqueness of the National Park is miss-portrayed - the South Downs has no wilderness areas, the landscape is the result of thousands of years of man's intervention. This needs to be recognised in seeking to accommodate a level of development that focuses on living landscapes and meeting the needs of local people. They comment that the level of development should not be set artificially low. The Local Plan must embrace national planning policy to significantly boost the supply of housing for its residents. They consider that the authority has no idea about or care for where that unmet housing need is to be provided. The Goodwood Estate felt that the plan should set out the development requirements of the National Park clearly. West Dean supported the Plan but commented that

 Key evidence studies are not available to view at time of publication  The Local Plan needs to create the correct balance of social, economic and environmental objectives  Policies need to be flexible enough to allow landowners to respond to changing economic circumstances.  Policies need to be proportionate and not create an unnecessary burden on new development  No specific policies on educational facilities and the socio-economic benefits they bring.

The City of Winchester Trust comment that the National Park provides a valued setting for the city of Winchester. A number of minor amendments were suggested including figure 1.5 should show local authority boundaries as well as LEP boundaries, colours used as backgrounds, references to Highways Agency need to be Highways

Agents and Developers Tetlow King consider that much of the content is superfluous, it should be focused, concise and accessible. The Key Challenges section focuses too much on development pressure and its impact on habitats and landscapes. Wates Developments felt that in relation to housing the plan was not positively prepared, justified or consistent with national policy. There was support for the promotion of Bohunt Park as a strategic allocation. Comer Homes comment that parts of the Local Plan seek to go further than the NPPF and introduce unfounded considerations (such as exceptional and exemplar). They consider the draft plan to be unjustified and unsound as it is not in accordance with the NPPF. Individuals

 Preferred Options title is misleading.  It is a comprehensive plan that clearly sets out good intentions, well written, well documented with supporting detail, thorough, clear. Support the full coverage of the plan.  Local Plan is too jargonisitic  Local Plan does not fulfil its statutory purpose  Inadequate consultation process  Insufficient mention of agriculture. Forestry & farming should be given highest priority.  A vibrant farming community is able to preserve the landscape. The farming community has had to respond to significant change.  No policies on intensive farming matters eg use of herbicides and insecticides  Have existing local plan policies been reviewed?  No reference to common land.  No policies on golf courses  Query who pays for the conservation and enhancement?  Is the rural hinterland destined to be populated by pensioners, weekenders and local unemployed? What other work in the 21st Century will sustain the local population?  Lack of reference to mineral extraction. The lorries cause great concern to the locals due to noise and diesel fume pollution, damage to listed buildings. Particular concerns about Pendean Quarry.  Midhurst is not a Saxon Manor  No weight should be given to the emerging Local Plan at this stage.  Concern about development proposals in East Chiltington put forward by Lewes District Council. Poor site, limited infrastructure, no services, unsustainable, damage to wildlife, landscape, used as play space, traffic increase.  More housing is needed for local people.  Thought and care must be put into the exterior design / quality and type of materials. A committee should look at fabrics/materials being used. Wish to see more imaginative developments.  The Duty to Cooperate interim statement is not fit for purpose, it fails to explain how the various authorities have settled the SDNPA’’s housing requirement and who is picking up the, as yet, undefined shortfall.  The plan does not identify how it will meet the figure of a minimum of 100 dwellings in the other villages within East Hampshire.  The duty to cooperate should be transparent. Where matters of policy and requirement have not been agreed they should be clearly stated and reasons given for not meeting them.

 How will areas/villages not assessed as being suitable areas for development be protected if they do not have a neighbourhood plan? By having a neighbourhood plan it appears there is an understanding that there will be some development. A number of typo’s and word requiring further explanation were identified by individuals including:

 SD4/SS and SD4/WW have identical wording  ‘Scheduled monument’ rather than ‘scheduled ancient monument’  English Heritage rather than Historic England  ‘Heritage assets’ rather than ‘historic assets’  Correct word is ‘harm’ and not ‘impact’ in regard to development proposals affecting heritage assets.  Explanation of Environmental limits  Explanation of Natural capital  Explanation of Cultural heritage  Explanation of palimpsest A number of other matters were commented on which are unrelated to the Local Plan. These include the agency agreements between the SDNPA and the Districts and Boroughs that determine planning applications; enforcement matters; the process for determining planning applications and notifications of planning applications. One respondent questioned the democratic accountability of National Parks. Reg 22 (1) (c) (iv) The representations have been taken into account as follows:

 Historic England are named as a relevant ‘specific’ body with which the SDNPA has engaged constructively through Duty to Cooperate (para 1.28)  A Policies Nap and full core document library have been published with the Pre-Submission plan; they were not required as part of the Regulation 18 consultation.  A full set of allocations are set out in the Pre-Submission plan that along with allocations in neighbourhood development plans meet the development provision figures set out in this Local Plan  The preferred approach and the reasonable alternatives are explained both in the Sustainability Appraisal and the Pre-Submission plan (paras 3.117 to 3.121)  Further explanation is given on dark night skies (paras 5.45 to 5.60) and tranquility (paras 5.39 to 5.44)  The policies relating to the broad areas that referenced ‘small scale’ and ‘modest’ have been deleted.  Supporting text to policy SD10: International Sites commits the NPA to monitoring all development within the 400 metre zone around the Wealden Heaths Phase II SPA (para 5.91)  The role of village design statements is explained in chapter 1 (para 1.41)  The relationship between the Local Plan and neighbourhood plans is explained in chapter 1 (para 1.36 to 1.41) and chapter 7a (paras 7.5 to 7.6)  Owlesbury is identified in Policy SD25: Development Strategy as a village where the principle of development will be supported within the settlement boundary  The Local Plan policies have been re-ordered so that the strategic and development management policies are set out next to each other in three main chapters. This is explained in chapter 1 (paras 1.17 to 1.18).  The amount of introductory text has been reduced so that it is set out at the beginning of the chapter and not before each policy.

 The cumulative impact of development is addressed in criterion 3 of policy SD1: Sustainable Development.  Criterion 1b of policy SD25: Development Strategy prioritises the use of previously developed land.  Greater clarification is provided on the link between minerals and waste plans and this Local Plan in chapter 1 (paras 1.5 to 1.6)  Various changes were made to figure 1.5 (reference unchanged)  The development requirements for the Local Plan are set out in chapter 7.  The reference to Midhurst as a Saxon Manor has not been carried forward  Policy SD26 identifies villages in that part of the National Park located in East Hampshire District that meet the figure of new100 homes originally set I the Joint Core Strategy  Hollycroft Field, East Chiltington designated under policy SD47: Local Green Spaces  A further version of the Duty to Cooperate Statement has been published at the same time as the Pre-Submission Local Plan and deals transparently with housing.  A number of typos have been corrected. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason The structure of the plan is difficult to follow The structure of the Local Plan follows the and should be organised around steering and headings of the Partnership Management Plan controlling development Explanation should be provided of the link Further information is provided in the Housing between housing figures set in joint core Background Paper strategies and the Local Plan Request for more design criteria Policy SD5: Design seeks to ensure that all development is of the highest possible design quality Request for more account to be taken of Infrastructure needs are addressed through the infrastructure needs Infrastructure Delivery Plan Objections to the phrase ‘unacceptable adverse The phrase has been deleted from the plan impact’ used in a number of policies as a reason for refusing planning permission. Greater emphasis is needed on the economy This is a landscape led plan, which is and employment. appropriate for a nationally protected landscape. Employment is part of the socio- economic duty of national park authorities, which is pursuant to the purposes of national parks. Objection to 8 affordable homes in Itchen Abbas Site allocated under policy SD76 in line with the spatial strategy of the Local Plan Request that the plan should acknowledge that The highest level of landscape protection is some parts of the National Park are of a higher awarded to the whole National Park and it is quality than others and that a blanket not appropriate to identify areas of varying application of restrictive policies will over time landscape quality. The main evidence based be seen as unjustified. study supporting the Local Plan is the South Downs Integrated Landscape Character Assessment (SDILCA).

The uniqueness of the National Park is mis- The South Downs was established as a National portrayed and the Local Plan should significantly Park in 2010, which gives it the highest level of boost its supply of housing. landscape protection in the country. National parks are named in foot note 9 of the NPPF as an example of an area where objectively assessed need does not have to be met. Allocate Bohunt Manor as a strategic site The site was rejected in SHLAA on landscape grounds. The site is not adjacent to a settlement identified for development in policy SD25 of the Local Plan The plan focuses too much on landscape and Housing forms part of the socio-economic duty of not housing and so is not sound national park authorities. Section 11A(1) of the National Parks and Access to the Countryside Act 1949 places the duty in pursuit of the purposes. The plan is unsound as it introduces The SDNPA considers that the Local Plan is considerations that go beyond the NPPF consistent with national policy i.e. the NPPF and the Vision & Circular. Insufficient attention is given to agriculture in There is a Local Plan section on Agriculture and the plan Forestry. The subject is addressed more fully in the Partnership Management Plan Various requests for additional policies on a The Local Plan cannot have a policy on every number of subjects such as golf courses type of development. All relevant policies such as SD4: Landscape Character and SD5: Design will be applicable.

Chapter 1: Introduction

Reg 22 (1) (c) (iii) There were a total of 71 comments on this chapter. These are summarised below. National Agencies Natural England welcomed the Green Infrastructure Network and asked for it to be added to figure 1.3. Borough, City, County and District Councils Brighton & Hove City Council supported with the following changes to the Introduction: Refer to Brighton & Hove and not Brighton & Hove, refer to ‘Highways England’ and not ‘Highways Agency’ and refer to ‘development plan’ and not ‘local plan.’

East Hampshire considered that as this is a Reg 18 consultation no weight should be given to the emerging Local Plan and asked that appendix 1 should list what the policies will be replaced by.

Lewes District Council welcomed the Duty to Cooperate statement. East Sussex asked for greater explanation of the link between minerals and waste plans and the local plan. They also welcomed the ecosystem services approach to the Local Plan.

West Sussex supported how the NPA has engaged with WSCC on cross boundary strategic issues. Parish and Town Councils

Steyning Parish Council welcomed the emphasis on the statutory purposes of the National Park.

Liss Parish Council supported with the following changes to the Introduction fig 1.5 should identify administrative boundaries, further explanation of the links between the Local Plan and joint core strategies and appendix 1 should list what policies will be replaced by.

Bramshott and Liphook supported the Introduction and asked that more emphasis should be given to the statutory requirement for ‘all relevant authorities, including statutory authorities, including statutory undertakers and other public bodies, to have due regard to these purposes.’

Bury Parish Council thought that the change from an AONB to National Park designation should give a higher level of protection to the landscape and endorsed the 7 special qualities. Owslebury Parish Council commented that the NPA should ensure that partner LPAs ensures that the NP’s purposes and policies are fully understood.

Rowlands Castle Parish Castle commented that farming should be given more priority in figure 1.2 and supported the landscape led approach as long as it is flexible enough to recognise enterprise. It queried what would happen with neighbourhood plans that were made before the adoption of the Local Plan. East Dean & Friston Parish Council supported the landscape led approach and the protection of the Heritage Coast. Iford Parish Meeting supported the special qualities. Clapham Parish Council requested further clarity on what would happen to NDPs that had not reached pre-submission by the date set in the Local Plan.

Duncton Parish Council welcomed the advice that village design statements may be more appropriate for small villages than NDPs.

Liss Parish Council requested greater clarity that development proposals will be assessed against all relevant NDP and Local Plan policies.

East Chiltington Parish Council thought that the NPA should support parish councils that are too small to produce NDPs. Other Organisations Amberleigh House Limited supported the aims and objectives of the Local Plan.

The Petersfield Society welcomed the landscape led approach, the focus on ecosystem services and that the National Park should be an exemplar for sustainable development. It welcomed the NPA’sa support for NDPs It was concerned over the layout of strategic and DM policies. Thomas Hampshire Ltd requested greater clarity required on what the Local Plan is seeking to achieve. The Garner Group and Sunley Estates objected to the Introduction on the grounds that this was a Reg 18 consultation and so no weight should be given to the emerging Local Plan at this stage. Also objected to the landscape led approach of the Local Plan which was to the detriment of the duty to foster social and economic well-being of communities. Request greater clarity on what the Local Plan is seeking to achieve.

University College London strongly supported taking an ecosystem services approach to the Local Plan.

Thakeham Homes objected to the Introduction in regard to the Purposes and Duty.

Lavant Residents for the Relief Road commented that the South Downs does not include spectacular landscapes or wilderness areas and there should not be strong strictures against development.

CPRE Sussex supported the Local Plan which is focussed, amply evidenced and clearly expressed. It is a well- constructed Plan for development within the National Park. It aslo supported the special qualities. Sussex and Hampshire & Isle of Wight Wildlife Trusts supported the landscape led and ecosystem services approach of the Local Plan. Ricardo plc thought that reference should be made to devolution bids and links to LEPs. A number of organisations asked for administrative boundaries to be shown on fig 1.5. Agents and Developers

The Angmering and Cowdray Estates supported the plan and recognised the considerable effort that has gone into preparing it, noted that key evidence studies were not available to view at time of publication, commented that the Local Plan needs to create the correct balance of social, economic and environmental objectives, policies need to be flexible enough to allow landowners to respond to changing economic circumstances and proportionate so as not create an unnecessary burden on new development

Individuals The following comments were made:

 This is a Reg 18 consultation and so no weight should be given to the emerging Local Plan at this stage.  The landscape led approach of the Local Plan has been to the detriment of the duty to foster social and economic well-being of communities.  The South Downs does not have the same iconic landscape or wilderness areas of other national parks and so should deliver a higher level of development  Support for ecosystem services.  Support for landscape-led approach.  Greater clarity required on what the Local Plan is seeking to achieve.  A prosperous vibrant rural community without onerous restrictions being imposed is needed for the South Downs.  Exemplary articulation of purposes and duty.  Insufficient clarity on the status of NDPs in the determination of planning applications.  Proposed re-wording of national park duty.  Support required for villages not producing a neighbourhood plan.  Some parts of the National Park like Petersfield and Liss should be set higher development requirements.  The SHMA referred to in para 1.19 is not robust as it sets off from the premis that only a proportion of the housing need will be met.  Community led plans should also be made part of the development plan.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows:

 Various changes were made figure 1.3 (now figure 1.4) including the addition of the Green Infrastructure Framework  Various corrections to names of organisations and documents were requested and actioned including references to Brighton & Hove rather than Brighton and Hove  The point was made that no weight should be given to the Regulation 18 document. Legal advice was sought on the matter, which advised that weight could be given to the plan. An update is given on the weight to be given to this Reg 19 document (para 1.3)  Greater clarification was sought on the link between minerals and waste plans and this Local Plan. Further guidance is given and it is stated that this plan will replace all saved local plan and joint core strategy policies other than those policies relating to minerals and waste (paras 1.5, 1.6 and 1.35)  Various changes were made to figure 1.5 (reference unchanged)  Chapter 1 explains what policies will be replaced by the Local Plan and references appendix 2, which lists all the policies to be replaced and what they will be replaced by (paras 1.34 and 1.35)  Further clarification given on the risk of neighbourhood development plans (NDPs) leaving policy gaps in Local Plan (para 1.39 and 1.40)  Greater clarity provided on development proposals being assessed against all relevant NDP and Local Plan policies (para 1.36)  Concerns over the split of development management and strategic policies into different chapters of the plan is addressed by their re-grouping into topic based sections. This is explained in chapter 1 (paras 1.17 and 1.18)  More explanation given on what the Local Plan is seeking to achieve (para 1.10 and fig 1.1)

 Explanation that community-led plans such as parish plans may be more suitable for villages than NDPs (para 1.41)

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason More emphasis should be given to the statutory This is already set out clearly in figure 1.1 requirement for ‘all relevant authorities, including statutory authorities, including statutory undertakers and other public bodies, to have due regard to these purposes.’ Objections to the landscape led approach of Section 11A(1) of the National Parks and Access to the Local Plan which was to the detriment of the Countryside Act 1949 places the duty in pursuit the duty to foster social and economic well- of the purposes. being of communities. The South Downs does not include spectacular The South Downs was designated as a national landscapes or wilderness areas and there should not park due to its iconic lowland landscapes. As a be strong strictures against development. national park it has the highest level of national landscape protection along with AONBs. Reference should be made to devolution bids It is not possible to name all duty to cooperate work. The detail is addressed in the Duty to Cooperate statement. Proposed re-wording of national park duty. The duty is specified in the Environment Act: 1995. Some parts of the National Park like Petersfield and The development requirements set in this plan Liss should be set higher development requirements. are capacity based and landscape led. The requirements for Petersfield and Liss are carried forward from the East Hants Joint Core Strategy. The SHMA referred to in para 1.19 is not robust as The South Downs SHMA and its update have it sets off from the premis that only a proportion of been prepared in line with Government policy the housing need will be met and guidance. Community led plans should also be made part of Community led plans are not development plan the development plan. documents and so cannot be made part of the development plan. Further explanation is given on possible adoption as supplementary planning documents (SPD) (para 1.41)

Chapter 2: Spatial Portrait

Reg 22 (1) (c) (iii) There were a total of 66 comments on this chapter. These are summarised below. National Agencies Heritage England requested that separate key challenges were identified for heritage and habitats, that the Local Plan refers to ‘historic environment’ and ‘heritage assets’ rather than cultural heritage and proposed some additional wording on heritage at risk. Borough, City, County and District Councils East Sussex County Council pointed out that RAMSAR is not an acronym. Winchester City Council consider that insufficient regard given to the socio-economic duty Parish and Town Councils Selborne Parish Council welcomes the landscape-led plan, protection of special qualities and focus on ecosystem services. It also supports the mention of chalk aquifers as an ecosystem service. It supported the info graphic forming figure 2.4. It agreed with the issues and challenges identified.

Barlavington Parish Council stated that the plan does not address minerals, open cast mining and fracking.

Rottingdean Parish Council noticed the omission of Rudyard Kipling, Edward Burne-Jones and Enid Bagnold. Also welcomed recognition of high cost of housing, supported the use of local building materials and welcomed recognition of poor broadband.

Rowlands Castle Parish Council supports references to dark night skies, access to affordable housing and the aging population.

Iford Parish Council supports access to the National Park particularly for young people and agreed there was a broadband problem in the parish. It highlighted conflict between different users of the National Park.

Buriton Parish Council thought we should refer to ‘Superfast broadband’ rather than just ‘broadband.’

Steyning Parish Council agreed that affordable housing is an important issue.

Other Organisations The Brighton & Lewes Downs Biosphere asked for a reference to be added to the UNESCO Biosphere Region designation. The CPRE and the City of Winchester Trust supported the landscape led approach. The Sussex and Hampshire & Isle of Wight Wildlife Trusts support the section on why national parks matter and the use of the PMP as evidence base for the Local Plan. The South Downs Society supports the structure of the Local Plan and its emphasis on purposes and duty.

The NFU supports the reference to farming.

The South Downs Land Managers’ Group think that food, timber and water are more important ecosystem services than access and recreation. Also consider high house prices in the South Downs to be due location in south east England and affordable housing is not a problem restricted to working families.

Ricardo plc thought that specific economic targets should be set and travel to work patterns were also an issue.

The British Horse Society would like the number of horses to be added to fig 2.4. Agents and Developers The following comments were made:

 Key evidence based documents not available to view.  The landscape led approach of the Local Plan has been to the detriment of the duty to foster social and economic well-being of communities.  Not all the landscape of the SDNP is iconic.  Other economic activities such as quarrying should be mentioned. Individuals There were a number of comments received from individuals:

 The landscape led approach of the Local Plan has been to the detriment of the duty to foster social and economic well-being of communities.  Not all the landscape of the SDNP is iconic.  The special qualities are irreplaceable  Mention ‘enclosed wonderful almost secretive places’ under tranquillity  The AONB provided sufficient protection for the South Downs  A living landscape means that change happens  The link between landscape and people existed before the creation of the National Park  Tranquillity and dark night skies are threatened by the growth of Gatwick Airport  Development outside the National Park threatens dark night skies.  Explanation required of acronyms  Queried the 46 million visitor days to the National Park.  Need to ensure that settlements are as much of the landscape as open countryside.  Support for commentaries on towns and villages  More explanation required of sustainable development  Issues raised of broadband issues in specific villages  Visitor pressures will destroy the special qualities of the National Park  Reference required to NERC under key challenges.  Highlighted issue of charity events on the South Downs Way  Conflict between different users of the National Park  Not meeting housing need is a key challenge Please note that Chapter 2: Spatial Portrait of the Local Plan: Preferred Options has been incorporated into Chapter 2: Spatial Portrait and Spatial Strategy of the Pre- Submission Local Plan.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Clarification is given in chapters 2 (footnote 13) and chapter 5c (para 5.101) on the differences between cultural heritage and historic environment  Reference is made to ‘superfast broadband’ rather than just ‘broadband in chapter 7 of the Local Plan  Reference has been added to the UNESCO Biosphere Region designation (para 3.48)  Chapter 6 refers to the the South Downs Visitor and Tourism Economic Impact Study report, which noted that, in 2011/12, 46 million visitor days were spent in the National Park (para 6.48)  Chapter 5 states that the definition of landscape encompasses all types and forms including townscape (para 5.19)  Reference is made to visitor pressures in chapter 6 (para 6.55)  The challenge of not meeting housing need is an important issue addressed under the heading ‘level and distribution of housing growth’ (para 3.117 to 3.123) and in section 7b: Homes (Strategic Policies) The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason The plan does not address minerals, open cast Topics covered in relevant minerals and waste plans mining and fracking. Request to mention certain historic characters In order to have a clear and succinct plan it is not possible to mention all locally significant people Food, timber and water are more important Ecosystem Services have not been prioritised in ecosystem services than access and recreation. the Local Plan Specific economic targets should be set and Employment land requirements are set in travel to work patterns were also an issue. policy SD35. Travel to work patterns are assessed in the Employment Land Review (ELR) Objections to the landscape led approach of Section 11A(1) of the National Parks and Access to the Local Plan which was to the detriment of the Countryside Act 1949 places the duty in pursuit the duty to foster social and economic well- of the purposes. being of communities. Not all the landscape of the SDNP is iconic The South Downs was designated as a national park due to its iconic lowland landscapes. As a national park it has the highest level of national landscape protection along with AONBs.

Chapter 3: Vision and Objectives

Reg 22 (1) (c) (iii) There were a total of 40 comments on this chapter. These are summarised below. National Agencies Historic England and Natural England requested separate objectives on historic environment and biodiversity. Natural England advise that a clear link should be made between the Local Plan objectives and the Partnership Management Plan. Natural England advise that a clear link should be made between the Local Plan objectives and Local Plan policies. Borough, City, County and District Councils Chichester DC requested separate objectives required on historic environment and biodiversity. Horsham DC supported the vision and objectives. Hampshire CC supported the vision and objectives particularly in regard to climate change. Parish and Town Councils Rottingdean Parish Council, Iford Parish Meeting, Selborne Parish Council supported the vision. Plumpton Parish Council asked whether local residents would be disempowered by the NPA being the LPA. Rowlands Castle Parish Council thought that the Vision should relate to the plan period ie up to 2032 rather than 2050 Selborne Parish Council noted that the Vision required targets. Rowlands Castle Parish Council requested more explanation of ecosystem services and for some flexibility in regard to businesses being compatible with the special qualities of the National Park. Other Organisations CPRE supports the vision and objectives and asked for a more logical ordering of the objectives. The National Trust supports the vision and objectives. The Design Review Panel thought that the vision and objectives should prioritise design and that we should be clearly differentiate between ‘conserve’ and ‘preserve.’ Arundel Chamber of Commerce supports the vison but considers many of the Local Plan policies to be unduly onerous. Lavant Residents for the Relief Road thought that villages should be enhanced as well as the landscape and that residents are as important as visitors.

Agents and Developers The following comments were made:

 The objective on villages and market towns should also refer to increasing the supply of housing.  The vision should refer to learning institutions and specific visitor attractions  The vision should refer to quarrying.  Separate objectives requested on historic environment and biodiversity.  The objectives should embrace opportunities to enhance the landscape through the restoration of quarries. Individuals The following comments were made:

 Several individuals supported one of or both the vision and objectives  Several individuals thought that the vision was wishful thinking.  Farming and forestry should come first and not last in the vision.  Several individuals questioned why cultural heritage and biodiversity were combined in one objective.  The vision should refer to the wider economy around the National Park.  The objective on villages and market towns should also refer to increasing the supply of housing. Reg 22 (1) (c) (iv) The representations have been taken into account as follows:

 Separate objectives for cultural heritage and biodiversity.  New paragraph in chapter 1 describing the links between the PMP and Local Plan objectives (para 1.11)  More explanation given for ecosystem services in the Chapter 1: Introduction (para 1.14 to 1.16)  Objective amended so that ‘Business activities that are broadly compatible’  New objective relating to the socio-economic duty including the provision of housing.  All policies linked to specific Local Plan objectives throughout the plan.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason The Vision should relate to the plan period i.e. The Vision is carried forward from the PMP and up to 2032 rather than 2050. goes up to 2050. The objectives and policies are stepping stones from the vision to the local plan period. The Vision requires targets. Targets are set in the PMP More explanation of ecosystem services. Further explanation of ecosystem services given in introduction The vision and objectives should prioritise The Vision is carried forward from the PMP. design. Clearly differentiate between ‘conserve’ and Conserve has been used consistently ‘preserve.’ throughout the Vision. The objective on villages and market towns New objective relating to the socio-economic duty should also refer to increasing the supply of including the provision of housing To protect and housing. provide for the social and economic wellbeing of National Park communities supporting local jobs, affordable homes and local facilities The objectives should embrace opportunities This is matter for minerals and waste plans. to enhance the landscape through the restoration of quarries The vision should refer to learning institutions The Vision is carried forward from the PMP and and specific visitor attractions. does not go down to this level of detail. The vision should refer to quarrying. The Vision is carried forward from the PMP. This a matter for minerals and waste plans. Several individuals thought that the vision was A Vision is meant to be aspirational but grounded in wishful thinking. reality. Farming and forestry should come first and not Farming and forestry relate to the duty and not the last in the vision. purposes and so should come second The vision should refer to the wider economy The Vision is carried forward from the PMP and around the National Park. relates solely to the National Park

Chapter 4: Core Policies

Reg 22 (1) (c) (iii) There were a total of 242 comments on this chapter. These are summarised below. Comments on Introduction

There were a total of 6 comments on the introduction (paragraph 4.1) of the chapter. These are summarised below. National Agencies There were no comments made on paragraph 4.1 by National Agencies. Borough, City, County and District Councils There were no comments made on paragraph 4.1 by City, County, Borough and District Councils. Parish and Town Councils Selborne Parish Council agreed with paragraph. Lodsworth Parish Council expressed support for chapter, but commented that the document as a whole is convoluted and excessively wordy. Other Organisations Bignor Park Estate expressed support but commented that they consider the policies to be pointless if there are not sufficient powers, money or resources are available for enforcement. The South Downs Network made a number of general comments:

 They strongly support the ecosystems services approach and placing landscape and the special qualities at the heart of the decision making process.  They strongly support the aim of the Plan to be an exemplar in sustainable development.  They consider the right way to consider development to ensure that the natural capital of the National Park is not lost and is able to sustain the local communities that live within it and the many visitors who enjoy its special qualities and contribute to the local economy  Express concern that there is no policy on the cumulative impact of development and consider this omission to be surprising given that this why many people wanted a National Park with strong planning powers to be able to tackle the ‘death by a thousand cuts’ brought about by small incremental damaging change.  They consider that prioritising the development of brownfield land over greenfield sites should be given greater emphasis.

Wiggonholt Association support the four core policies, which they consider will provide the overarching framework for evaluating all development proposals in the National Park across the board. They attach particular importance to the first two. Agents and Developers There were no comments made on paragraph 4.1 by agents or developers. Individuals There were no comments made on paragraph 4.1 by individuals.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Policy SD1(3) and its supporting text (para 4.7) address the cumulative impact of development  Policy SD25: Development Strategy priorities the use of PDL in criteria 1(b) and 2(d)

Policy SD1: Sustainable Development in the South Downs National Park

Reg 22 (1) (c) (iii) There were a total of 34 comments on this policy/chapter. These are summarised below. National Agencies Historic England welcomes and supports recognition of the reference to cultural heritage in the supporting text. They recommend that Figure 4.3 could also include reference to historic parks and gardens and battlefields. Natural England commented that there is no reference made to the need to consider and protect wildlife and biodiversity. Borough, City, County and District Councils There were no comments made on Policy SD1 by City, County, Borough and District Councils. Parish and Town Councils Three Parish Councils made comments regarding the statement in paragraph 4.5 regarding SDNPA working in partnership with other local authorities to ensure it that development outside of the National Park does not have a detrimental impact on its setting or otherwise prejudice the achievement of the Purposes.  Plumpton Parish Council consider this to have potential to over-rule wishes of local community whilst being excluded from the benefits of protection within the National Park and this conflicts with the principle of self-determination that is claimed to be at the heart of neighbourhood planning and this Local Plan. They are concerned that this conflicts with the principle of self-determination that is claimed to be at the heart of neighbourhood planning and this Local Plan.  Rowlands Castle Parish Council consider this to very insular view and that it should be recognised that the SDNP can have both a beneficial and adverse impact on areas outside and adjacent to the National Park. They comment that the SDNPA should work with representatives of areas which may experience adverse impacts in order to minimize them and it should be a mutual Duty to Cooperate.  Steyning Parish Council welcome and supports the statement

A number of Parish Councils (and Parish Meetings) state their support for the policy:  Selbourne Parish Council  Madehurst Parish Meeting  Patching Parish Council

Patching Parish Council support the policy and consider that this and other policies support the control of development in small downland villages and provide a good platform for their emerging neighbourhood plan.

Madehurst Parish Council request that further clarification is given to what the ‘material considerations’ are (referenced in criteria 3).

Rowlands Castle Parish Council are unclear on the meaning of criteria 1 (b) of the policy (relating to the duty) and request that this is rephrased.

Steyning Parish Council welcomes the clarity provided by criteria 1 of the policy.

Other Organisations A number of organisations made comments on the statement in paragraph 4.5 regarding SDNPA working in partnership with other local authorities to ensure it that development outside of the National Park does not have a detrimental impact on its setting or otherwise prejudice the achievement of the Purposes.  City of Winchester Trust specifically reference the employment allocation of the former camp area (Bushfield Camp) on Bushfield Down and state that it is important that there is no adverse impact from any development of Bushfield Camp on views from St Catherine’s Hill.  CPRE Hampshire asked if, for the assistance of neighbouring authorities, the Plan should list the types of development are likely to have such an adverse impact.

A number of organisations state their support for the policy, including:  CPRE Sussex  Friends of Lewes Society  Friends of the Earth (Brighton & Hove)  Sussex Wildlife Trust  Hampshire and Isle of Wight Wildlife Trust  South Downs Society  South Downs Land Managers Group

The Goodwood Estate consider there is an overriding issue with the Plan that it fails to recognise the long term needs of the rural areas in terms of sustainability. The key aim is to protect the status quo rather than take positive steps to enhance the National Park and to allow rural areas to develop and become sustainable in terms of communities, rural jobs and housing. Hampshire and Isle of Wight Police & Crime Commissioner’s Office emphasised the importance of considering crime and disorder when planning a development. If they are not considered at the early stages of the developmental process, it can make them difficult and costly to deal with after the development is completed. They note that there is no reference to the prevention of crime and disorder within the document. Request that a paragraph is inserted within the document (perhaps within the Core Policy SD1), indicating that crime and disorder is an aspect of the design that will be considered at the appropriate time. To inform the process, in their submission, developers must show how potential crime and disorder issues have been assessed and mitigated.

The South Downs Society support the policy. However, they have commented that there is a lack of clear policies aimed at achieving the park’s statutory purposes, other than through the mechanism of responding to planning applications of which the primary aim will not necessarily be the achievement of those purposes. They argue that even where planning permission is not required, there should be a clear statement in the plan that such positive activity is to be supported. They acknowledge that this may be included in the PMP but argue that it should be more than a reactive device.

Sompting Estate strongly support the statement in paragraph 4.5 regarding SDNPA working in partnership with other local authorities to ensure it that development outside of the National Park does not have a detrimental impact on its setting or otherwise prejudice the achievement of the Purposes. They comment that the boundary is freely crossed by wildlife, views and people enjoying the countryside and in many locations the special qualities valued within the boundary are present and valued outside the National Park.

Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trust (joint response) stated their strong support for the policy and consider that the core policies ensure a rigorous framework for development in the National Park and are in accordance with the NPPF and Vision and Circular. They strongly support the definition of sustainable development in paragraph 4.2.

The Wiggenholt Association commented that the presumption in favour of sustainable development lies at the heart of the NPPF and as such applies to all Local Plans. The definition in paragraph 4.2 is rightly identified as the starting point for the Local Plan. Cumulative impact is a potential problem which is only mentioned in Policy SD3. In order to avoid unnecessary repetition asks if this can be incorporated in Policy SD1.

The South Downs Land Managers Group support and welcomes the positive wording of the policy and supports and welcomes Criteria 3.

The National Farmers Union (NFU South East Region) recognise the importance of the purposes and need to include them in a core policy, but have expressed concern that this may prevent utilitarian structures required for the continuance of agricultural operations. The request that further clarification on any exceptions by which a development may not necessarily comply with the requirement to conserve and enhance the special qualities of the Park. They support criteria 3 of Policy SD1.

CPRE Sussex support the policy and supports the weight given to conservation of landscapes and scenic beauty in development considerations.

Agents and Developers The Home Builders Federation made a number of comments related to presumptions in favour of sustainable development:

 They question the assertion in the SHMA on page 12 that that paragraph 14 of the NPPF does not apply.  They do not consider that designation as a national park means that the Authority is not bound by the presumption in favour of sustainable development and that other national planning policy need not necessarily apply.  They consider that it is the task of the SDNPA to provide a local interpretation of how the presumption will operate in the Park (paragraph 16).  That applications for development of allocated sites should be determined without delay where they accord with the development plan.  The plan worded in a negative way.  They consider that the plan should enable allocated sites to be able to come forward swiftly and not create further obstacles to delivery of these sites. Callstone Ltd consider that the principle and sentiment of the policy laudable, but that requiring standards over and above current national targets is not sound or justifiable. They argue that the requirements need to be weighed against whether they are viable and practical and the economic viability of development must not be jeopardised. They consider this to be a disincentive to develop in the National Park which will have an effect on delivery rates and argue that the National Park should meet its housing and other needs and to not do so would fail to deliver the sustainable principles of the planning system, which is its golden thread. Wates Development Ltd consider there to be too much emphasis is given to the environmental element of sustainable development. The three strands of sustainable development should be taken as a whole. Recommend that criteria 2 is deleted.

Dudman Group of Companies consider there to be potential conflict in criteria 1c of the policy and suggest that it is amended to read “Conserve and/or enhance…”

Individuals One individual stated their support for the statement in paragraph 4.4 regarding great weight should be given to conserving landscape and scenic beauty in national parks. However, they consider to be challenging to administer given pressure for housing in the South East. One individual stated their support for the policy and commented that the whole section could be summed up in the sentence in paragraph 4.4. One individual stated their support for the aspirations of the policy, but commented that care should be taken not to ‘freeze’ the Park and that there should be consideration of interpretation of housing need and it important not to shut out new people, particularly families which will bring vitality to the towns and villages. One individual requested that Policy SD1 should be amended to reflect that proposals should comply with policies in the Local Plan and neighbourhood plans (i.e. amend criteria 1(d) and criteria 3 to add reference to neighbourhood plans). Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Policy SD1 (2) lists the three aspects of purpose 1 including wildlife.  SD1.2 clarifies the differences between the purposes and the duty  Additional supporting text is provided on material considerations (para 4.10)  To provide greater clarity policy SD1(b) has been reworded as follows: ‘In pursuit of the purposes, the National Park Authority will pay due regard to its duty to seek to foster the economic and social well-being of the local communities within the National Park.’ (SD1(2)  Although crime and disorder is not addressed in SD1, it is addressed in criterion j of SD5: Design.  Cumulative development is addressed in criterion 3 of SD1.  Although agricultural buildings are not addressed in policy SD1 they are addressed in policy SD39: Agriculture and Forestry.  SD1.4.b requires compliance with policies in the development plan, which includes both the Local Plan and neighbourhood development plans.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Figure 4.3 could also include reference to This diagram is not included in the Pre- historic parks and gardens and battlefields. Submission Local Plan

Objections to paragraph 4.5 regarding SDNPA The SDNPA continues to work positively with its working in partnership with other local neighbouring local authorities, which are authorities to ensure it that development obliged under Section 62 of the Environment outside of the National Park does not have a Act to have regard to the purposes of the detrimental impact on its setting or otherwise National Park. prejudice the achievement of the Purposes. Wider reference should be made to achieving This is addressed through the Partnership the statutory purposes of the National Park Management Plan The HBF made a number of comments relating to Agree that the presumption in favour of the presumption in favour of sustainable sustainable development does apply in the development in the National Park National Park as set out in SD1, but that is in the context of a nationally protected landscape. National parks are named in foot note 9 of the NPPF as an example of an area where objectively assessed need does not have to be met Too much emphasis on the environmental Criterion 2 is based on the Sandford principle element of sustainable development and established in 1974 by the National Parks Policy criterion 2 of the policy should be deleted Review Committee Amend wording to ‘conserve and/or enhance’ The wording is taken from the 1995 Environment Act and there are several references in the NPPF to ‘conserve and enhance.’

Policy SD2: Ecosystem Services

Reg 22 (1) (c) (iii) There were a total of 51 comments on this policy. These are summarised below. National Agencies The Environment Agency support the overriding principles of this policy and in particular the specific reference to the need for development proposals to conserve water resources, sustainably manage land and water environments, improve resilience to and mitigation of climate change, reduce pollution and mitigate the risk of flooding. They suggest that to strengthen the policy could require development proposals to both “manage and mitigate” the risk of flooding. Historic England welcomes and supports recognition of the reference to cultural heritage in paragraph 4.19. They recommend Figure 4.3 and paragraph 4.19 could also include reference to historic parks and gardens and battlefields. They object to Policy SD2 due to the lack of reference to cultural heritage and/or historic environment. They welcome and support the reference to historic nature in clause 2a) of Policy SD2.

Sport England welcomed recognition of the opportunities provided by the National Park to ‘improve opportunities for people’s health and wellbeing’. They have objected to the Local Plan, because it does not address the provision or protection of formal sports facilities for resident communities and recommends following Sport England guidance to ensure the provisions of NPPF are fully met.

Natural England welcome Policy SD2 and strongly supports the ecosystems approach to the Local Plan, which is supported by NPPF, They made a number of comments:  They advise that clearer links are made to ecosystems services through the document. Policies such as SD12 for example do not cite the ecosystems services approach.  They advise that care is taken that the National Park designation does not override other considerations such as statutory wildlife sites. A number of policies omit reference (most notable SD1) and biodiversity or wildlife, is not emphasised as a key consideration throughout.  Welcome clear explanation of the ecosystem services and the pictogram  Climate amelioration is mentioned suggest the inclusion of the provision of space for climate change adaptation and promotion of the ability to adapt.  Advise that point “g) reduce pollution” should state “improve water quality”. This is because this includes both ground and surface water and is in line with the Water Framework Directive. This aims to provide improvement and not only cessation of pollution.

Borough, City, County and District Councils Brighton &Hove City Council support the embedding of the ecosystem services approach. East Sussex County Council suggest the policy could be strengthened by changing the wording to ‘…mitigate and where possible reduce the risk of flooding' Chichester District Council commented that it is not clear why cultural heritage is included as an ecosystem service (in the supporting text) but not mentioned in Policy SD1. They also comment that the Plan will need to demonstrate how provision for green businesses is being planned for (mentioned in paragraph 4.14). They suggest that the National Policy Context should make reference to paragraph 7 and paragraph 17 of the NPPF.

East Hampshire District Council consider that this policy duplicates other policies and makes the policy repetitive and whole document unnecessarily long.

Parish and Town Councils Selborne Parish Council welcome and support the policy. Madehurst Parish Meeting supports the policy. They suggest a more explicit definition of ‘high quality sustainable design’ as this is subjective. Patching Parish Council supports the policy and consider that this and other policies support the control of development in small downland villages and provide a good platform for their emerging neighbourhood plan. Arundel Town Council suggest deletion or précis sub-paras a to k as they are too restrictive. Bramshott and Liphook Parish Council fully support and comment that the policy appears to encompass the key environmental factors. They suggest that key independent stakeholders such as wildlife trusts, RSPB, and CPRE should be statutory consultees for major development proposals.

Rowlands Castle Parish Council support the policy and made the following comments:

 the policy refers to 'reduce pollution' but does not describe to what types of pollution this refers and it does not appear to provide the same level of protection that is afforded by the EHDC/SDNP JCS Policy CP27 – Pollution. They recommend amending Policy SD2 or add another policy, to provide similar protection to that afforded by Policy CP27.  acknowledges reference to water management in criterion b) and c) of Policy SD2 and on page 22. However, EHDC/SDNP JCS policy ('Water Resources/Water Quality') is more prescriptive. Suggest that the policy is amended in order to make it easier to judge compliance with it.  Suggest increasing the priority to stimulate economic activity as all the other imperatives are surely dependent on generating wealth.  Suggest moving i), j) & k) into a new category – with economic activity as the first priority – these are separate from the environmental requirements that should be listed separately. Rowlands Castle Parish Council made a general comment multiple policies refer to ‘unacceptable adverse impact’ or ‘adverse impacts’ but no indication is given on how this would be assessed. Difficult to assess compliance with policies and suggest criteria are clarify what could be considered an ‘unacceptable adverse impact’ or ‘adverse impacts’.

Other Organisations RSPB welcomed the inclusion of a policy on ecosystem services. They did comment that it is not clear what constitutes an ‘unacceptable adverse effect’ and recommend this is replaced by ‘significant adverse effect’. CPRE Hampshire comment that definitions of ecosystem services and natural capital should be incoluded in the glossary. CPRE Sussex supports the policy and welcomes the approach. They are concerned about the repeated use of the phrase ‘unacceptable adverse impact’ and consider it to lack any objective evaluation criteria and thereby invites repeated litigious challenge. Their preference would be to remove the word ‘unacceptable.’ Friends of Lewes Society support the policy. South Downs Society supports the policy.

Friends of the Earth (Brighton & Hove) support the policy and suggest the removal of ‘unacceptable’ before ‘adverse impact’. Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trust commented that this is a template policy and approach that other local planning authorities should aim for and adopt. They recommend strengthening the policy by amending criterion a): “provide more, better and joined up natural habitat”. This would make the policy more effective and in line with the government’s 2020 biodiversity strategy and the Natural Environment White Paper. Gilbert White Museum commented that the reproduction of the table on page 33 is poor. They also question whether the Western Weald (referenced in paragraph 4.19) is sufficiently widely understood by those who will read the Plan and suggest the broad spatial diagram (Figure 4.4) should appear earlier than page 41. Wiggenholt Association acknowledges that the Local Plan has made safeguarding ecosystems services a basic principle. They suggest amending criteria 1 to use term 'respect' instead of 'do not have an unacceptable adverse impact on' which is too weak. They commented on the lack of reference in the policy (with the possible exception of 1(k) (sustainable design)) to the fourth service ‘Cultural Services’. They consider this omission to reflect a more tentative approach to the third part of the first purpose. South Downs Land Managers Group support the ecosystem services approach as principle underpinning the Local Plan. They strongly support the wording of criteria 1 “provided that they do not have an unacceptable adverse impact on the natural environment …” as a better approach than unfeasible ‘no harm’ wording. They also note that paragraph 4.6 is a repeat of section 1 and Figure 4.1 is a repeat of Figure 2.3. The Angmering Estate, Cowdray Estate and West Dean – The Edward James Foundation commented that the Plan should recognise the important contribution that increasing the supply of housing can make to the rural economy and benefit of local communities to support thriving places. The benefits of housing should be reflected in Core Policy SD2 (Ecosystem Services) alongside sustainable economic activity and high-quality sustainable design. The Sompting Estate supports the use of wording ‘unacceptable adverse impact’ and consider it to be a sound approach which recognises the balanced judgement that will often be made by officers and Members. Lancing College consider that the policy and Figure 4.3 should make reference to the National Park being a place in which people also learn and accordingly should benefit from improved learning and educational environments and it should make reference to the need for the sustainability of economic and institutional based activities within the National Park to be defined as activities that have a long term future, such that their requirements to adapt and change their functions and accommodation within their estates will be supported by the Local Plan. They also commented that Figure 4.3 should make reference to acknowledge wider estate stewardship roles, which present ongoing financial obligations and challenges that must be met to ensure the long term maintenance and enhancement of large estates, their heritage assets and their resulting landscapes that have helped to define the National Park as a special place.

National Farmers Union (NFU South East) question the absence of any measurable criteria in relation to the term "as appropriate" in this policy. They are concerned about how this would be applied and where it could be considered that delivery of a particular service was not appropriate for that type of development. They consider that greater clarity is required on how these services will be assessed as being appropriate to particular applications.

The Leconfield Estate comments that the Plan should recognise the important contribution that increasing the supply of housing can make to the rural economy and benefit of local communities to support thriving places. The benefits of housing should be reflected in Core Policy SD 2 (Ecosystem Services) alongside sustainable economic activity and high-quality sustainable design.

Brighton & Lewes Downs Biosphere strongly welcomed the visionary approach taken to adopt an ecosystems approach with a fundamental emphasis on provision of ecosystem services.

The Design Review Panel commented that consideration should be given to bio security issues/ country side security and native species/movements of plants. The plan should include ways of dealing with environmental, social, and economic changes: impacts of global warming-caused plant and animal species declines and successes, human population shifts, flooding and changes in agriculture and industry, and how these can be addressed/what measures can be built in in order to adapt to change.

Agents and Developers There were no comments made by agents and developers on this policy. Individuals Two individuals commented that the policy seems to be summary and is a duplication of elements of other policies. One individual suggested policy is omitted and reference made to detailed policies elsewhere. One individual commented that climate change mitigation and adaptation will both be needed to ensure the Park functions. The policy does not included adaptation and only refers to mitigation and increasing resilience. One individual stated their support for the policy. One individual commented that the use of an ecosystems approach as a foundation and framework for planning in the National Park is highly appropriate and this is an opportunity to pioneer the application of national policy on ecosystems approach on a landscape scale. One individual commented that it is an excellent holistic approach and they support importance given to ecosystem services. One individual commented that criteria 1 is the key to the whole ethos of the National Park, Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Criterion 1d of policy SD2 amended to ‘manage and mitigate’ the risk of flooding.  Reference to ‘cultural resources’ added to criterion SD2.1.k  Provision and protection of formal sports facilities is addressed in policy SD46: Provision and Protection of Open Space, Sport and Recreational Facilities and Burial Grounds/Cemeteries.  More links to ecosystem services are made throughout the plan  Clarification is given on the interlinking of Policy SD2 and other Local Plan policies (para 4.17)  Criterion 1c states ‘improve water quality.’  High quality design is explained in the supporting text of policy SD5: Design (para 5.19)  The policy reference to ‘unacceptable adverse impact’ has been deleted from the policy  Definitions of ecosystem services and natural capital have been added to the glossary  Criterion 1b of policy SD2 amended to ‘provide more, better and joined up natural habitats.’  The phrase ‘as appropriate has been deleted from policy SD2.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Address climate change adaption in Policy SD2 The policy addresses resilience to and mitigation of climate change (SD.1 e) Delete criteria a to k as they are too restrictive The policy criteria encourage development proposals to take a positive approach to the delivery of ecosystem services and are not unduly restrictive Prioritise economic development as all Ecosystem services are the benefits that people ecosystem services are dependent on this get from the environment. An ecosystem services approach helps us to value nature. Add housing and economic development to the These are not part of the benefits that people policy criteria get from the environment. These important issues are addressed elsewhere in the plan Add references to learning and educational A specific reference is not made, but education establishments in the National Park. is defined as a cultural service under figure 1.3: The four aspects of Ecosystem Services Add references to bio security issues/ country These matters although important are beyond side security and native species/movements of the remit of the Local Plan plants.

Policy SD3: Major Development in the South Downs National Park

Reg 22 (1) (c) (iii) There were a total of 44 comments on this policy. These are summarised below. National Agencies Historic England made the following comments:

 Request that para 4.25 is amended to included reference to the historic environment  Suggest that the term ‘harm’ would be more consistent with NPPF than ‘adverse impact’.  Question if this a justifiable interpretation of "major development" and application of the prescribed considerations for assessing such proposals.  Paragraph 4.23 states that "major development" will be given its "common usage”. Suggest this is in terms of nature and scale rather than impact, which we consider would commonly be a separate step to determining whether or not the proposal is major development.  The Authority's legal advice refers to "serious" adverse impact - is this the Authority's test for "unacceptable" Natural England made the following comments:

 Surprised that this key policy does not include the need to consider impacts on statutorily protected wildlife sites or biodiversity. Policy considers impacts on the designated landscape but not designated wildlife sites. Acknowledge that their protection falls under separate policy but advise that this policy should be revised to include the requirement to assess these impacts.  The impact of development proposals on habitats and/or species listed as ‘Habitats and Species of Principal Importance’ within the England Biodiversity List, published under the requirements of S41 of the Natural Environment and Rural Communities (NERC) Act 2006 should be also included. Borough, City, County and District Councils

East Hampshire District Council request further clarification on criteria 2 (c) and whether ‘outside the designated area’ means outside the SDNP. They consider it unclear how this criteria would be implemented or if it is reasonable.

East Sussex County Council made the following comments:

 Benefit from a general explanation on how the Local Plan will work in tandem with Minerals and Waste policies in the South Downs  The definition of major development should be highlighted and possibly included within the policy.  Given the prevalence of major development, as defined in the DMPO 2015, within minerals and waste this would provide clarity as to when this policy should be applied to waste and minerals development.  Policy should cross reference to relevant minerals and waste policies in existence. Wealden District Council are interested that major development is not defined and acknowledge that this is difficult in a protected landscape with little guidance available. They are currently considering this issue for the High Weald AONB and would welcome discussion. West Sussex County Council suggest that major development is more clearly defined.

Parish and Town Councils Bramshott and Liphook Parish Council consider that robust evidence should be provided with all minor proposals to ensure that major development is not required within the National Park in order to deliver the proposal. They refer to the example of Liphook, where number of minor applications have been approved which fail to take into account that major housing development would be required in order to deliver these proposals. Buriton Parish Council note that paragraph 4.28 refers to the important matter of cumulative development, but comment that this does not appear to be covered in the policy. Madehurst Parish Meeting fully support the policy, but are concerned that the interpretation of ‘unacceptable’ is too subjective. They also ask if criteria 2 a) to e) in any specific order and what are the priorities. Patching Parish Council support the policy and consider this and other policies to support the control of development in small downland villages and provide a good platform for their emerging neighbourhood plan. Selborne Parish Council support the principle of the policy but make the following comments:

 strongly believe that the phrase ‘serious adverse impact’ should be removed from the supporting text at 4.23.  the words "unacceptable adverse impact" in the policy should be removed because it implies that an adverse impact can be acceptable in a national park. They note that during the public enquiry into EHDC's Local Plan Second Review, the Council was not allowed to use this terminology and the Inspector replaced it with the words "cause harm" or "harm" Woolbeding with Redford Parish Council support the policy. They suggest that sustainability should include the concept of embedded carbon (i.e. life cycle). This has implications in looking at long term viability and also financial sustainability of a scheme. Other Organisations Brighton & Lewes Downs Biosphere acknowledge that para 2.25 is based on ‘one planet living principles’, which is consistent with the Brighton and Lewes Downs Biosphere Management Strategy 2015-20. They comment that this should help the area designations to work cohesively on their shared sustainable development focus.

CPRE Sussex supports the policy and welcomes the consideration of ‘potential’ adverse impacts. They suggest that the words "moderated" in criteria 2(d) and "mitigated" in criteria 2(e) should both changed to "avoided". This assumes a degree of detriment is inevitable and to meet the first purpose of the National Park it should be the primary responsibility to avoid harm.

Highfield and Brookham Schools are concerned about the lack of definition of what constitutes Major Development. They note that the NPPG states that this is matter for the decision taker and it should be possible to set out parameters and/or set out examples. This ensures a transparent policy for those considering new development. Highfield and Bookham Schools consider it to be unclear how Policy SD3 is intended to relate to Policy SD22 in relation to development in an estate plan considered under criteria 4 of SD22. Friends of Lewes support the policy. Friends of the Earth (Brighton & Hove) support the policy, but suggest using the term ‘significant’ instead of ‘unacceptable’.

Lancing College comment that the policy must acknowledge that major development that forms part of an endorsed Estate Plan will be considered favourably where the need for and the principle of such development has already been appraised by the SDNPA against the requirements of the estate, taking into account also the wider objectives and vision for the National Park. The National Trust are concerned about the omission of the word ‘local’ when referring to context and this does not comply with para 154 of the NPPF. They comment that this does not provide a clear indication of how a decision maker should react to a development proposal and are concerned that there is scope for context to be interpreted too widely and for the potential adverse impacts of a development to be considered well beyond a reasonable scope, particularly when considering the potential aspects as identified in criterion 1. They consider that this is clearly supported by legal advice from James Maurici QC (July 2014). NFU (South East Region) question the reliance upon the concept of ‘potential adverse impact’ as a measure of acceptability, without considering the likelihood of such an outcome. They suggest it is less problematic to refer to predicted adverse effects as assessed by evidence based enquiry. The South Downs Land Managers Group support the strong stance against major development. The South Downs Society support the policy. Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trust (joint response) state their strong support for the policy and consider that the core policies ensure a rigorous framework for development in the National Park and are in accordance with the NPPF and Vision and Circular. They acknowledge that cumulative impact is commented on in para 4.26, but there is no reference in the policy to the consideration cumulative or in combination impacts and it is vital that this is addressed. Upper Itchen Valley Society made reference to the Itchen Valley Management Plan (1995) which concluded that the damage from cumulative impact of small developments could be equivalent to that caused by a major development scheme. They acknowledge that para 4.28 makes reference to cumulative impact but this is not covered in the policy. West Dean – The Edward James Foundation support the policy with changes. West Dean – The Edward James Foundation and the Leconfield Estate consider that the policy is imprecise as many types of development could have a ‘perceived 'potential to have an unacceptable adverse impact on...the National Park' and this would trigger the need for more onerous policy tests in (a) – (e) which could be unreasonable. They request greater certainty on what constitutes major development, including specific criteria. The Wiggonholt Association support recognition that major development has potential to have adverse impact, taking into account cumulative impact, but would like to see appropriate references to Policy SD1 and SD2 incorporated in text.

Agents and Developers Comer Homes consider that criteria listed at part 2 of the policy is in accordance with the thrust of paragraph 116 of the NPPF. However, they comment that other parts of the Local Plan, in particular SD33, seek to go further than this and introduce unfounded considerations (such as exceptional and exemplar). Wates Development Ltd made the following comments:

 Policy is ambiguous and provides no certainty with regards to what constitutes major development in the SDNP.  Most development has the ‘potential’ to have an unacceptable adverse impact and this is open to interpretation.  Should be re-worded to reflect national guidance. NPPG confirms that the application of paragraph 116 of the NPPF, will be a matter for the relevant decision taker, taking into account the proposal in question and the local context. Individuals Two individuals commented that the terminology in criteria 1 is inconsistent with NPPF and use of the term ‘harm’ would be better than ‘adverse impact’. One individual commented that there is a need to consider location and setting. One individual commented that great care must be taken when consideration is given to any proposed major development and what might seem to be appropriate to one end of the Park may be quite unsuitable somewhere else. They are concerned that a careless popular approval could well lead to the establishment of an unwelcome future precedent. One individual commented that para 4.23 is very negative and asks about potential positive impacts. They also commented that para 4.25 is negative and does not consider jobs and the economy. Also is this not clear if the objectives are life cycle or just during the operational/useful phase of their life. They also asked where the exceptional circumstances referred to in Policy SD3 are defined. One individual agreed that major development should be the exception and agree with the broad thrust of the policy. They commented on paragraph 4.25 and consider that thought needs to be given to definition of Zero Carbon and the embodied carbon in structures and distance travelled by materials coming to site. Local materials and environmentally friendly materials, in production as well as use, should be used. They also commented that zero waste seems an arbitrary term, and almost impossible to achieve, and suggest that reference to sustainable waste would be better. One individual commented that the policy does not make reference to the principles set out in paragraph 4.25 of the supporting text. One individual considers that the policy should be amended to make clear that it is not intended to call into question the allocation of sites for development in adopted neighbourhood plans. One individual suggested the following amendment to criteria 2 (d): “any detrimental effect on the environment, to the locality, the landscape and quiet recreation, and the extent to which that could be moderated; and” One individual considers that major development must be allowed in the four market towns, commenting that these areas do not affect the park as a whole and have excellent communications and access to major road networks and trains. They consider it far better to build there than in areas on the border on the National Park, such as Rowlands Castle, which is a lot less well served with public transport.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Reference added to cultural heritage (para 4.28)  Reference added top ‘wildlife’ in criterion 1 of Policy SD3.  Clarification provided on what is the ‘designated area’ (para 4.25)  Further guidance is given in chapter 1 on the links between minerals and waste plans and this Local Plan (paras 1.5, 1.6 and 1.35)  The impact of cumulative development is now addressed in criterion 1 of policy SD3.  Policy wording changed from ‘unacceptable adverse impact’ to ‘serious adverse impact’ in criterion 1 to provide clarification.  The measures of sustainable development are now set out in criterion 3 of the policy and expanded in the supporting text (para 4.28)

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Use the word ‘harm’ rather than ‘adverse Legal advice has been sought on the matter and impact’ this is the advised wording. Question if this is a justifiable interpretation of Legal advice has been sought on the matter and "major development" and application of the the NPA does consider this approach to be prescribed considerations for assessing such justified. proposals. Add reference to the impact of development This level of detail is not needed in a core policy proposals on habitats and/or species listed as ‘Habitats and Species of Principal Importance’ within the England Biodiversity List, published under the requirements of S41 of the Natural Environment and Rural Communities (NERC) Act 2006. Request to define major development in the Policy SD2 sets out how the SDNPA will policy determine what constitutes major development in the first criterion of both the Preferred Options and Pre-Submission plan Policy should reference relevant minerals and This level of detail is not needed in a core policy waste policies and would soon get out of date. Sustainability should include the concept of Development proposals for major development embedded carbon. will be measured against a number of factors including zero carbon. Lack of clarity on how policy SD3 applies to Policy SD3 applies to all development including estate plans that in estate plans. Individual policies are not cross referenced in the Local Plan Insert the word ‘local’ before ‘context’ in The impact of a development proposal may criterion 1 of policy SD3. extend outside the ‘local’ context and this could be significant in a nationally protected landscape. The SDNPA considers that policy SD3 provides sufficient clarity for decision making in line with para 154 of the NPPF. Change policy wording form ‘potential adverse An in-depth consideration of whether the impact’ to ‘predicted adverse impact.’ development would in fact have an impact

would be required to predict an adverse impact. This would be an unduly onerous policy requirement The policy should cross reference policies SD1 Individual policies are not cross referenced in and SD2. the Local Plan The policy and supporting text is unduly Most of the policy is positively worded. That negative part of the policy that is negatively worded is consistent with para 116 of the NPPF. The major development test should not be The major development test may need to be applied to adopted neighbourhood plans applied for allocations in adopted neighbourhood plans. Add the words ‘to the locality’ to criterion 2d Not considered necessary Major development should be allowed in the The major development test applies four market town throughout the National Park in line with the NPPF.

Broad Area Policies

Reg 22 (1) (c) (iii) There were a total of 107 comments on this section. These are summarised below. Comments on the Introduction

There were a total of 30 comments on the introductory section for the Broad Area Policies. These are summarised below. National Agencies Historic England suggest adding a reference to para 7 of NPPF in para 4.31. They also comment that there is no evidence on the historic environment listed on page 50. They welcomes and support the reference to "historic settlement patterns" in paragraph 4.43 and their use in creating the Broad Spatial Diagram. Natural England advise that policy links need to be made within these areas with regard to Policy SD13 (International Sites). Borough, City, County and District Councils Chichester District Council consider that there needs to be a more accurate map clearly defining the boundaries between different areas. They also comment that not all the areas have a description of the historic environment and settlement characteristics. The Coastal Plain would particularly benefit from this additional information given the acknowledged development pressure which has potential to impact on heritage assets and settlement character. East Hampshire District Council supports para 4.43 which states that development will be guided by the SDILCA. They note that small scale development will be accommodated in a number of small villages provided it is within the settlement policy boundaries (SPB). In this regard, the current review of the SPB is important as there have been situations whereby the SPB is either inappropriate or out of date in the past. They request confirmation that SPBs are subject to review. Horsham District Council are supportive of the spatial approach. They consider that the broad areas reflect the broad landscape character areas of the park and this is clearly shown in figure 4.4 which they think is a useful plan. They comment that within Horsham District, the ‘Spring Line’ settlements of Pulborough, West Chiltington/Storrington/ Sullington, Steyning, Bramber and Upper Beeding have particularly close connections to the landscape of the National Park and support the reference to their role in a wider hierarchy of settlements in para 4.35. They welcome the opportunity to explore how this relationship can be more clearly expressed in other sections of the plan and/or shown on the Spatial Diagram. Winchester District Council made the following comments:

 The size and complexity of the document and the way it is laid out, does not allow for easy interpretation and application of policy. For example, each of five broad areas have a subtly different approach to development (i.e. ‘limited’ growth or ‘moderate’ scale growth), but no indication as how this is to be interpreted or what is intended by ‘limited’ and ‘moderate’.  The spatial diagram and accompanying policies which reflect the spatial areas, appear part way through the Plan and it is not obvious that these are the ‘lead’ policies for proposals within the designated areas (for example Policy SD22 Development Strategy appears on page 123). There needs to be a stronger link between the spatial areas and the development strategy (i.e. SD4 could list the settlements covered by the respective spatial area).

 The policies in relation to tourism and the rural economy are required to be considered in conjunction with other relevant policies and in particular the development strategy and the need to deliver multiple benefits through ecosystem services. For example, reference to ‘provisioning services’ such as viticulture and ‘regulating services’ such as water management, ‘provisioning services’ such as aquaculture and ‘cultural services’ such as tranquillity. The terminology used does not aid clarity of interpretation and application of the policies and, whilst the spirit of the policies may seem straightforward, the detail could potentially cause issues with determining applications. Parish and Town Councils Selborne Parish Council support the policy and approach taken. Rowlands Castle Parish Council support the allocation of 5 areas. They consider this is logical and the underlying characteristics are well explained. However they question whether the development strategy is correct for each area and, in summary, consider that the case for limiting growth to such an extent in the other four areas needs to be re-examined. They make the following comments:

 The Dip Slope is identified for moderate growth - whilst all the other four areas are designated for small scale or limited growth (except for Petersfield, Midhurst, Petworth, Liss & Lewes together with the Western Weald).  Concerned that with limited growth identified in the Coastal Plain and limiting growth in other areas could add to development pressure in the southern reaches of the Park. They make reference to significant development already taking place just across the boundary (for example in Horndean, Clanfield and Rowlands Castle) and that they are now facing pressure for even more development from the adjoining Havant Borough Council and Portsmouth City Council, and the proposed 'Combined Authority'.  Should be recognised that a significant part of the area of Rowlands Castle which is outside the SDNP, has been identified as a potential reservoir for Portsmouth Water.  Also necessary to preserve the current 'strategic gap' between Rowlands Castle and Havant, which lies outside the SDNP, and to avoid even more coalescence of these communities. Warnford Parish Council suggest a more detailed map is provided as it is not easy to determine from the map whether Warnford is considered part of the Scarp Slope or Western Downs Broad Areas. The Parish contains landscape types characteristic of both and it is assumed that the relevant policy would be applied depending on the nature and location of a proposal. Other Organisations Lancing College commented that they appreciate the intention is to seek only to define very broad areas, however demarcation of these zones on such a large scale that it does present an overly simplistic summary of the characteristics of the National Park. For instance, Lancing College falls within the broad Scarp Slope area, albeit the southern part of the site in particular has much of the characteristics identified in the description of the Dip Slope. They consider that this approach is acceptable in supporting text and illustrative diagrams but becomes more problematic when these broad classifications are carried forward into more prescriptive policies applied to a particular area but which that may not be directly relevant to an individual site. Consider two alternative options are to (i) make clear that individual sites will be reviewed based to their own characteristics and Policy SD4 will be applied accordingly; or (ii) a less simplistic classification is applied and emphasis is instead placed on the Landscape Character Types (Figure 5.2).

Marwell Wildlife support Figure 4.4, but suggest adding some key settlement names to the figure to enable better understanding of the information presented on this figure (this also applies to other figures which do not have settlement names). The National Trust object to the omission of Hinton Ampner House and Petworth House as tourist hotspots on Figure 4.4 (and make reference to significant visitor numbers at both properties). They consider that they contribute to the understanding of the heritage and landscape qualities within the National Park and provide significant economic support to the facilities and services in the surrounding town and communities as well as providing a wide range of employment opportunities within the Park. The South Downs Land Managers Group make a number of comments on Figure 4.4:

 agree in principle that surrounding areas should be featured. However, seems inconsistent and an unsound approach not have shaded areas to the north of eastern scarp or south of coastal plain.  too small  colour definition between Dip Slope and Western Downs not obvious.  when enlarged key is out of focus making it difficult to read. The Sompting Estate commented on Figure 4.4 stating that they do not understand why no half- shaded ‘surrounding area’ is indicated north of the eastern scarp, or south of the Coastal Plain National Park boundary.

Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trust (joint response) supports the division of the broad areas and the assessment of development against the areas special qualities. They strongly support the requirement for growth to deliver multiple benefits through ecosystem services and comment that the growth in natural capital should always be encouraged and should be a core aim of the Local Plan. They are concerned about the ambiguity of the type of growth these policies refer to. Wiggonholt Association agree to the five broad areas proposed which reflect the fact that the 'special qualities' of the National Park vary and that the amount and form of future development will also vary. From a presentational point of view they wonder whether this should appear as a strategic policy in conjunction with Policy SD22 (Development strategy). Agents and Developers There were no comments made by agents and developers on this section. Individuals Two individuals made comments on Figure 4.4, including:

 Too small scale and has no place names on it. Reconsider and amend with more meaningful and readable plan.  Clarify what the tourist hotspots relate to. Seem haphazard and appear to omit many real hotspots.  Maps and plans should be labelled as such. Maps are not figures.  Suggest a map is included for each policy. One individual commented that the SD4 policies should have individual numbering. One individual makes reference to land they are promoting on the edge of Alfriston and comments that Alfriston on cusp of both the Dip Slope and Coastal Plain. They consider that Figure 4.4 is too

77 broad in nature and difficult to identify locations on it which is confusing, particularly as the development strategy is based on it. They suggest providing more detail to provide more clarity on the decision making process, particularly in relation to the exceptions referred to in Policy SD22, where it is in accordance with the relevant broad area policy. One individual commented that electric vehicles that are zero carbon in use will become common and their use should be considered alongside public transport, some of which is polluting, and cycling. One individual agreed with the more pragmatic approach set out in para 4.36. One individual agreed with 4.47 in particular as a pragmatic choice. One individual commented on water pollution coming off the South Downs onto the Manhood Peninsula which is a very special area in its own right with a regionally important population of water voles, important populations of geese, ducks and wildfowl with internationally important sites at Chichester Harbour, Medmerry and Pagham Harbour. They questioned what the SDNPA intend to do about this contamination. They also commented that of the areas within Chichester District it brings in 49% of all tourist income. It should be noted that the section in the Preferred Options entitled ‘Achieving the Vision for the National Park across the five Broad Areas’ along with the area specific policies SD4/CP: Coastal Plain, SD4/DS: Dip Slope, SD4/WD: Western Downs, SD4/SS: Scarp Slope and SD4/WW: Western Weald have not been carried forward to the Pre-Submission version of the Local Plan. The Spatial Portrait that formed figure 4.4 of the Preferred Options has been amended and now forms figure 3.4 of the Pre- Submission plan. The explanatory text for the diagram is set out in chapter 3. Reg 22 (1) (c) (iv) The representations have been taken into account as follows:

 Figure 3.4 includes clearly defined boundaries for the broad areas and appendix 1 lists the settlements, strategic sites, gateways and hubs in the broad areas.  Chapter 7 confirms that all the settlement boundaries have been reviewed as part of the Local Plan process unless a neighbourhood plan is being prepared for the area (para 7.9)  Criterion 3 of policy SD4: Landscape Character relates to gaps between settlements  Both Hinton Ampner and Petworth House are named in chapter 3 (paras 3.12 and 3.27).

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Add reference to paragraph 7 of the NPPF All sections on national policy context have been deleted from the plan Address the issue of water pollution coming This matter is beyond the scope of the Local from the South Downs on to the Manhood Plan Peninsula.

Policy SD4/CP: The Coastal Plain

Reg 22 (1) (c) (iii) There were a total of 22 comments on this policy. These are summarised below. National Agencies Historic England welcomes and supports the identification of the important cultural heritage and historical features of the broad areas and the identification of distinctive towns and villages. However, they comment on the lack of reference to cultural heritage and important features in the paragraph on the Coastal Plain broad area, which consider is a significant omission given the acknowledged development pressure adjacent to the Park which has the potential to impact on heritage assets, settlement character and the Park's special qualities. Borough, City, County and District Councils There were no comments made by City, County, Borough and District Councils on this policy. Parish and Town Councils Arundel Town Council comment that ‘Binsteds Wood’ should be amended to ‘Binsted Wood’ in para 4.52. They also comment that it is not clear why the Coastal Plain area is restricted to “limited growth” whilst the Dip Slope area seeks to permit “moderate-scale growth” and that equal levels of sustainable growth should be permitted. Patching Parish Council support the policy and consider that this and other policies support the control of development in small downland villages and provide a good platform for their emerging neighbourhood plan. Selborne Parish Council agree with and support the policy. Other Organisations The British Horse Society consider that the policy does not make a strong enough comment on what a barrier the A27 is to Non-Motorised Users (NMU) (especially equestrians) trying to access the Park, and the safe network of bridleways and byways on the Downs. They comment that there should be a commitment to encouraging safer continuity for PROW and all NMUs across the A27 in partnership with Highways England and development has a big part to play in funding improvements

CPRE Sussex supports the policy and welcomes the proposal of limited growth. However would welcome more details in relation to flood risk areas (reference to their comments on Policy SD17 and 18). They also support changes to cultivation and land use in flood sensitive zones as opposed to major engineering solutions. The Chichester Society support the provision of good visitor facilities at gateways to the National Park, particularly improvements to the public rights of way network for both walkers and cyclists, both from the city and from the new housing developments, towards the National Park to the NW, N and NE of the city. Friends of the Earth Brighton & Hove and the South Downs Society support the policy. Lavant Residents for the Relief Road commented that paragraph 4.54 should include recognition that due to its scale and location Mid Lavant should not be categorised along with the other hamlets and villages and opportunities to improve social wellbeing for residents may come at a cost (i.e. a level of enabling development which would not otherwise be unacceptable).

Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trust (joint response) express strong support for policy and consider that the core policies ensure a rigorous framework for development in the National Park and are in accordance with the NPPF and Vision and Circular. The South Downs Land Managers Group comment that there needs to be a definition of what is meant by growth and it is unclear how this policy would impact on potential for on farm developments or farm diversification proposals outside of settlements. West Sussex Local Access Forum commented that the A27 is a significant barrier to non-motorised users (NMUs) trying to safely access the Park. This probably applies most of all to equestrians, who in many instances (if able) have to box up to the Downs, where the problem of height barriers at car parks is an issue. They suggest that the policy should include a SDNPA commitment to seek to deliver safe multi-use PRoW/NMU access from the Coastal Plain to the Park, in conjunction with Highways England. It should also acknowledge the significant lack of safe off-road multi-use routes on the Coastal Plain, the reason behind the need for better connectivity to the Park. Agents and Developers Portico Property Limited have made representations made in relation to Land at Dodd’s Lane, Swanmore, which lies within the Coastal Plain area and has been submitted through the SHLAA. They note that much of this area is relatively less tranquil and light pollution is more prevalent due to the proximity of large urban areas to the south. They also note that much of the Coastal Plain within the National Park is sparsely populated and this population relies on settlements beyond the southern boundary for many essential services. They go on to comment that Swanmore is acknowledged to be a sustainable settlement for further growth by the adopted Winchester and South Downs Joint Core Strategy (JCS). Portico considers that Land at Dodd’s Lane is sustainably located to help meet the development needs of Swanmore and the Coastal Plain area. Individuals One individual commented that reference to jobs is missing (this could also apply to other broad area policies). One individual commented that there is already over development on the south coast of Sussex, any more will only put more strain on the local roads and other resources. They request that improvements to the road systems, in particular A27, must be improved before any other development is considered. One individual requested that reference to the Manhood Peninsula noted for its tranquillity and dark skies is added to para 4.52. They note that this area is given special attention in the Natural England National Character Area and there is a need to consider sensitivity of this area outside of the SDNP. They also comment that flatter land is now being allocated due to development pressure in Chichester District outside of the National Park. It should be noted that Policy SD4/CP: Coastal Plain has not been carried forward to the Pre-Submission version of the Local Plan. The broad areas and river corridors are discussed in chapter 3 under a number of sub-headings. Reg 22 (1) (c) (iv) The representations have been taken into account as follows:

 Reference has been made to the cultural heritage and historical features of the Coastal Plain (para 3.67)  Further detail has been provided on the how the A27 acts as a barrier to non-motorised users (para 3.73)  Further detail is provided about flooding on the Coastal Plain (para 3.74)

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Correct spelling of Binsted Woods to Binsted Reference deleted Wood Further detail requested on development in This is a broad spatial portrait and the Lavant discussion of individual villages is beyond the scope of this plan. Promotion of SHLAA site at Dodd’s Lane, Site rejected in SHLAA (ref WI031) Swanmore Add reference to jobs Although specific reference is not made to jobs reference is made to farming and new enterprise (para 3.65) Add reference to the Manhood Peninsula This area is an important part of the Coastal Plan, but is located outside the National Park.

Policy SD4/DS: The Dip Slope

Reg 22 (1) (c) (iii) There were a total of 14 comments on this policy. These are summarised below. National Agencies There were no comments made by National Agencies on this policy. Borough, City, County and District Councils Brighton & Hove City Council welcomes the general recognition of gateway points and note that there is an important gateway at Stanmer Park. They would welcome greater recognition to the Stanmer Park gateway point and reference to partnership working to help promote the gateway and facilitate enhancements. The promotion and enhancement of walking and cycling links to and from the City would also be welcomed. Parish and Town Councils Arundel Town Council made the following comments:

 would like to see the status of Arundel raised within the National Park’s scope of interest, with a view to promoting our town as a Gateway, or as they are referred to, “Service Centres”. This will enable businesses to benefit from marketing and assist the SDNP in promoting its interests and values in conjunction with their own.  Arundel is partly in the SDNP, and specifically in the Dip Slope. Arundel is not identified as a tourist hotspot despite Arundel Castle and other attractions catering to 300,000 visitors each year.  Paragraph 4.64 outlines the rich cultural heritage and historical features, but does not mention Arundel Castle or the Norfolk Estate, both in the National Park. East Dean & Friston Parish Council strongly agrees that any development in the Dip Slope area, which includes this parish, should be proportionate to the size of the settlement and to the landscape’s capacity to accommodate it; and should be shown to deliver multiple benefits through ecosystem services. Madehurst Parish Meeting note that Madehurst is not identified as an area for development in the cross referenced Policy SD22 and would welcome more explicit reference to the impact of any developments which are not set out in Policy SD22. Rowlands Castle Parish Council commented that the Broad Area policies should also refer to Local Landscape Assessments, in addition to SDILCA. Selborne Parish Council agree with and support the policy.

Other Organisations Arundel Chamber of Commerce made the following comments:

 Would like to see the status of Arundel raised within the National Park’s scope of interest, with a view to promoting our town as a Gateway (or “Service Centres” as they are now referred to).  Para 4.64 - Arundel is partly in the SDNP, and specifically in the Dip Slope, one of the five Spatial Areas of the National Park. There are several “Tourist Hotspots” identified on the Spatial Map but Arundel is not one of them, despite Arundel Castle and other attractions catering to 300,000 visitors each year  The plan states that the Dip Slope area, shares with the Coastal Plain opportunities for access (SQ5) to activities in the Park, including Rights of Way linking the coast to the crest of the Downs. The paragraph mentions specifically the Monarch’s Way, which goes up Arundel High Street and into Arundel Park. The paragraph also outlines the rich cultural heritage and historical features, mentioning the West Dean Estate, Weald and Downland Museum & Goodwood but not Arundel Castle or the Norfolk Estate, both of which are in the National Park. Brighton & Lewes Downs Biosphere are pleased to the Biosphere designation referenced in para 4.64. However, they note that they refer to the UNESCO designation locally simply as Biosphere, or Biosphere Region (rather than Reserve, the original UNESCO title, which is not felt appropriate for a non-statutory environmental initiative with a strong urban element). Friends of the Earth Brighton & Hove and the South Downs Society support the policy. Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trust (joint response) express strong support for policy and consider that the core policies ensure a rigorous framework for development in the National Park and are in accordance with the NPPF and Vision and Circular. The South Downs Land Managers Group commented that criteria 2 and 3 seem to be at odds with each other. They comment that as currently worded seems to imply that criteria 3 should be delivered in settlements. However, it is presumed that it is referring to the wider area outside of the settlements. They consider these examples are unlikely to be relevant to the majority of landowners and as currently worded this policy would seem overly restrictive and could have a negative impact on the ability of land owners to manage the land. Agents and Developers Callstone Ltd commented that the policy does not acknowledge that Shoreham Cement Works is located within the Dip Slope. They comment that the Shoreham Cement Works is considered to have a negative impact on the landscape of the National Park and, therefore, an appropriate degree of restoration, appropriately phased and supported by comprehensive redevelopment would assist in improving the landscape character of this area. Individuals One individual commented that it is not just the dip slope which has high tranquillity and dark skies and this is relevant for large areas of the Western Weald. It should be noted that Policy SD4/DS: Dip Slope has not been carried forward to the Pre-Submission version of the Local Plan. The broad areas and river corridors are discussed in chapter 3 under a number of sub-headings.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows:

 Arundel is named as a gateway in the River Arun Corridor into the National Park (para 3.80)  The supporting text of policy SD25 explains the planning status of land outside settlements named in the policy (para 7.9)  Reference is made to the Castle Park of Arundel (para 3.78)  Reference is changed from ‘Brighton & Lewes Downs Biosphere’ to ‘Brighton and Lewes Downs Biosphere Reserve’ (para 3.48)  The strategic site of Shoreham Cement Works is referenced in the River Adur Corridor (para 3.84 and 3.93).

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Name Stanmer Park as a gateway to the Gateways are settlements outside the Naitnal National Park Park and Stanmer Park is inside

Policy SD4/WD: The Western Downs

Reg 22 (1) (c) (iii) There were a total of 7 comments on this policy. These are summarised below. National Agencies There were no comments made by National Agencies on this policy. Borough, City, County and District Councils There were no comments made by City, County, Borough and District Councils on this policy. Parish and Town Councils Cheriton Parish Council commented that the River Itchen flows through the parish and is crossed many times a day. They request that mention should be made of this unique heritage. Selborne Parish Council agree with and support the policy. Other Organisations Friends of the Earth Brighton & Hove and the South Downs Society support the policy. Itchen Valley Parish Council commented that the River Itchen is central to the villages in the Itchen Valley Parish, the river is a “World Class Asset”. Its environs and extraordinary attractive features are enjoyed by local people and attract a large amount of visitors both for sport and recreation. IVPC and the SDNP as custodians of this waterway must work to protect its unique character and the approaches to it. They request that the description of the Western Downs should reference the para 4.70) and the DMPs need to be tested to ensure the river is afforded the highest protection possible. They suggest that the title of the area should be changed to “The Itchen and Western Downs”. Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trust (joint response) express strong support for policy and consider that the core policies ensure a rigorous framework for development in the National Park and are in accordance with the NPPF and Vision and Circular. The South Downs Land Managers Group made a number of detailed comments which were also made on Core Policy SD4/CP (see above). Agents and Developers There were no comments made by City, County, Borough and District Councils on this policy. Individuals There were no comments made by individuals on this policy. It should be noted that Policy SD4/WD: Western Downs has not been carried forward to the Pre-Submission version of the Local Plan. The broad areas and river corridors are discussed in chapter 3 under a number of sub-headings. Reg 22 (1) (c) (iv) The representations have been taken into account as follows:

 Reference is made to the River Itchen (para 3.3)

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Re-name broad area as River Itchen and Although the River Itchen is an important area Western Downs within the National Park, the broad area covers a much wider area

Policy SD4/SS: The Scarp Slope

Reg 22 (1) (c) (iii) There were a total of 18 comments on this policy. These are summarised below. National Agencies There were no comments made by National Agencies on this policy. Borough, City, County and District Councils There were no comments made by City, County, Borough and District Councils on this policy. Parish and Town Councils Buriton Parish Council would like reference added to local landscape character assessments and village design statements in addition to SDILCA in all broad area policies. They consider that these locally-produced documents which will help differentiate between the five sub-areas. Bury Parish Council note that para 4.85 highlights the opportunities and challenges of satisfying the need for more good-quality, low-cost accommodation for users of the South Downs Way. However, they see potential conflict here with the special qualities, emphasised in para 4.79 and need to maintain tranquillity and the darkest night skies and the aim of encouraging fewer cars. They comment that any proposals for development on presently undeveloped, delicate environment sites, particularly sites outside existing settlement areas, needs to take account of the seven special qualities and the first duty of the SDNPA. Iford Parish Meeting welcomes the fact that the plan recognises the problems of narrow roads and a scarcity of parking. The proposal to support walkers and cyclists, but to aim for fewer cars, is keenly supported. They also supports the recognition given to the views out from the scarp slope and the fact that these views are vulnerable to development. Plumpton Parish Council commented on the statement in para 4.86 regarding views from the scarp slope. They strongly question the right of SDNPA to have jurisdiction over the development of communities outside its borders unless it also confers the same levels of protected status as those enjoyed by villages within its boundaries. Selborne Parish Council agree with and support the policy. Steep Parish Council comment that they find it difficult to imagine how this policy can be practically interpreted in either promoting or refusing an application in our area. Warnford Parish Meeting made the following comments:

 Warnford Parish is on the boundary between the Scarp Slope, Dip Slope and Western Downs areas and the definitions of the boundary of the Scarp Slope area are not consistent with each other or with the map. The map suggests that the bottom of the Meon valley is included in the Scarp Slope; Para 4.77 says that western limit of the Scarp Slope area is Old Winchester Hill, however Para 4.80 says that Beacon Hill NNR (which is west of Old Winchester Hill) is included in the Scarp Slope area.  Warnford Parish needs to know which area(s) it is in and request clarification on the boundaries of the areas with a more detailed map and amend the text consistent with it.  Consider that criteria 4 is very vague and needs further clarification. They questions what the practical implications for (as examples) a new farm building, a tourist holiday cottage or an affordable housing scheme on a rural exception site.

Other Organisations Brighton & Lewes Downs Biosphere suggested that it could be noted that an eastern part of the scarp slope is also covered by the UNESCO Biosphere designation (as it is in para 4.58 under Dip Slope). CPRE Sussex welcome that the focus of development in this part of Sussex will be in Lewes. Friends of the Earth Brighton & Hove, Friends of Lewes Society and the South Downs Society support the policy. Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trust (joint response) express strong support for policy and consider that the core policies ensure a rigorous framework for development in the National Park and are in accordance with the NPPF and Vision and Circular. However, they also note that that para 4.80 incorrectly states that the River Meon supports white-clawed crayfish. The South Downs Land Managers Group made a number of detailed comments which were also made on Core Policy SD4/CP (see above). Agents and Developers There were no comments made by City, County, Borough and District Councils on this policy. Individuals One individual commented that many spring line villages would benefit from a little small scale development to increase vitality and deal with the number of second homes and weekend cottages. New development should be limited to sole or principal residences. They also make reference to paragraph 4.85, commenting that cycling should be encouraged but specific rules enforced for large scale events, particularly those organised by commercial enterprises. Timing and ranking by elapsed time should be prohibited. All signage must be removed, and be only of an appropriate size. It should be noted that Policy SD4/SS: Scarp Slope has not been carried forward to the Pre-Submission version of the Local Plan. The broad areas and river corridors are discussed in chapter 3 under a number of sub-headings. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Possible conflicts between providing more good-quality, low-cost accommodation for users of the South Downs Way with the special qualities is addressed in policy SD23: Sustainable Tourism.  Noted that the Brighton & Lewes Downs Biosphere Reserve also covers part of the Scarp Slope  Reference to the white-clawed crayfish deleted The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Clarification to be provided on which broad Warnford is located on the Dip Slope. Figure area Warnford is located 3.4 has been made clearer, but it is not possible to name all villages in the National Park. Specific rules should be enforced in regard to This is beyond the remit of the Local Plan large-scale cycling events

Policy SD4/WW: The Western Weald

Reg 22 (1) (c) (iii) There were a total of 16 comments on this policy. These are summarised below. National Agencies Natural England notes that paragraph 4.90 cites the Mens SAC and Ebernoe Common Special Area of Conservation as nationally important woodlands and advise that these are of international importance. They have both been afforded statutory protection as Special Areas of Conservation under the Conservation of Habitats and Species Regulations 2010, as amended (the ‘Habitats Regulations’). The supporting text and policy should reflect this and refer to Policy SD13 (International Sites) which is applicable here. Borough, City, County and District Councils There were no comments made by City, County, Borough and District Councils on this policy. Parish and Town Councils Bepton Parish Council generally support moderate growth in Midhurst subject to the specifics of proposed sites and necessary infrastructure (i.e. roads, schools, medical provision etc). Harting Parish Council identify an error in Criteria 4 of the policy which refers to ‘Scarp Slope’ and should refer to Western Weald. Liss Parish Council made a number of comments:

 Object to criteria 3 which links Liss to the market towns and suggests that these towns can meet the needs of the surrounding areas. They would prefer that Liss was not singled out, and described simply as a village in the park, or if not then request insertion: ‘of Midhurst and Petersfield after the word "towns" in the final sentence to make it clear that Liss is not included in the requirement to meet the needs of surrounding areas.  They are concerned about the treatment of Liss as a large centre which appears in several policies, such as SD4WW, SD29 and SD53. They comment that Liss is a large village in population but, apart from the railway station the range of services and facilities provided in the village are limited and only serve the village itself and the housing immediately adjoining. They note that para 7.171 of the draft plan recognises that these facilities are in decline and that the village relies on Petersfield and other centres for all significant shopping, employment, health, education and community facilities. Selborne Parish Council agree with and support the policy. Woolbeding with Redford Parish Council support the policy and comment that a risk to the Western Weald is “Surreyfication” given the proximity to London commuter stations such as Haslemere. They consider that emphasis should be placed on good design that is sympathetic to the landscape of National Park and particular attention is needed in the local landscaping of gateways and driveways to prevent it becoming suburban. They also suggest that the Western Weald section should emphasise the dark skies and tranquillity away from towns.

Other Organisations Friends of the Earth Brighton & Hove and the South Downs Society support the policy. The Petersfield Society endorse CPRE views in respect of the need to emphasise the use of previously developed land Para. 4.31 and the focus of the policy is supported Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trust (joint response) express strong support for policy and consider that the core policies ensure a rigorous framework for development in the National Park and are in accordance with the NPPF and Vision and Circular. The South Downs Land Managers Group made a number of detailed comments which were also made on Core Policy SD4/CP (see above). Agents and Developers CALA Group Ltd commented that there is no definition, in the policy, supporting text or elsewhere in the Local Plan, of what constitutes ‘moderate scale growth’ for Liss. Except in terms of housing this is clarified at Policy SD23 of being for ‘approximately 150 dwellings’. Suggest a definition of ‘moderate scale growth’ is included in the Policy. Tetlow King notes that criteria 2 states that the focus of development in this area will be in the market town of Petersfield...". The use of the word "in" is wrong it should say "at" Petersfield as this gives the impression that there will be no development beyond the boundaries of this existing settlement when the Neighbourhood Plan proposes green field development at the town. Individuals One individual suggests that the European Protected Species of bats making use of the hedgerows, ancient woodland and shaws should be noted. One individual supports the policy, including at the SDNP boundary at Liphook where the beautiful scenic views to and from Weavers Down have been long cherished. They note that the SDNP contributes significantly to the wellbeing of the Liphook Conservation Area and that it is likely that this boundary at Liphook will continue to attract unwanted pressures (applications & appeals) for large housing developments and suggestions that the boundary of SDNP should be redrawn. Both should continue to be resisted. It should be noted that Policy SD4/WW: Western Weald has not been carried forward to the Pre-Submission version of the Local Plan. The broad areas and river corridors are discussed in chapter 3 under a number of sub-headings. Reg 22 (1) (c) (iv) The representations have been taken into account as follows:

 Mens SAC and Ebernoe Common Special Area of Conservation are referenced as being of international importance (para 3.23).  Liss is referenced as a village (para 3.27)  Reference is made to tranquility and dark night skies in the Western Weald (para 3.23)

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Good design requested in the Western Weald Policy SD5: Design requires all development to prevent the ‘Surreyficaton’ of the area. across the National Park to be of the highest possible design quality. Add reference to the European Protected It is not possible to name all protected species Species of bats making use of the hedgerows, found in the broad areas ancient woodland and shaws.

Chapter 5: A Thriving Living Landscape

Policy SD5: Landscape Character

Reg 22 (1) (c) (iii) There were a total of 58 comments on this policy. These are summarised below. National Agencies Historic England welcomes and supports the policy, particularly clauses 2c), 2d) and 3 and made the following comments:

 Consider "as appropriate" in criteria 2 is unnecessary these words reduce clarity.  Para 156 of the NPPF (as referenced in para 5.11) actually requires local plans to include strategic policies to deliver the conservation and enhancement of the natural and historic environment, including landscape. They also consider the word "deliver" to be significant and indicating that the Government expect local plans (and local planning authorities) to be proactive in the conservation and enhancement of the natural and historic environment.  Welcomes and supports the reference to context and character of an area and local distinctiveness in para 5.16 and the references to time depth and historic features in para 5.18.  Welcomes and supports paras 5.20 and 5.21, although paragraph 5.21 should refer to the historic significance of designed landscapes and Registered Historic Parks and Gardens. Consider these paragraphs, relating as they do to heritage assets, would sit better within the section on the historic environment. Natural England supports the policy. Southern Water understands the Authority's intention to protect open space between built-up areas, but cannot support the current wording of the policy. They are concerned that it could create barriers to statutory utility providers, such as Southern Water, delivering essential infrastructure required to serve existing and planned development allocated. They considers that should the need arise, special circumstances exist in relation to the provision of essential water and wastewater infrastructure (e.g. a new pumping station) required to serve new and existing customers. This is because there are limited options available with regard to location, as the infrastructure would need to connect into existing networks. Borough, City, County and District Councils Adur and Worthing Council made the following comments:

 The emerging Local Plan for Adur allocates strategic greenfield sites at West Sompting, Shoreham Airport and New Monks Farm, Lancing. These are located adjacent to the southern boundary of the SDNP (and visible from it). While account will be taken of the setting of the National Park, it is important that the delivery of these sites is not jeopardised.  The same principle applies to Worthing. Work has commenced on a full review of the adopted Worthing Core Strategy and a new Local Plan is being progressed. Given the scale of housing need, and very limited opportunities available all opportunities for development will need to be ‘positively tested’. This will include the consideration of a number of greenfield sites around the Borough, some of which abut, or are close to the South Downs  Officers from the SDNPA have been made aware of the work being progressed to consider these sites and this engagement will continue as further evidence is published and options for development are considered.

Chichester District Council consider this section to be very good. East Hampshire District Council made the following comments:

 Welcomes the supporting text regarding resisting the spread of undesirable exotic species in the countryside and note that Leyland Cypress hedges are a particular blight in the rural landscape of East Hampshire. They consider this is relevant to urban as well as rural areas.  Paragraph 7.33 of the Joint Core Strategy states that the precise boundaries for Gaps will be identified in a future Local Plan. The evidence base supporting this policy and the supporting text identifies and proposes a new Gap in the National Park Area. It is unclear how or if this is being addressed in the SDNP Plan. Parish and Town Councils Arundel Town Council suggest the delete ‘clearly’ in criteria 1 and the deletion or shortening of criteria 2a to 4. They consider this to be unnecessary emphasis. Buriton Parish Council support and welcome the policy. However, they would wish the National Park Authority to be 100% confident that all the Strategic Policies are sufficiently robust and practical to withstand the tests and rigours of Planning Appeals etc. The Parish Council is conscious that all these new policies are replacing some long-standing, tried-and-tested policies in the East Hampshire Local Plan and Joint Core Strategy. Bramshott and Liphook Parish Council, in particular, agree with criteria 3 and criteria 4 and consider that some developers display disregard to the importance of the overall landscape, resulting in the destruction of landscape features important to local communities such as ancient hedgerows and trees prior to the submission of a planning application. They suggest that restoration of important features should be a condition of any approved development. A number of parish councils made the following comments on crtieria 2e) (relating to gaps between settlements):

 Buriton Parish Council and Rowlands Parish Council both note that the East Hampshire Joint Core Strategy includes a policy on gaps (CP23) which is much more comprehensive and specific for this topic.  Buriton Parish Council feels that the National Park may need to do more to prevent the coalescence of some settlements (including Petersfield and Buriton)  Rowlands Parish Council consider that additional gaps should be defined to prevent coalescence of settlements as developments take place.  Liss Parish Council suggest that these gaps need to be identified, either in the local plan, or encouragement given to identification in neighbourhood plans. Iford Parish Meeting support the policy. Itchen Valley Parish Council commented that they would like to see more non-native species plants/tree’s removed in favour of native species, particularly in conservation areas and suggest that applicants wanting to remove non-native species should be approved with a requirement to replace with native species, if appropriate to the historic landscape. Liss Parish Council note that para 5.18 refers to impact of cumulative development, but this is missing in the policy and should be included. Madehurst Parish Meeting fully support this policy and specifically support the reference in criteria 2e regarding preservation of open landscape and gaps between settlements.

Patching Parish Council support the policy. Rodmell Parish Council are concerned with the long term problem of soil degradation/erosion caused by the intensity of modern farming practises. The question whether it is possible to build some safeguards into this policy to help with this increasing problem and whether reference could be made to soil quality in criteria 2a and 2b. Selborne Parish Council express strong support for the policy, particularly for criteria 3. However, request that criteria 4 is reworded and the word "unacceptable adverse impact" should be replaced by the word "harm". They comment that this currently implies that an adverse impact may sometimes be acceptable and any adverse impact could harm the first National Park purpose. Twyford Parish Council supported the policy but consider there to be three specific omissions:

 How the landscape is to take account of land outside the park; the boundaries of the NP are very long and vulnerable to landscape intrusion.  Lack of recognition of the River Itchen and its valley (i.e. as a landscape feature/ historic landscape/SAC/SSSI/ water resource and fishing) and as a boundary of the SDNP.  Gaps between settlements on the boundary of the SDNP and the social role of these gaps distinct from landscape role (reference made to the separation between Twyford and Colden Common and between Twyford and Shawford/Compton). West Meon Parish Council supports this policy and proposals which conserve and enhance the landscape character of West Meon. The Parish Council are involved in a landscape character assessment of West Meon. Other Organisations Angmering Estate and Cowdray Estate consider that para 5.17 should include clarification on when a Landscape and Visual Impact Assessment (LVIA) will be required to provide certainty for applicants. They also request that the scope and extent of a typical LVIA should also be clarified (e.g. should it include photomontages), because LVIAs with photomontages are costly to procure and a proportionate and consistent approach as to when they are required is needed. CPRE Hampshire expressed strong support for the policy and made the following comments:

 This policy alongside SD6, SD7, SD8 and SD9 are an essential tool to conserving and enhancing the Special Qualities of the SDNP throughout the Plan Period.  The express reference to the experiential and amenity quality of the landscape in Policy SD5, in addition to landscape character, is an important amplification and clarification.  The general requirement in criteria 2(e) to conserve and enhance gaps between settlements is welcomed, but there is no policy to protect gaps between named settlements (as per Policy CP23 in the East Hampshire JCS, and CP18 in the Winchester District JCS). These are long established Gaps, much valued by the communities in the settlements concerned, and it would be a serious concern if those gaps within the SDNP were not to be protected by a specific policy. CPRE Sussex supports the policy and regards regard Policy 2(e) to be of particular importance and supports the weight given to conservation of landscapes and scenic beauty in development considerations. The City of Winchester Trust commented that the potential impact on views from the SDNP caused by any sites near the boundary of the National Park allocated for development in local plans of adjoining local planning authorities needs to be identified. The Trust recommends these sites, including Bushfield Camp, are identified and listed in the Local Plan.

The Design Review Panel made a number of comments:

 Language within the Local Plan needs to be clarified and defined and provide more detail, such as: o Character o Conserve and Enhance o Appropriate o Landscape – there may be an assumption that this is ‘green’ and the perception is that it does not include built form - needs to be specified.  Concerns about the term “Character” and consider it a very nebulous concept that could be interpreted in a wide range of ways, leaving developers to work on what they want it to mean, rather then what we intend it to mean.  Landscape is not defined in the plan, the term “Immediate, adverse effect on the landscape”, needs more definition, similarly to the term ‘Character’.  Issues in the landscape with regard to highway safety standards and its associated clutter. Highways brief is to maintain a certain level of signage or constructing curbs poses detrimental effects to the character of an area.  It should be clear that the park area is not all the same quality of landscape. Friends of the Earth Brighton & Hove request the deletion criteria 4 and do not consider it necessary, as the policy contains a development test in criteria 1 which is a more positive statement. Friends of Lewes Society welcomes the overall aim of the policy and principle that development proposals that would have an adverse impact on the character of the landscape will be refused. They support criteria 2(b) and note that with climate change and the continuing occurrence of alien diseases and parasites it may well be preferable to plant non-native species in some instances. They suggest that ‘unacceptable’ weakens the policy and should be removed from criteria 4. Folkington Estate note that the policy and supporting text seeks to address the effects of development outside the Park or along its boundary which could have an effect on its special qualities. They make the following comments:

 The National Park’s special qualities are also expressed outside its boundary and the Low Weald north of the Park boundary is a prominent part of its setting and makes reference to the how the park is appreciated from outside the boundary and has a close relationship to this area. Para 5.23 should state that development or activities outside the Park may impact on its special qualities.  There is a threat to the special qualities from any potential enlargement or realignment of the A27 on the boundary or to the north of it.  Suggest amendments to the policy, specifically that it: o should not include the word ‘unacceptable’ as this sets a high bar and can cause argument over its meaning. ‘Harmful’ would be preferable. o should include the word ‘opposed’ as well as ‘refused’ because where development lies outside the Park boundary the NPA will not have a power of refusal but can and may wish to oppose it. Gilbert White Museum note that the reproduction is poor and text hard to read on Figure 5.2. Lavant Residents for the Relief Road commented that Criteria 2 e) ignores that gaps will vary greatly in character and width. They comment that gaps should be justified beyond protecting attractive landscape and should be retained to avoid physical and/or perceived coalescence and maintain the separate identities of the settlements.

The National Trust made a number of comments

 Supports the specific inclusion of criterion (d) and reference to Historic England’s Register of Historic Parks and Gardens. The Trust currently owns and manages two Registered Historic Parks and Gardens (RPG) within the National Park at Uppark House and Petworth Park.  Considers that it is important that measures are put in place in the Local Plan to ensure that the custodians of these important national landscapes and gardens are able to demonstrate a good understanding of the significance of these heritage assets and how any proposals within them are complementary to the designed landscapes.  Concerned by the lack of recognition within the policy of the importance of the setting of RPGs. Reference made to NPPF para 128 and 132.  The Trust is currently producing a document that will enable us to better understand the settings of our landscapes, both designated and non-designated and this will assist in identifying areas where development would harm the setting of properties. The Petersfield Society support comments made by CPRE regarding ‘unacceptable adverse impact’ and the need to include a specific policy on settlement gaps. Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trust (joint response) support the requirement for high quality and effective green infrastructure, along with biodiversity enhancements that runs through the strategic policies (reference examples in Policy SD5 part b) and SD6 part c) and e)). They comment that this approach is particularly supported by paragraphs 99, 109 and 114 of the NPPF. The South Downs Society support the policy. The South Downs Land Managers Group support this policy but have concerns regarding criteria 3 and that the scale of landscape restoration should be commensurate with the scale of development (if the development does not itself constitute the restoration). They also request clarification as to whether it would be applied to just the area covered by development proposal or the whole land holding. The Sompting Estate state their strong support for criteria 5 of SD5. They considers that the statement in para 5.23 needs to be expanded to clarify that this issue, and the need to have regard to the Park’s purposes and duty as expressed in the special qualities, applies not merely to adverse impacts on the Park itself, but also to adverse impacts on the setting of the Park were relevant.

West Dean - The Edward James Foundation and the Leconfield Estate supports the need for new development to protect the landscape and scenic quality of the National Park, but make the following comments:

 Important that the Plan recognises that not all development proposals will necessarily be perceived to conserve or enhance the Park (e.g. large utilitarian farm buildings, energy infrastructure, etc.). However, they serve an important functional and operational need which needs to be recognised in the policy.  Cautious of officers attributing too much weight to community led/local landscape character assessments in planning decisions, because in many cases they have not been publicly consulted on and can therefore be biased towards a particular viewpoint.  Consider that para 5.17 should include clarification on when a Landscape and Visual Impact Assessment (LVIA) will be required to provide certainty for applicants. They also request that the scope and extent of a typical LVIA should also be clarified (e.g. should it include photomontages), because LVIAs with photomontages are costly to procure and a proportionate and consistent approach as to when they are required is needed. Wiggonholt Association support that that Local Plan is to be landscape driven and consider the need to safeguard the experiential and amenity quality of the landscape to be an important point. They suggest it would be helpful to highlight the gaps between named settlements where these are particularly sensitive for the communities concerned. Upper Itchen Valley Society express strong support for the policy, but made the following comments:

 Reference to the Itchen Valley Management Plan (1995) which concluded that the damage from cumulative impact of small developments could be equivalent to that caused by a major development scheme. They acknowledge that para 4.28 makes reference to cumulative impact but this is not reflected in Policy SD3 or SD5. Agents and Developers Callstone Ltd commented:

 The Local Plan should seek to direct new development to previously developed land / brownfield land in the first instance, such as Shoreham Cement Works. Such opportunities should be maximised so that areas of less disturbed landscape character can be saved from development.  Agree with para 5.19 regarding good design avoiding the need for screening. Dudman Group of Companies consider that reference to the "conservation and enhancement" of landscape character should be amended to read "conserve and/or enhance" to remove any potential conflict in the wording. They comment that "enhancement" might not involve conservation" and to the contrary in order to "enhance" a particular landscape characteristic may mean temporarily disturbing the existing characteristic. A comment made on behalf of client promoting land on the edge of Alfriston at Kings Ride Farm for development, which has been submitted through the SHLAA process. They comment that the policy fails to take sufficient account of appropriate mitigation measures which may form part of a development proposal and could overcome any adverse impact arising on the character of the immediate and wider landscape. Home Builders Federation are concerned that criteria 4 is too open ended and would fail to provide an adequate steer to applicants and decision-takers in terms of whether the principle of

98 development on a particular site is accepted. They suggest that the Local Plan should clarify that all allocated sites in the plan provide acceptable locations for development and the principle of development should not be in doubt. Smith Gore supports the need for new development to protect the landscape and scenic quality of the National Park. They request that the scope and extent of a typical LVIA should also be clarified (e.g. should it include photomontages), because LVIAs with photomontages are costly to procure and a proportionate and consistent approach as to when they are required is needed.

Individuals One individual objected to the policy and commented that:

 the best way to preserve landscape character is to clearly define and have the potential for adequate development within the settlement policy boundaries, so that landscape can be preserved and enhanced without pressure from residential or other development over the Plan period.  Policy SD5(4) should acknowledge that there is need within the Park for development and that any development will have some impact on the character of the landscape. It is therefore important that Settlement Boundaries allow for some development whilst distinguishing between areas within or adjacent to settlements where development may be appropriate and the wider landscape setting. One individual commented that criteria 3 might conflict with the specific policies on the cement works. One individual agreed with the policy. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Policy structure and wording amended for clarity and consistency with other polices in the Local Plan and this captures many minor comments about wording. An example of a key change is the final ‘sting in the tail’ criteria (4) which is deleted to reduce unnecessary repetition of text elsewhere in the Local Plan – the Local Plan should be read as a whole.  The definition of landscape is clarified in the supporting text to also include townscape. Some terms are further clarified in the glossary.  Wording has been added to the supporting text to provide further clarification with regard to LVIA requirements.  The criteria relating to protecting the open and undeveloped nature of existing gaps between settlements is expanded to reference the individual integrity of settlements.  Reference to the setting of designed landscapes (which include Registered Historic Parks and Gardens) is included in the policy.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Suggested that specific gaps between It is considered that the policy criteria is the settlements are identified and named for appropriate mechanism for protecting the protection through this policy identity of settlements and the integrity of predominantly open and undeveloped land between settlements. Current wording related to protecting the This policy should be read in conjunction with open space between built up areas is not the Telecommunications and Utilities supported by Southern Water due to the Infrastructure policy. The capacity physical special requirements of their service provision. infrastructure is a material consideration for a planning application. The policy fails to take sufficient account of This matter would be taken into account at appropriate mitigation measures which may application stage. form part of a development proposal and could overcome any adverse impact arising on the character of the immediate and wider landscape. The "conservation and enhancement" of The Authority has sought legal advice which landscape character should be amended to read confirms that the use of ‘conserve and enhance’ "conserve and/or enhance" to remove any is appropriate. potential conflict in the wording. The Local Plan should seek to direct new This matter is addressed through the Strategic development to previously developed land / Policy which sets the Development Strategy. brownfield land in the first instance, such as Shoreham Cement Works. Such opportunities should be maximised so that areas of less disturbed landscape character can be saved from development. Suggested that reference and criteria related to Disagree. It is considered that it is appropriate historic significance of designed landscapes and to provide criteria here in relation to the Registered Historic Parks and Gardens would historic character of landscape, and that this sit better within the Historic Environment policy works with the policies included within section. the Historic Environment section. Comment that non-native plant/tree species Matter is considered to be appropriately should be removed in favour of native addressed in the criteria or this policy and plant/tree species, particularly in conservation those in the following policies: areas and if appropriate to the historic - Trees, Woodland and Hedgerows landscape. - Biodiversity and Geodiversity - Historic Environment - Conservation Areas - Design Requested reference to soil quality be included The role of soils is an important ecosystem service. This matter is addressed in the Core Policy on Ecosystem Services.

100

Policy SD6: Design

Reg 22 (1) (c) (iii) There were a total of 54 comments on this policy. These are summarised below. National Agencies Two National Agencies responded to this policy. Both supported the policy and made the following comments: Historic England – welcomed and supported the section on contribution to the cultural heritage, character and function of settlements (paragraphs 5.35 and 5.36). Would welcome the addition of “historically significant features” to the list of elements of landscape and built environment. As well as Conservation Area Appraisals and Management Plans in the policy list at clause 1. Sport England – the policy should include reference to Active Design Borough, City, County and District Councils Support was given by three district councils. The following comments were made: The policy needs to address the need to create safe and accessible places, where crime and fear of crime do not undermine the quality of life of residents (paragraphs 58 and 60 of the NPPF). Parish and Town Councils 11 Parish/Town Councils responded to this policy. 8 Supported the policy. The following comments were made:

 Policies must be robust enough to withstand appeals.  The design of new buildings should not only reflect the past.  Whole Estate Plans (masterplans) should extend to all businesses with significant land holdings.  Materials currently being approved are highly inappropriate.  The SDLP should require all new buildings and renovations to include bat and bird boxes, as is required in the New Forest National Park.  Suggestion made that the policy wording is strengthened to ensure impact on the National Park boundary is rigorously scrutinised.  The Design SPD referred to in the supporting text should be added to the list at clause 1.  Clarification of the phrase “private realm”  Recommended deleting clause 2 as this gives unnecessary emphasis.  The policy should cross-reference policy SD7-views and clarify which views should be protected.

101

Other Organisations 18 groups or organisations commented on this policy. 11 supported the policy. The following comments were made:

 Overall the Plan should be encouraging the sort of actions/proposals that the SDNPA do want, through a more positive framework. Wordsmithing may be required to make the plan more positive. More needs to be said encouraging better connected habitats, benefits to the SDNP in line with Purposes, and make clear the longterm aim of a fully connected, wildlife rich landscape.  Further clarification on estate plans required (who/what estates are advised/must draft one)  Prompt preparation and publication of a Design SPD is required. Consultation on draft Design SPD would be welcomed. It should include illustrations/examples/graphics. It should also be referenced in the list at clause 1.  Reword clause 2a from “make a positive contribution to the character” with “respect the character”. As a positive contribution is open to wide interpretation and debate.  The term “where appropriate” is quite weak and should be replaced with “Development proposals should…”  The policy does not provide enough information for applicants, this needs to be included. The detailed guidance for design should not be devolved to an SPD.  It is unclear what the Authority means in Clause 2f) “adaptable”. This must be clarified. Other terms also questioned (where relevant, robust, appropriate, private realm, unacceptable)  The Authority should also encourage modern design. Addition to Clause 1) “…are of a high- quality design, including excellent modern design…”  The importance of proportionality as well as clarity when implementing the Whole Estate Plans is paramount. It must be clear when they are required, what applications they have to accompany, what “robust” means in terms of an estate plan (clause 1, 4th bullet)  There should be a threshold for largescale development proposals, to ensure that they are earmarked for Design Review Panel at validation stage.  The policy should include a presumption in favour of locally sourced materials (2a), rather than just locally appropriate.  Applicants should be required to include an explanation of the purpose of the development, in order to discern whether there’s a genuine attempt to ‘enhance’. Information should consider how the people are going to use the place/space and how the design layout would function -including social, environmental and economic issues. There needs to be more emphasis onto whom the imagined community will be. Development proposals should present clearly defined concepts/aims which explain how development will ultimately enhance the experience of the end user.  There should be an additional policy on street pattern/grain, footpaths and sunken lanes

102

Agents and Developers 12 comments were received on this policy. 3 supported and 1 objected to the policy. All made comments, which are summarised below:

 In relation to Whole Estate Plans, in clause 1 (4th Bullet) the qualifying phrase “where relevant” must be kept in the policy.  Local vernacular should not be at the expense of innovative design.  Querying what the Strategic Stone Study is / availability?  SD6 2) Neglects to mention jobs. Objection

 Not all landscape is of equal quality, some has no ‘iconic’ quality whatsoever. By unreasonably taking a landscape led approach across the whole of the Park area, the plan lacks balance and fails to give appropriate weight to the statutory Duty of the National Park.

Individuals 6 individuals responded to this policy. 3 supported and 3 objected to the policy. The comments made are summarised below: Support

 Guidance for camping / caravan sites would be helpful Object

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The policy has been significantly restructured to provide greater clarity, in particular with regard to the requirements for development proposals to take a landscape-led approach, and also to reduce unnecessary duplication of text elsewhere in the Local Plan.  Additional criteria is added to ensure development is designed improve safety and perceptions of safety and to be inclusive and accessible for all.  Wording of the policy and supporting text is amended for clarity to reflect that all development proposals, including innovative and modern design, must reinforce local distinctiveness, taking reference and visual cues from landscape and local settlement identify and character.  Reference made in the supporting text to ‘locally sourced materials’  Reference made in the supporting text to active design.  Additional wording in the supporting text regarding the importance of development to meet the day-to-day functional needs of its users.  The Authority is undertaking work on a Design SPD and this is referenced in the supporting text of this policy.  Key terms are explained in the supporting text and through the glossary.  Separate Whole Estate Plan guidance has been produced.

103

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Respondent’s commented that not all landscape The South Downs was designated as a national is of equal quality some has no ‘iconic’ quality park due to its iconic lowland landscapes. As a whatsoever by unreasonably taking a landscape- national park it has the highest level of national led approach across the whole of the Park area landscape protection along with AONBs. planning policy lacks balance and fails to give appropriate weight to the statutory duty of the National Park Authority. The policy should cross-reference policy SD7- Disagree. The policies do not cross reference views and clarify which views should be other policies in the Local Plan – the Local Plan protected. should be read as a whole.

There should be a threshold for largescale Disagree. It is not considered appropriate to development proposals, to ensure that they are have a set threshold in this manner. earmarked for Design Review Panel at Applications are to be considered on a case by validation stage. case basis with regard to Design Review Panel as the specific context, constraints and sensitivities of a site are important factors.

104

Policy SD7: Safeguarding Views

Reg 22 (1) (c) (iii) There were a total of 50 comments on this policy. These are summarised below. National Agencies Historic England welcomes and supports the policy and made a number of comments:

 welcome and support paragraph 5.45, but would like to see "Conservation Area Character Appraisals" and "Conservation Area Management Plans" added as documents to which reference should be made in the first sentence.  In historic environment terms, views can be significant in terms of the appreciation or significance of the viewing place (e.g. the Temple of The Winds) as well as of the heritage assets in the view. They would prefer "heritage assets" to "cultural heritage" in clause 1d). Natural England supports the policy. Borough, City, County and District Councils Adur and Worthing Council commented that it will be important to understand how views over the sea and coast beyond the National Park boundary could impact development outside of the National Park (reference to para 5.40) and request clarification on the wording of para 5.48. East Hampshire District Council state that from a landscape perspective the Council supports the policy. East Sussex County Council have serious concerns about the implementation of the policy, specifically reference in supporting text to proposals visible beyond the boundary of the National Park. They comment that superficially, this policy could appear to be beyond the power of the NPA and should be considered as a strategic matter under the Duty to Cooperate, but to date, they are not aware of any attempt made by the NPA to discuss this matter. They suggest addition and consultation on comprehensive criteria in relation to areas, distances, and types of application. Winchester District Council made a number of comments:

 Concerned regarding the interpretation of policies as there are various references in the Local Plan to evidence based studies that are yet to be published and references to areas being defined on the policies map which does not appear to have been produced.  It is not possible to assess the potential implications of this policy as part of the current consultation without seeing the Viewshed Characterisation Study.  Would not wish this policy to have a negative impact on proposals within the Winchester District or on its ability to determine development proposals on the edge of the Park – for example in and around Winchester Town and within the larger settlements where sites have been allocated for development through Local Plan Part 2.  The terminology used in the policy and how the judgements will be made as to potential impact when officers are considering planning applications needs to be resolved and clarified. Horsham District Council welcome the opportunity to work with the NPA in relation to safeguarding key views to the park (such as Chanctonbury Ring) from key locations within Horsham District.

105

Parish and Town Councils Arundel Town Council suggestion deletion of criteria 2 and 3, which they consider provides unnecessary emphasis. Buriton Parish Council welcomes the policy. However, they would wish the National Park Authority to be 100% confident that all the Strategic Policies are sufficiently robust and practical to withstand the tests and rigours of Planning Appeals etc. The Parish Council is conscious that all these new policies are replacing some long-standing, tried-and-tested policies in the East Hampshire Local Plan and Joint Core Strategy. Bury Parish Council supports the concept of the Core and Strategic Policies. All are important, but the Council particularly noted with broad approval of SD7 (amongst others listed). They suggest a greater degree of cross referencing in a future document between the policies and where they apply in specific regions. Bramshott and Liphook Parish Council support this policy and in particular item 1(b) which is significant for settlements with cross boundaries or which have a boundary with the Park. They consider that importance should be placed on views which border main routes as these are significant for residents, visitors and especially viewers with disabilities which prevent them from accessing the Park by foot or other sustainable forms of transport. As an example, with an increasing ageing population, the views from Portsmouth Road and Longmoor Road in Liphook are significant both for visitors entering the Park and local residents including those with mobility problems. Cuckfield Parish Council makes a number of comments:

 Notes that whilst not within the Park itself, the Parish is within the 'zone of influence' and as a High Weald ridge-top settlement has an affinity with the South Downs.  Note that landscape, and in particular views, are a key theme of the Plan and their 'Made' Neighbourhood Plan highlights that our far reaching strategic views to the South Downs from the village boundary is a distinctive quality, which we aim to preserve through a number of planning policies.  They note that new development within the Weald can have a significant impact on views from the South Downs ridge, particularly at the eastern end of the Park (with reference made to housing development in Haywards Heath and Burgess Hill).  They recognise limited jurisdiction of the NPA outside the boundary of the National Park, but recommend that the NPA work closely with adjacent planning authorities and neighbourhood forums to ensure that future development outside the Park can be accommodated within the landscape in the least imposing way, and thereby mitigate impacts on views to and from the Park itself.  Suggest a plan of key locations of (GIS terrain map driven) 'viewer potential' may be helpful in determining which areas to focus on, where impacts may be greatest.

106

East Chiltington Parish Council, Liss Parish Council and Rottingdean Parish Council all express strong support for the policy. East Dean & Friston Parish Council consider this to be a very significant policy for the parish of East Dean and Friston. They referred to the Viewshed Characterisation Study and asked when it will be available for consultation. They express two concerns about the draft policy:

 ‘Take into account’ is a weak term unless it can be more tightly defined.  Emphasis is on mitigation of the effects of development. This could greatly weaken the protection of views, and therefore undermine the policy. It is at odds with SD6 clause 2(b) which requires development proposals to take account of their location and context to ‘reduce the need’ for screening planting, etc. Suggest that these two policies should be interlocked. Iford Parish Meeting welcomes the policy and note that Iford forms part of an area of inspirational landscapes and breathtaking views, as defined in the Local Plan. Itchen Valley Parish Council support the notion of protecting view but note that it is also important to restore lost views where possible, views along the Itchen in particular are important to our community. Patching Parish Council supports the policy. Plumpton Parish Council made the following comments:

 The terms in criteria 1 are too vague. 'Unacceptable' and 'adverse' are subjective measures  Para 5.43 - The breadth of this policy is too great. The SDNP is, because of its geography, in a position to over-ride communities’ rights to self-determination across a very large swathe of landscape. Question how far would this right to veto developments within its viewscape extend. Consider that SDNPA’s powers do not extend outside its borders or that villages bisected by or on the borders of the Park and over whose development plans SDNPA claims jurisdiction enjoy the same protected status with regard to local council housing development quotas as those within the park’s boundaries  Para 5.48 is not clear. Question whether it suggests that SDNPA will be able to block developments outside the boundary if they impede views of the Downs from anywhere within eyeshot of the Downs. Selborne Parish Council support the policy, in particular paragraph 5.48, but suggest the removal of the word "unacceptable" before "adverse impact" from criteria 3. Steyning Parish Council welcomes the emphasis placed on the importance of preserving views in para 5.42 and 5.43. Warnford Parish Meeting support this policy in principle but note that the Viewshed Characterisation Study does not appear to be in the public domain so the specific impact on Warnford cannot be assessed. They request access to this document.

107

Other Organisations The Chichester Society suggest that the Local Plan should identify those areas outside the National Park where development would adversely affect key views from the Downs. They consider this to be of particular concern in the vicinity of Chichester and iconic views (i.e. of the spire of Chichester Cathedral with the inlets of Chichester Harbour beyond, viewed from Bow Hill, Stoke Clump, St Roche’s Hill/ The Trundle, and Halnaker Hill) are vulnerable to proposed housing development within the adopted Chichester District Local Plan, as well as from a possible A27 northern bypass or from new or reopened mineral sites under consideration within the draft WSCC/SDNPA Minerals Local Plan. They request close liaison between the NPA and Chichester DC is essential in mitigating the visual impact of these major developments. The City of Winchester Trust note that their comments are made without the benefit of seeing the contents of a ‘Viewshed Characterisation Study’ which was not available. They comment that as the setting of Winchester to the East is on the boundary of the National Park it is important that the policies in the Local Plans of both the National Park and Winchester City Council complement and support one another in protecting the views from the National Park, particularly St Catherine’s Hill, towards Winchester and Bushfield Down and the views in the other direction from Winchester and Bushfield Down towards St Catherine’s Hill and any other land within the National Park. CPRE Hampshire express strong support for the policy and make the following comments:

 Views are the main way that the public experiences landscape and landscape character, and so maintaining views is critical to conserving the Special Qualities of the SDNP.  There is no reference to the impact of development outside the SDNP on views from the SDNP.  Express strong support for policies SD5, SD7, SD8 and SD9 as a group and consider them an essential tool to conserving and enhancing the Special Qualities of the SDNP throughout the Plan Period.  To include specific detailed policies to safeguard views, relative tranquillity and dark night skies is innovative, very welcome and entirely appropriate for a national park located where these critical features are always under threat. CPRE Sussex strongly support the policy, but would like to see the additional provision within this policy setting out the Authority’s approach to development proposals outside the park that affect that landscape or valued views enjoyed from it. Friends of Lewes Society welcomes and support the policy. Friends of the Earth Brighton & Hove supports the policy, but suggests that removal of ‘unacceptable’ before ‘adverse impact’ in criteria 3. The National Trust support the policy and consider that the work carried out by the SDNPA and Land Use Consultants in identifying key views within the National Park will support the continued understanding of the landscape character of the park and the impact of development upon on key views. They note that they are happy to support the monitoring of these viewpoints. The South Downs Society support the policy. Wiggonholt Association consider the policy to be a valuable innovation which directly serves National Park purposes. They note that the length of the SDNP, which in many places is very narrow, and the need to safeguard views applies not only to views within the NP but also of the NP from outside and from within the NP of the surrounding countryside. They consider that this implies a need for close co-operation with neighbouring LPAs going beyond what is foreseen in criteria 5.

108

Safeguarding of iconic views of the Seven Sisters coastline, Seaford Head and the Cuckmere Estuary need protection from development outside the National Park.

Agents and Developers D C Heaver and Eurequity Limited object to the policy. They note that the Viewshed Characterisation Study was only made publicly available a few days prior to the close of the consultation and was missing the Figure 2.1 and Figure 2.2. Given this they consider that it is not possible to comment informatively on this policy given these key supporting viewshed maps are not available. Therefore they wish to reserve the right to comment on this policy further once these maps are made available. Dudman Group of Companies suggest that it should be recognised that some forms of development and land-use are temporary and that visual impact can be transient and vary over the lifetime of the development. They comment that it may be that visual impact during the whole life, or part of the life cycle, of a development may be adverse but that on completion of the development restoration and reinstatement may be beneficial to the wider landscape. Forest Holidays Ltd welcome the strategic approach taken to safeguarding views. However, they consider it difficult to comment on the content of the policy when certain baseline information used to inform the policy has not yet been finalised / published (i.e. the Viewshed Characterisation Study). They agree that strategic assessments and theoretical considerations are not a substitute for a site based LVIA and that it is this which is the most appropriate method to assess a development’s impact on the landscape. The Home Builders Federation asked that it should be clarified that this does not apply to sites allocated by the plan and assume that the Authority has already judged that these sites do not adversely affect any safeguarded views. Tetlow King question what special quality criteria 3 is referring to and considered that the wording could be used to refuse all planning applications. The consider that any development can be perceived to have adverse impacts, the criteria is not concise, it is too subjective on what "unacceptable adverse impact" means and does not allow a balance against the benefits of the proposal. Individuals One individual strongly supports the policy. One individual state that they agree with the policy. One individual suggested the addition of, and ensure that those areas lying within the setting of the SDNP retain their views onto the SDNP and similarly those from the SDNP out into the adjacent areas are retained. One individual commented that the views within the SDNP are one of the many, arguably one of the main, attractions of the SDNP and that these views should be conserved at all times for posterity and the enjoyment of future generations. Reference made to the views from the Selborne Hanger, and from Selborne's public rights of way (Nos 13 and 14), looking towards the straggling form of Gracious Street, which must be one of the highlights of any walker or visitor to these areas. One individual comments that the policy is very important to maintain the character of the National Park.

109

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Policy structure and wording amended for clarity and consistency with other polices in the Local Plan, for example, the final ‘sting in the tail’ criteria is deleted, and to reduce unnecessary repetition of text elsewhere in the Local Plan – the Local Plan should be read as a whole.  The term "cultural heritage" is changed to "heritage assets" in clause 1d) (now 2d)).  The Viewshed Characterisation Study has been published on the evidence page of the Authority’s’ website.  Paragraph 5.48 which refers to outside of the National Park is deleted due to lack of clarity as part of the overall restructure of supporting text.  Key terms are explained in the supporting text and through the glossary.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Some respondents have asked the provision be As required by section 62 of the Environment made in the policy to protect view into the Act 1995, local authorities planning National Park, and from the National Park into development and determining planning surrounding areas from development which applications outside of the National Park, but may take place outside of the National Park. which may impact the National Park, have a duty to have regard to the National Park purposes. The National Park will work with authorities on this matter. Additional text proposed for clarity. The policies of the South Downs Local Plan can only apply directly to the South Downs Local Planning Authority Area. "Conservation Area Character Appraisals" and This matter is covered by the policies in the "Conservation Area Management Plans" added historic environment section of the Local Plan. as documents to which reference should be Cross references are minimised to reduce made in the first sentence repetition the Local Plan should be read as a whole. The Home Builders Federation asked that it It may be the case that some allocations may should be clarified that this does not apply to need to address the criteria of this policy sites allocated by the plan and assume that the through the design and layout of the Authority has already judged that these sites do development. not adversely affect any safeguarded views.

110

Policy SD8: Relative Tranquillity

Reg 22 (1) (c) (iii) There were a total of 39 comments on this policy. These are summarised below. National Agencies There were no comments made the National Agencies on this policy. Borough, City, County and District Councils Chichester District Council commented that a pixelated map is not detailed enough and a more accurate map is required. East Hampshire District Council state that from a landscape perspective the Council supports the policy. Winchester District Council comment that they understand that an evidence document is being prepared that will establish the baseline for relative tranquillity and until this is published it is difficult to determine the implications of this policy. Parish and Town Councils Arundel Parish Council suggest deletion of “clearly” in criteria 1 and deletion of criteria 2 as they provide unnecessary emphasis. Buriton Parish Council welcomes the policy. However, they would wish the National Park Authority to be 100% confident that all the Strategic Policies are sufficiently robust and practical to withstand the tests and rigours of Planning Appeals etc. The Parish Council is conscious that all these new policies are replacing some long-standing, tried-and-tested policies in the East Hampshire Local Plan and Joint Core Strategy. Bury Parish Council supports the policy. They suggest a greater degree of cross referencing in a future document between the policies and where they apply in specific regions. Bramshott and Liphook Parish Council fully support this policy which covers an element which is underestimated as a value to the health and well-being of residents. This shows a welcome holistic approach to development. Iford Parish Meeting note that Iford Parish has been placed in the highest category of tranquillity scores for the National Park. Iford Parish Meeting supports the designation and the policy. In particular, the reference to increased vehicle movements which may be caused by development remote from the location. Consider that the policy would help to resist development which could result in increased traffic on C7, which already suffers from excessive traffic, and is therefore welcomed by the Parish Meeting. Itchen Valley Parish Council and Liss Parish Council support the policy. Madehurst Parish Meeting comment that Madehurst and neighbouring Houghton Forest appear to be in the top level on the tranquility scale and, therefore, consider policy criteria 1b and 1c; 2 and 3 are very relevant to Madehurst and strongly support these. Selborne Parish Council support the policy, but suggest replacing “unacceptable adverse impact" with the word ‘harm’ in criteria 3. Steyning Parish Council welcomes the emphasis on tranquillity.

111

Warnford Parish Meeting support this policy in principle but note that the South Downs Tranquillity Study does not appear to be in the public domain. Fig 5.3 shows an isolated area with negative tranquillity score in the Warnford/West Meon area which may be a result of noise from irresponsible and illegal motorcycle use on the A32. If this is the case they do not believe that it is reasonable for future development to be based on these figures. They request access to the Study so that we can properly consider this point and decide whether the evidence base for the policy is sound in terms of its implications for Warnford. West Meon Parish Council supports the policy in a whole, in particular 1(b), as West Meon is seriously affected by motorbike noise on the A32. Other Organisations The Angmering Estate, the Cowdray Estate, Leconfield Estate and the West Dean - The Edward James Foundation note that the policy cross-refers to the South Downs Tranquillity Study, which is not available to view. They are aware of the Campaign to Protect Rural England’s (CPRE) work on quantifying tranquillity. However, tranquillity is not a recognised planning concept and without the accompanying Tranquillity Study, it is difficult to comment on this policy. They also comment that the policy could be onerous and act as an unnecessary impediment to development and further clarification on the Tranquillity Study and its implications should be provided. CPRE Hampshire express strong support for the policy and make the following comments:

 Express strong support for policies SD5, SD7, SD8 and SD9 as a group and consider them an essential tool to conserving and enhancing the Special Qualities of the SDNP throughout the Plan Period.  To include specific detailed policies to safeguard views, relative tranquillity and dark night skies is innovative, very welcome and entirely appropriate for a national park located where these critical features are always under threat.  Agree that relative tranquillity is one of the key characteristics that makes the SDNP so valued and consider the inclusion of this policy entirely appropriate in the Plan. Note that CPRE has long campaigned for tranquillity to become a mainstream aspect of planning and so this policy is strongly supported by CPRE Hampshire.  The policy needs to deal with indirect impacts of development proposals on relative tranquillity, as well as direct impacts and support criteria 1(b). CPRE Sussex strongly support the policy. Friends of the Earth Brighton & Hove support the policy, but suggest removing ‘unacceptable’ before ‘adverse impact’ in criteria 3. Gilbert White Museum note that the reproduction is poor and text hard to read on map on page 65. NFU (South East Region) notes that the study referenced is yet to be published and members of the public currently have no indication as to the criteria that will be used to assess tranquillity. They are concerned that a very strict definition could be used to prevent particular livestock enterprises. For example if an increase in cattle noise is considered as an unacceptable harm to tranquillity enjoyed by residents and visitors. They suggest a further consultation once the tranquillity study has been published. South Downs Land Managers Group comments that there is a need to recognize that farming involves the use of large and sometimes noisy equipment but is necessary in order to manage the land. There may be other economic activities in rural areas that are appropriate / essential that

112 impact on tranquility and that there may need to be a trade off. They suggest additional wording to para 5.50 to acknowledge this. The Upper Itchen Valley Society strongly support the policy, but in this context there is nothing about control of events such as Boomtown at Matterley Bowl near Winchester which is anything but tranquil! Wiggonholt Association and South Downs Society support the policy. Agents and Developers D C Heaver and Eurequity Limited note that the policy makes reference to the South Downs Tranquility Study, but that this is not yet available to review. In light of this, they consider that it is not possible to comment informatively on this policy and wish to reserve the right to comment further once the study becomes available. Dudman Group of Companies suggests that references to "conserve and enhance" should be amended to read "conserve and/or enhance" to avoid conflict between the two terms. The consider that the policy should recognise that any new development will impact the status quo and in particular the temporary and varying nature of the impact. Whilst noting the reference in the text to the effect that "tranquillity" is to be differentiated from "noise", they feel it should be clarified that there are statutory limits for noise, issued from time to time, and whilst compliance with such limits may not necessarily automatically mean that the "tranquillity objectives" will be met, nevertheless where statutory controls on noise do apply these should not be overridden by this proposed policy. Forest Holidays Ltd comment that it is hard to comment policy without understanding the core evidence base, in particular, the South Downs Tranquillity Study, which is yet to be finalised and published. They request that the study and its methodology should be published to allow a thorough understanding / examination of this policy as without it, no proper assessment can be made of the appropriateness of the policy. They comment that any assessment of the effects of tranquillity should be undertaken in an objective and recognised manner. Smiths Gore note that the policy cross-refers to the South Downs Tranquillity Study, which is not available to view. They are aware of the Campaign to Protect Rural England’s (CPRE) work on quantifying tranquillity. However, tranquillity is not a recognised planning concept and without the accompanying Tranquillity Study, it is difficult to comment on this policy. They also comment that the policy could be onerous and act as an unnecessary impediment to development and further clarification on the Tranquillity Study and its implications should be provided.

113

Individuals One individual supports the policy. One individual considers this policy to be a hugely important principle in supporting the overall strategy for the SDNP. One individual suggest inclusion of a reference to Gatwick and proposals there which are having an adverse impact on tranquillity within and the Park and in areas adjacent to the SDNP and considers that by only referring to development proposals this overlooks the way in which the sky is not being defended above people's homes.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason One individual suggest inclusion of a reference As required by section 62 of the Environment to Gatwick and proposals there which are Act 1995, local authorities planning having an adverse impact on tranquillity within development and determining planning and the Park and in areas adjacent to the SDNP applications outside of the National Park, but and considers that by only referring to which may impact the National Park, have a development proposals this overlooks the way duty to have regard to the National Park in which the sky is not being defended above purposes. The National Park will work with people's homes. authorities on this matter. However the Local Plan policies can only be applied in the Local Planning Authority area. Dudman Group of Companies suggests that The Authority has sought legal advice which references to "conserve and enhance" should confirms that the use of ‘conserve and enhance’ be amended to read "conserve and/or enhance" is appropriate. to avoid conflict between the two terms.

114

Policy SD9: Dark Night Skies

Reg 22 (1) (c) (iii) There were a total of 54 comments on this policy. These are summarised below. National Agencies Natural England supports the inclusion of this policy. They comment that it supports Policy SD13 (International Sites) with reference to sites designated for the protection of bats and that it also has the potential for wider biodiversity benefits. Borough, City, County and District Councils Adur and Worthing Council support this initiative in principle. The comment that it should be noted that this initiative should not hinder the development of strategic and other development (and associated infrastructure) outside the National Park and the urgent need to address safety and congestion issues along the A27 trunk road adjacent to the Park should be recognised. They also note that proposals for the New Monks Farms strategic site which is being progressed through the Adur Local Plan includes a proposal for a new junction on the A27. East Hampshire District Council state that, from a landscape perspective, the Council supports the policy. However, they comment that there is no advice on who our Development Management Officers should consult to make such an assessment outlined in criteria 3 and a plan showing the environmental zones alongside the policy would be helpful. Wealden District Council are pleased to note the inclusion of dark night skies policies and are seeking to explore this aspect of policy in relation to Wealden District, not only to help support the objectives of the South Downs National Park Authority, but also to help protect and enhance the landscapes elsewhere in the District. They would welcome further discussion on this matter. Winchester District Council note that a dark sky core boundary is referred to in policy but not available on the policies map which has yet to be published. Furthermore, there is reference to the measured and observed sky quality in the surrounding area not being reduced, it is unclear as to how this will be assessed. Parish and Town Councils Arundel Town Council suggest the deletion of criteria 2 and suggest deletion of “the most rigorous” in para 3, considering this to be unnecessary emphasis. Buriton Parish Council welcomes the policy. However, they would wish the National Park Authority to be 100% confident that all the Strategic Policies are sufficiently robust and practical to withstand the tests and rigours of Planning Appeals etc. The Parish Council is conscious that all these new policies are replacing some long-standing, tried-and-tested policies in the East Hampshire Local Plan and Joint Core Strategy. Bury Parish Council supports the policy. They suggest a greater degree of cross referencing in a future document between the policies and where they apply in specific regions. Bramshott and Liphook Parish Council state that the policy, which is significant for both people and wildlife, is fully supported as it protects both areas of development and adjacent areas from unnecessary light pollution. They suggest inclusion of restrictions to future changes or additions to lighting after a development has been established. Cheriton Parish Council keen to support the policy and will continue to oppose extra street lighting.

115

Clapham Parish Council comment that it would be helpful if you would clarify the policy with regard to existing intrusive lighting. Droxford Parish Council suggest providing a simple key for figure 5.4 to explain mags per arc second to the less technically minded. East Dean & Friston Parish Council consider this is another policy which is potentially important locally, and which the council will wish to dovetail with the parish’s Village Design Statement. However, they comment that without seeing the detail of the Policies Map it is difficult to make more specific comment. Harting Parish Council commented and suggested changes to: • criteria 2d (i) - consider it should be more specific about where, and under what circumstances, rooflights, roof lanterns, conservatories with glass roofs, two-storey ‘barn style’ windows etc will be allowed. They comment that with efficient double glazing and, in many rural situations no need for blinds & curtains for privacy, mitigation measures are unenforceable. • criteria 2d(ii) - suggest that planning permission should be required for the installation of roof-lights etc in all extant properties throughout the National Park as well as for ‘new build’. Itchen Valley Parish Council, Iford Parish Meeting and Liss Parish Council support the policy. Madehurst Parish Meeting fully support this policy and the application for International Dark Skies status. Note that Madehurst is in the epicentre of a key part of the National Park in this respect, given its elevated position on the Downs and bordering Bury Hill. Selborne Parish Council support the policy with enthusiasm. Steyning Parish Council support the policy and welcomes the emphasis on dark night skies. West Meon Parish Council supports the policy and comments that any development should respect this policy and have appropriate lighting levels. Woolbeding with Redford Parish Council request that para 5.55 also include the use of large high tower moveable floodlights to limit their usage to short periods only. Consider that they are currently a loop hole around current planning regulations with a major impact on dark skies. Other Organisations The Angmering Estate, the Cowdray Estate, the Leconfield Estate and West Dean - The Edward James Foundation support the policy in principle. However, comment that the requirement for a lighting assessment needs to be proportionate to the quantum and type of development proposed and the policy wording should be amended to reflect this (i.e. it should be recognised that small scale development with no external lighting requirement will not require a lighting assessment). CPRE Hampshire expressed strong support for policy and consider that to include specific detailed policies to safeguard views, relative tranquillity and dark night skies is innovative, very welcome and entirely appropriate for a national park located where these critical features are always under threat. They also comment that Figure 5.4 is important in supporting the need for Policy SD9 as it underlines the high quality of dark night skies which exist in the SDNP. Question whether it has been updated to take account of the recent improvements in street lighting in the SDNP and neighbouring areas, thereby reinforcing the evidence base supporting Policy SD9.

116

CPRE Sussex strongly support the policy but comment that mitigation (referenced in criteria 1c) is not appropriate or sustainable as regards protection of bat roosts, where peer reviewed studies show that there are flaws in monitoring success. Friends of Lewes Society supports the policy. Friends of the Earth Brighton & Hove supports the policy. NFU South East Region comment that lighting is essential to enable work to take place in farm yards in a safe and effective manner, particularly as many farm activities take place during antisocial hours. They acknowledge that there are certain mitigations that can be included such as the use of PIR’s and appropriate positioning, in most cases strong flood lighting is required in a farmyard, as the alternative would be to operate with heavy machinery or livestock under very dangerous dark conditions. Therefore, they consider that agricultural planning applications are unlikely to be able to comply with this policy in its entirety and suggest that the policy wording is amended to include scope for the installation of lighting where it can be demonstrated there is an essential health and safety requirement. The National Trust has supported the Dark Skies project since its inception. They comment that they will continue to support this project and will give careful consideration to the light levels within our own land and properties and seek to minimize external lighting in areas of our land which are within the identified darkest areas. South Downs Society supports the policy. Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trust (joint response) support the inclusion of a policy on dark night skies. However they suggest that the policy should be strengthened in regard to the protection of biodiversity from the impacts of lighting (SD9 part b) and para 5.61 should be incorporated into the policy wording rather than sitting in the supporting text where it holds far less weight. They suggest that given the high potential for bat roosts across the National Park, there must be specific protection for European Protected Species in this policy and recommend that a more specific term such as ‘habitats’ or ‘habitats sensitive to lighting’ is used rather than ‘key habitats’. South Downs Land Managers Group comment that rural crime is an increasing problem there may be a need for security lighting particularly on farms. They request that reference to security lighting in supporting text and acknowledge need in rural areas to deter rural crime. Wiggonholt Association consider that the policy should also include large wind turbines and cross reference to SD56.

117

Agents and Developers Smiths Gore support the policy in principle. However, comment that the requirement for a lighting assessment needs to be proportionate to the quantum and type of development proposed and the policy wording should be amended to reflect this (i.e. it should be recognised that small scale development with no external lighting requirement will not require a lighting assessment)

Individuals One individual commented that criteria 3 is too vague and woolly and there is no explanation as to whom will take the lead on such assessments. They also suggest that a plan showing the environmental zones alongside the policy would also be helpful. One individual questions how you reconcile Dark Night Skies with security lighting. One individual state that they fully support this policy and makes reference to live music event (Boomtown) at Matterley Estate which involved lasers, significant lighting over a large site, scaffold towers around the whole perimeter on which were searchlights and between which were lighting poles. They consider that none of these complied with the Dark Night Skies policy and I hope action will be taken to prevent a future occurrence. Two individuals stated their support the policy. One individual expressed support for the SDNP becoming an International Dark Sky Reserve One individual questions how dark night skies relate to visitor economy and whether they are a threat or opportunity and ask how we turn them to an opportunity. One individual agrees with the policy. They comment that security lighting and lighting of gardens, stables and manages in rural locations should be very strictly controlled and new developments should be carefully designed as suggested. One individual fully support the dark skies project and comments that the map illustrates the adverse impact of poor lighting implementation in surrounding settllements, such as Rowlands Castle where light spills into the National Park. Suggest the authority must set standards for surrounding communities to minimise light pollution. One individual commented that this is excellent and support this policy. However, they consider that it is threatened by increasing numbers of planes flying in and out of Gatwick and that SDNPA needs to challenge Gatwick over its plans and to insist on the importance of unspoilt night skies. One individual considers the policy to be ludicrous and ridiculous. They comment that people in the workplace (i.e. farmers and workers) need lighting when they are in the fields at night to be able to carry out their work safely and very often they are under pressure from the elements of the weather to complete certain tasks and need to work on late into the night to get the job done. One individual states that they entirely agree with the policy and domestic floodlighting should be prohibited and that commercial usage should be strictly regulated to only essential requirements. One individual agreed with the principle of the policy, but commented on the impact of not dark skies adjoining the park and the effect of these lights on the park itself? They question the authority of the NPA to influence light levels from adjoining land.

118

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Policy is significantly restructured to provide greater clarity and to reduce unnecessary repetition.  Recognition of the proportionality of lighting assessments to the scale of development proposals is added to the supporting text.  Map showing the zones is published along with a key.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason The impact of not dark skies adjoining the park As required by section 62 of the Environment and the effect of these lights on the park itself? Act 1995, local authorities planning They question the authority of the NPA to development and determining planning influence light levels from adjoining land. applications outside of the National Park, but which may impact the National Park, have a duty to have regard to the National Park purposes. The National Park will work with authorities on this matter. However the Local Plan policies can only be applied in the Local Planning Authority area. Policy should be strengthened in regard to the Matter is addressed through the Biodiversity protection of biodiversity from the impacts of and International Sites policies. lighting (SD9 part b) and para 5.61 should be incorporated into the policy wording rather than sitting in the supporting text where it holds far less weight. Consider that agricultural planning applications Health and safety would be an important are unlikely to be able to comply with this material consideration at planning application policy in its entirety and suggest that the policy stage. wording is amended to include scope for the installation of lighting where it can be demonstrated there is an essential health and safety requirement. Consider it should be more specific about This level of detail would not be appropriate where, and under what circumstances, for the Local Plan. Detailed guidance relating to rooflights, roof lanterns, conservatories with Dark Night Skies is being produced, as is a glass roofs, two-storey ‘barn style’ windows etc Design SPD which will provide more detail on will be allowed. They comment that with these matters. efficient double glazing and, in many rural situations no need for blinds & curtains for privacy, mitigation measures are unenforceable.

119

Policy SD10: The Open Coast

Reg 22 (1) (c) (iii) There were a total of 13 comments on this policy/chapter. These are summarised below. National Agencies Comments were received from 3 national agencies; Natural England, the Marine Management Organisation (MMO) both of which support the policy, the MMO with some changes; and Sport England that object to the policy as currently drafted due to the exclusion of reference to coastal sports facilities or activities in this policy or text. The MMO wish a dedicated National Policy Context for marine planning to be incorporated in the supporting text that makes specific reference to the Marine Policy Statement, of equal status to the NPPF as a statutory framework for marine planning. The have also proposed that Policy SD10 is amended to include reference to the South Marine Plan and MPS. Borough, City, County and District Councils Only Eastbourne Borough Council responded in this category fully supporting SD10 acknowledging the importance of The Heritage Coast (as the eastern gateway to the National Park) to the Economy of Eastbourne. Parish and Town Councils East Dean and Friston Parish Council PC supports the policy as drafted. Other Organisations Endorsement for the policy as drafted was received from: CPRE Sussex and British Canoeing. Qualified support was received from the following organisations: • Friends of the Earth Brighton the proviso being to either delete part 2 of SD10, or remove ‘unacceptable’ before ‘adverse impact’ in part 2; and • The Wildlife Trusts that recommend the policy is broadened out to include any MCZ off the National Park Coastline rather than simply Beachy Head West MCZ. Objections were received from the following organisations: • Southern Water policy that considers the current wording would create barriers to statutory utility providers, such as Southern Water, delivering essential infrastructure. It has proposed that para SD10 is amended to read: c) are necessary for the operational needs of coastal defence, agriculture, forestry or fishing enterprises or countryside management or utility providers. • The National Trust on the basis that the current wording in SD10.1b) fails to permit the replacement of existing visitor facilities of an appropriate scale, siting and design to respect their location within the National Park and within the Heritage Coast designation to ensure that the requirement within the NPPF of not just maintaining but improving access is achieved. The have proposed that the wording is amended to read: 1.b): “involve change of use or alterations or additions to buildings or the replacement of existing visitor facilities and associated infrastructure, or improvements that similarly conserve and enhance the character of Heritage Coast/ undeveloped coastline;”

120

Agents and Developers No responses were received from agents or developers. Individuals One individual commented on the policy stating that the coast also needs to be considered west to east as well as the specific part which intersects the SDNP. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Previous criteria relating to ‘coastal defence, agriculture, forestry or fishing enterprises or countryside management’ has been replaced with ‘activities in support of the heritage coast’ to encompass all appropriate activities that take place here, in line with comments from Sport England, Southern Water and National Trust;  New criteria 1a) has been added to the policy to make specific reference to the Beachy Head to Selsey Bill Shoreline Management Plan in response to the Marine Management Organisation’s comments;  Mention of the Marine Policy Statement as a statutory framework for marine planning has been included in the supporting text, as recommended by the Marine Management Organisation(MMO);  Friends of the Earth’s comments have been addressed by amending the wording of the criteria relating to Marine Conservation Zones (MCZ’s ) in the way they have suggested. The word ‘unacceptable’ has been removed and instead the policy says ‘cause no adverse impact’;  The policy refers to any MCZ in response to the Wildlife Trusts comments. Beachy Head West is still specifically mentioned in the supporting text as the intertidal section of this intersects with the Local Plan area. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason N/A N/A

121

Policy SD11: Historic Environment

Reg 22 (1) (c) (iii) There were a total of 32 comments on this policy. These are summarised below. National Agencies Historic England made a number comments:

 Welcomes and supports the policy in principle and consider it would fulfil the requirement of the NPPF for local plans to include a strategic policy to deliver the conservation and enhancement of the historic environment if either it or its supporting text set out proactive commitments from the Authority in addition to the reactive measures set out in the policy as currently drafted.  Note that the first criteria only relates to development proposals that realise opportunities to re-use redundant or under-used heritage assets - presumably other proposals that do not realise such opportunities (because they do not exist) will be considered against criteria 3 of the policy.  Criteria 2, 3 and 4 should refer to the significance of the heritage asset; "historic environment" would be better than "cultural heritage", "harm" better than "impact" and "substantial" better than "unacceptable" (terminology more consistent with the NPPF).  In criteria 2, development which affects listed buildings should also be determined with proper regard to the Authority's duties under the Planning (Listed Building and Conservation Areas) Act 1990;  Criteria 3 goes beyond the NPPF which considers that substantial harm to (or loss of) designated heritage assets will be wholly exceptional where those assets are higher grade.  Welcomes and supports paras 5.87 - 5.92, 5.97 – 5.106 but suggests a number of specific amendments to these paragraphs.  Pleased to see a number of references throughout the Local Plan to various aspects of the historic environment, although there are some places where we would like to see further recognition of the importance of the historic environment to the Park, particularly in respect of the Plan's consideration of ecosystem services, as identified in our other comments.  Aware that the Authority has been proactive with, for example, it’s commissioning of a survey of buildings at risk in the Park. Would like to see a commitment in the Plan to other proactive measures e.g. the maintenance of a rolling programme of Conservation Area reviews and character appraisals and the consideration of Article 4 directions where Conservation Areas are threatened by inappropriate permitted development.  The Plan does not set any approach specifically to heritage assets at risk. Appreciate that many are at risk from management rather than development issues, which are better addressed through the Partnership Management Plan, but there are still a number of assets with issues that could be addressed through the planning system. Therefore consider that the Plan currently does not adequately set out a positive strategy for the conservation and enjoyment, or a clear strategy for enhancing, the historic environment of the Park. However, consider that this deficiency can be easily rectified by incorporating their suggested amendments and additions.  It is not clear whether or not the Authority has considered whether any land should be specifically identified as being land where development would be inappropriate.

122

Borough, City, County and District Councils Lewes District Council are concerned that the wording of criteria 4 does not provide sufficient clarity about how a decision maker would weigh the public benefits of proposed works to a non- designated heritage asset against any unacceptable adverse impact of those works. They therefore consider that the policy fails to have proper regard to paragraph 154 of the NPPF. They note that in para 5.102 of the supporting text that, in addition to Adur and Eastbourne, Lewes District also has a list of buildings of local, visual or historic importance, which are identified in Appendix 2 of the adopted Lewes District Local Plan 2003 and are currently protected by ‘saved’ Policy H3. Chichester District Council made a number of comments:

 Consider that the Plan appears relatively weak in terms of policy on the historic environment and built heritage. The Plan is landscape-led and emphasises conservation of the natural environment. However the statutory purposes of national parks also require conservation and enhancement of the cultural heritage of the area.  Policies and references to the historic environment and built heritage appear rather fragmented. They Suggest reference in the strategic policy to a positive strategy for the conservation of the historic environment which could include reference to management of the historic environment, including Conservation Area appraisals, Heritage Risk strategies, Article 4 Directions etc.  Question the omission of a policy on listed buildings.  Question how the optimum viable use element of the policy to be tested. In most cases a developer will argue that the optimum viable use is a dwelling. Should residential uses be seen as the exception.  Suggest a number of specific amendments to supporting text and policy. East Hampshire District Council welcome and support the policy, but are concerned that the final part is not aligned with the NPPF. The Framework refers to ‘substantial public benefits’ being required to outweigh ‘substantial harm’ to a heritage asset not just non-designated heritage assets. They are supportive of the proposed preparation of an SPD and consider the continued preparation of CAA and management plans will be key to ensuring the significance of each area is understood. They recommend that heritage assets at risk should be specifically referred to in the supporting text, and in the policy. They suggest amending the supporting text to refer to the number of heritage assets at risk in the district, both on Historic England’s national register, and any listed buildings at risk on the local register. East Sussex County Council consider the Local Plan is generally strong on the historic environment and archaeology. In relation to the protection of non-designated heritage assets from loss or incremental change, they suggest that this can in part be achieved through support for the relevant Historic Environment Records where information about the historic environment, including non- designated heritage assets (including areas of archaeological interest/potential), is identified for use in the planning process. Wealden District Council note that throughout the document there is reference to ‘exceptional circumstances’; ‘very exceptional circumstances’ and ‘wholly exceptional circumstances’ but there is no clarification or guidance as to what these terms mean in the context of the policies they relate to such as Policy SD11and SD12. Suggest it may be beneficial to include signposts to legislation/guidance that covers these aspects, or to include definitions in the Local Plan document. Winchester District Council comment that given, the number and range of historic buildings and features within the National Park it is surprising that these policies (SD11, SD38, SD39, SD40 and SD41) are not more comprehensive and provide more guidance as to what is required of

123 development proposals. They note that there is no reference to historic parks and gardens and battlefields, given that cultural heritage values are one of the elements of ecosystem services, it is considered this oversight should be addressed in the next version of the Local Plan. Parish and Town Councils Arundel Town Council consider that the word “wholly” in criteria 3 is unnecessary emphasis and suggest deletion. Buriton Parish Council welcomes the policy. However, they would wish the National Park Authority to be 100% confident that all the Strategic Policies are sufficiently robust and practical to withstand the tests and rigours of Planning Appeals etc. The Parish Council is conscious that all these new policies are replacing some long-standing, tried-and-tested policies in the East Hampshire Local Plan and Joint Core Strategy. East Dean & Friston Parish Council comment that the policy is good, but concerned that the policy is dealing only with built assets and consider that farming and woodland landscapes should be considered an historical environment in locations shaped by such practices. Madehurst Parish Meeting consider it to be an important policy which they fully support and consider that it recognises the wider aspect of the historic landscape characteristics and historic assets which all create a special sense of place and really sums up the special qualities. Plumpton Parish Council question how the Local Plan will ensure the protection of heritage assets if this protection conflicts with the priorities/imperatives of another body, whether public or private. They also question what powers will the Plan have to enforce the protection and maintenance of heritage assets and consider that the words 'Will need to' does not suggest to us that SDNPA will have these powers. Selborne Parish Council comment that if Jane Austen is mentioned in para 5.88 then it should also mention Gilbert White and Selborne, and Lawrence Oates. Suggest that Criteria 3 and 4 "an unacceptable adverse impact" should be replaced by the words "cause harm". Other Organisations CPRE Hampshire are concerned about villages such as Steep, which has significant Arts and Crafts buildings, but has no conservation area and its character is relatively unprotected. They suggest addition text for criteria 2: “The impact of such proposals on the surrounding community and its historic character and environment will be taken fully into account in assessing such developments.”. They also comment that Criteria 1 needs to include ‘conserve and enhance the cultural heritage’ in accordance with the first purpose. CPRE Sussex support the policy. Friends of Lewes Society support the policy. Friends of the Earth Brighton & Hove support the policy, but suggest removal of ‘unacceptable’ before ‘adverse impact’ in criteria 3 and 4. Lancing College commented that the need to protect and enhance historic assets is noted and is supported, but equally the Local Plan must also acknowledge the direct management and financial implications this places on the custodians of such assets. Leconfield Estate commented that para 5.95 supports the conversion of listed buildings to a residential use where it would not compromise the significance of a heritage asset. They support this

124 level of flexibility and it is important that this is maintained to allow conversion of herniate assets to residential use in appropriate circumstances. The National Trust support the positive stance taken in criteria 1 of the Policy towards the re-use of redundant and under-used heritage assets as a means of securing their long-term conservation and enhancement and considers that this is fully in line with the guidance in the NPPF. They are concerned that criteria 3 of the Policy is not compliant with guidance in the NPPF at paragraphs 132 and 133. The significance of an asset and its setting should be clearly understood as part of development proposals and the impact of a proposal on this significance should be identified. The wording at criterion 3 does not reflect the approach and the Trust considers that the stance taken in this criteria does not reflect the guidance in terms of the impact of development on the significance of a heritage asset and when substantial harm or loss may be acceptable. Suggest bring the wording of criterion 3 in line with NPPF or if the NPA wishes to deviate from the guidance in para 133 that the “wholly exceptional circumstances” are quantified in the supporting text to demonstrate that the policy complies with the requirement in the NPPF for Local Plans to: “…provide a clear indication of how a decision maker should react to a development proposal should be included in the plan.” (para 154). Consider that without this adjustment the plan could not be considered sound. NFU South East Region has a general concern over definition of "optimum viable use" and how this will be assessed in planning applications. Applications brought forward through economic necessity or opportunity would be by definition 'optimal' to a developer/ landowner. They are concerned that this criteria could be used in an unnecessarily heavy handed manner if a proposal met with local opposition. Further clarification on the definition of optimum viable use would be advisable for the avoidance of doubt during plan implementation. The Petersfield Society is concerned that this policy does not adequately cover key buildings and open spaces in a village such as Steep which does not have a Conservation Area. Steep, has several listed and unlisted Arts and Crafts Buildings and the historic Bedales Estate. The policy needs to ensure that the character is conserved and enhanced. The developments such as new Bedales Tutor Buildings have already had an impact on the character of the village. Similarly incremental additions to key unlisted arts and crafts buildings can fail to take account of historic design. West Dean - The Edward James Foundation notes that Paragraph 5.95 supports the conversion of listed buildings to a residential use where it would not compromise the significance of a heritage asset. This level of flexibility is supported and it is important that it is maintained to allow the conversion of heritage assets to residential use in appropriate circumstances.

125

The Wiggenholt Association consider the policy on the historic environment is integral to the First Purpose of National Parks and to the 'special qualities' of the South Downs National Park and that there are serious problems with the policy and the thinking which underlies it. They made the following comments:

 Consider what was proposed to do in the Options Consultation relating to ‘designated heritage assets’ (identify those (assets) already at risk or vulnerable, exploit opportunities to secure their repair and enhancement, including the use of the Community Infrastucture Levy) marked the beginnings of a solution to the entrenched problem of buildings on the At Risk Register of English Heritage/Historic England where the owner refuses to carry out necessary repairs, often in the expectation of planning permission. This does not appear in the Preferred Options Document, the draft IDP or the CIL Updated and consider this a serious omission.  Consider that para 5.95 accepts too easily the difficult balance of residential conversion to the potential detriment of the first purpose.  The definition of ‘non-designated heritage assets’ is confusing. How does the identification of assets work, particular across multiple authorities. Consider criteria 4 to be based on a subjective test. Would like to see the whole area of heritage assets brought into clearer focus by the Local Plan, since cultural heritage is a critical justification for the formation and existence of National Parks. The South Downs Society support the policy. However, they note that a number of the draft policies make reference and “unacceptable adverse impact” and they see no reason to qualify “adverse impact” in this way. The aim of the plan should be to conserve and enhance the special qualities of the park and to include provisions for a degree of adverse impact is quite inappropriate and likely to engender unnecessary argument about the acceptability of various levels of damage. The same wording is adopted in other policies in the draft plan and should be amended. The South Downs Land Managers Group are pleased to see a positive approach to the re-use of redundant or under-used heritage assets, in particular support the wording ‘optimal viable use which secure long-term conservation’. They suggest an additional condition to SD11 enabling development proposals which would not otherwise be approved to be considered in the context of a whole estate/ farm plan. Agents and Developers There are no comments from agent and developers on the policy. Individuals One individual consider that the final part of the policy is out of step with the NPPF, which refers to ‘substantial public benefits’ being required to outweigh ‘substantial harm’ to a heritage asset not just non-designated heritage assets. They also question how the optimum viable use element of the policy will be tested, when in many cases it will be argued that residential use is the optimal viable use. Consider that residential use should be seen as the exception to the policy but should be specifically provided for. One individual supports the policy.

126

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Policy and supporting text structure and wording amended for clarity and consistency with other polices in the Local Plan and this captures many minor comments about wording. An example of a key change is the final ‘sting in the tail’ criteria (4) which is deleted to reduce unnecessary repetition of text elsewhere in the Local Plan – the Local Plan should be read as a whole.  Reference to significance of heritage assets is added to the policy and clarified further in the supporting text.  Listed Buildings policy now included in the Local Plan.  Key terms are further clarified in the supporting text or included within the glossary.  Further clarification in the supporting text regarding optimum viable use.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Concern that the policy only addressed the Disagree. The term heritage asset includes the historic built environment. built environment such as buildings and monuments, but also sites, areas and landscapes identified as having a degree of significance meriting consideration in planning decisions because of its heritage interest. Designed landscapes are considered to be most appropriately addressed in the Landscape Character policy. Insufficient protection of non-designated The policy applies to non-designated heritage heritage assets. assets.

127

Policy SD12: Biodiversity and Geodiversity

Reg 22 (1) (c) (iii) There were a total of 38 comments on this policy. These are summarised below. National Agencies The Environment Agency support this policy and are pleased to see specific reference to the need to have regard for ecological networks. They also support the need for development proposals to seek to both protect and enhance biodiversity. Natural England welcomes the policy and advises that it encompasses a robust consideration of biodiversity and geodiversity. They strongly support statement that a landscape-scale approach is needed to conserve restore and reconnect habitats across the National Park. The recommend the following amendments:

 Advise that the explanatory text mentions priority species listed under S41 of the NERC ACT 2006. Section 40 of the NERC Act 2006 places a general duty on all public authorities, including local planning authorities, to conserve and enhance biodiversity.  Protected species are a material consideration when considering planning applications and this should be referenced here. – see Natural England’s Standing advice for protected species  Advise that this policy has clear links to the benefits of ecosystems services and the mutual benefits of these policies. Furthermore the G.I framework which is currently being developed should also be referenced. Borough, City, County and District Councils Brighton & Hove City Council supports the references to the Brighton and Lewes Downs Biosphere and welcomes partnership working to contribute to the delivery of biodiversity improvements within the Biosphere and the South Downs Way Ahead Nature Improvement Area. Chichester District Council suggests that the supporting text needs to include definition of geodiversity. East Sussex County Council made the following comments:

 Para 5.115 - Coastal Vegetated Shingle is a better example of an irreplaceable habitat than Maritime Cliff and Slope (although it is recognised that these are just examples).  Para 5.126 - SNCIs are Local Wildlife Sites, therefore both do not need to be listed. Wealden District Council note that throughout the document there is reference to ‘exceptional circumstances’; ‘very exceptional circumstances’ and ‘wholly exceptional circumstances’ but there is no clarification or guidance as to what these terms mean in the context of the policies they relate to such as Policy SD11 and SD12. They suggest including signposts to legislation/guidance that covers these aspects, or to include definitions in the Local Plan document.

128

Parish and Town Councils Arundel Town Council made the following comments

 Figure 5.6 - “The Arun Valley” per se is not “a designated RAMSAR site”. Just one part of it is such a site.  Cross refer to para 5.136 and Figure 5.7.  Whilst criteria 3(i) and 3(ii) are fully acceptable on national and international grounds, criteria 3(iv) is unjustifiably restrictive, even more so than 3(i) and 3(ii). Criteria 3(iv) should be amended to mirror para 3(iii).  Delete criteria 4 to 7. Unnecessary emphasis. Bramshott and Liphook Parish Council are concerned about criteria 3 (i) (b) which refers to "overriding public interest why the proposal should nonetheless proceed". There needs to be robust requirements and evidence shown that members of the public have been clearly informed of the purposes, duty and policies of the National Park, and that public interest applies to public benefit and not to public support. Buriton Parish Council commented that the policy says little about Geodiversity whereas, in practice, it is the geology which shapes the entire National Park. Bury Parish Council supports the concept of the Core and Strategic Policies. They consider all to be important, but the Council particularly noted with broad approval those relating to Biodiversity and Geodiversity, among others, those listed above seem well designed to address Bury's needs and challenges. They suggest a greater degree of cross referencing in a future document between the policies and where they apply in specific regions. Duncton Parish Council support the protection given to the natural habitats within the SDNP, but are concerned over the protection of the sand escarpment in the Heath End Sand Quarry that has become an important breeding ground for Sand Martins. East Dean & Friston Parish Council comment that the predecessor to this policy has not served the parish council well. They consider that only requiring Ecological Impact Assessments if a development if a development is considered likely to have an adverse impact undermines the first purpose and declared emphasis on landscape and impact assessments should be mandatory, independent and of the highest calibre and should also apply to land impacting, by reason of its proximity or viewshed, on a special type of site listed in the hierarchy of designation. Elsted and Treyford Parish Council suggest that a policy for all development to incorporate bat habitats is included. Iford Parish Meeting support the policy. Lavant Parish Council question whether Biodiversity Opportunity Areas' (BOA) importance overridden by the SD12 or no longer relevant. They suggest reference to BOA’s under criteria 3 (iv). Liss Parish Council comment on need to define how “no alternative” will be assessed (criteria 3a) and ‘especially’ is not required in criteria 6 and weakens the policy since invasive plants by definition will be damaging. They also note that references to geodiversity appear lost. Madehurst Parish Meeting support the policy, but comment that it is particularly wide ranging and subsequently longer and more detailed than others. They comment that clear definition and supporting information may be required to avoid speculative development applications. They also note the hierarchy at each stage provides the ‘opt out clause ‘ of some type whilst we recognise for

129 major infrastructure projects there may be imperatives for proceeding we note that there is no clear guidance as to what this might be and so subjective analysis is likely. Similarly under local sites there is the potential for subjectivity around the demonstration of ‘no adverse impact’. This can be the cause of appeal and ongoing discussion around applications and would respectively suggest some level of guidance is included to avoid subjectivity at an early stage. They support criteria 3(iii) re irreplaceable habitats including Ancient Woodland and loss of aged or veteran trees outside Ancient Woodland. Rottingdean Parish Council support the extension of Beacon Hill Nature Reserve. Selborne Parish Council request that mention is made of the network of pre-Roman sunken lanes. There are 70 miles of these throughout the National Park and they support an unusual range of flora and fauna. Other Organisations The Alice Holt Community Forum made a number of comments including:

 Consider the policy to be too weak, which they consider surprising given the National Park designation and the sandford principle.  Criteria 3(i) - require the deletion of the words “or adequately mitigated”. If mitigation is adequate then it follows that there should be no “adverse effect”, so the words are redundant. If despite mitigation there is still an adverse effect, then the international treaties require that the development should be refused unless the three specified matters can be demonstrated.  Criteria 3 (ii) - words “or adequately mitigated” are redundant. Further paragraph 118 of the NPPF, second bullet point contains no reference to mitigation. If regardless of mitigation, there is an adverse effect, the starting point is that the development should be refused, unless there are exceptional circumstances, as specified in the NPPF.  Criteria 3(iii) - unnecessarily and inappropriately qualifies the statement providing for the refusal of permission for development resulting in the loss or deterioration of ancient woodland by the words found in the NPPF “unless the need for, and benefits of, the development in that location clearly outweigh the loss”. The qualification in the NPPF seriously detracts from the protection seemingly provided but the NPPF applies across the whole country, including undesignated countryside and built up areas and it may be thought to be appropriate to retain the qualification to those areas; but we are here dealing with a National Park where the Sandford Principle applies. Ancient Woodland in the South Downs National Park needs firmer protection in the Local Plan and the qualification should be removed. We note that criteria 3 (iv) and 7 of the Policy have no such qualification about “need or benefits outweighing loss”.  Criteria 7 - “mitigated or compensated for” should be deleted. If the mitigation is adequate, there should be no adverse effect. Compensation can never be adequate on its own. Compensation should only be relevant where it has been judged that exceptional circumstances apply which override the recognised harm. Brighton & Lewes Downs Biosphere comment that the correct name to use should be 'Brighton & Lewes Downs Biosphere Partnership' and marine chalk habitats should be added as a biodiversity focus for this too. CPRE Hampshire supports all these aims regarding biodiversity which are creditable and well expressed. However they consider that through the entire section and accompanying policy, geodiversity seems very much like the poor relation, rather as an afterthought. They comment that there seems to be some confusion as to how the two interrelate in terms of habitat, and it is

130 important to note that many of the designated biodiversity sites, such as heathland, could not exist without the fundamentals created by the underlying geology. They suggest that it might be better either to separate Geodiversity as a separate section, or to balance the weight of the arguments to be more even and Policy SD12 (or a separate one) should aim to protect the underlying geology across the Park, not just in designated sites, as well as the ecosystems that sit above it. CPRE Sussex supports the general thrust of the policy and welcomes the refusal of planning permission for development resulting in the loss or deterioration of irreplaceable habitats. They make reference to para 109 and feel that there is an opportunity to plan for a net gain in biodiversity through the planning system and that the Local Plan could do more to positively encourage this and identify land that could fulfil this need. They consider that the words "or adequately mitigated" in Criteria 3(i) needs to be deleted as they are not compatible with the Habitats Regulations (paras 61(5) and 102(4)), which require development proposals to be refused unless the SDNPA has "ascertained that it will not adversely affect the integrity of the European site”. Mitigation necessarily involves acceptance of some harm to an EU site's integrity and the regulations don't permit that (except where there is an overriding public interest). Friends of the Earth Brighton & Hove support the policy. NFU South East Region comment on concerns raised by their members relates to the substantial time delays associated with submitting, processing and delivering projects. Key amongst this is the delay caused by biodiversity considerations. They recognise the statutory underpinning that makes this policy a requirement but request that SDNPA make every effort to enable timely development through providing clear advice and signposting as part of your development management service. The RSPB strongly supports the policy and its commitment to conserving biodiversity and geodiversity. They particularly support criteria 2 and its encouragement of the creation ecological networks and restoration of habitats. South Downs Local Access Forum considers that there is a need to define in whose opinion there is ‘no alternative’ (criteria 3(a)) and the second half of sentence in criteria 6 “especially .. “ is not required and weakens the policy. Contradicts “invasive” description. Invasive plants by definition will be damaging. South Downs Society supports the policy. The South Downs Society support the tiered approach (avoid, mitigate, compensate) focusing on protected sites and encouraging the positive contribution to the protection, management and enhancement of biodiversity and geodiversity interest outside of protected sites.

131

Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trust (joint response) strongly support the inclusion of a biodiversity policy and made the following comments:

 Policy could strengthened to ensure clarity to applicants that ‘net gains’ to biodiversity will be required for all proposals as per NPPF paragraph 109. The ecosystem services and landscape driven approach running through the plan should not detract from this or the need to create a coherent ecological network. They recommend that the term ‘net gain’ is included in the wording of criteria 3 (v).  Should be recognition of the importance of Biodiversity Opportunity Areas (BOAs) in the policy wording. For example criteria 4 could be strengthened with a requirement to have regard for BOAs. This would be in line with the policy’s requirement to have ‘regard to ecological networks’ (criteria 2) and help to ensure that development contributes effectively to the creation of net gains to biodiversity.  Strongly support the level of protection given to local sites in the policy (part 3 (iv)). Local Wildlife Sites are an essential component in the creation of a coherent ecological network and must be conserved and enhanced in order to achieve the aims of the Government’s Biodiversity 2020 strategy and to conform to NPPF paragraphs 113 and 117.  Criteria 4 of the policy could be strengthened with the addition that the requirement to ‘ensure appropriate management’ is long-term or in perpetuity. The Woodland Trust would wish to see no loss of ancient woodland and they make general comments about value and conservation of Ancient Woodland. They consider that ancient woodland must be given absolute protection under the Local Plan and policy amended to say: “Development resulting in the loss of ancient woodland will not be permitted.” Agents and Developers Callstone Ltd agree with the general approach. However, they consider that this would need to be addressed on a site-by-site basis in order to allow developments to respond to their individual circumstances, and should incorporate appropriate design mitigation measures to ensure that the overall deliverability of development proposals on a site. Individuals One individual commented that Bio and Geodiversity should not be sacred totems. One individual comments that they do not support that aspect of the approach which states that if avoidance and mitigation are “unachievable, then the impact should be compensated for”. They consider that, given the first purpose of the National Park and the Sandford Principle, the right approach in many cases should be that the development should not proceed and this approach is not consistent with the provisions in the NPPF. One individual support the policy and approach. One individual comments on the need to link up with Integrated Coastal Zone management in adjacent areas such as the Manhood Peninsula (ICZM, CDC).

132

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Policy structure and wording amended for clarity, particularly with regard to key terminology, and consistency with other polices in the Local Plan (for example, the final ‘sting in the tail’ criteria is deleted), and to reduce unnecessary repetition of text elsewhere in the Local Plan – the Local Plan should be read as a whole.  Biodiversity Opportunity Areas and protected species are referenced in the policy which addresses assets ‘outside of designated sites’.  Reference to net gains for biodiversity is added to the policy.  Additional working to the supporting text requires a landscape and ecology management plan to be provided which includes mechanisms for management in the long term.  The role and importance of geodiversity is further clarified in the introduction and supporting text.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Request that mention is made of the network Addressed through the general principles of the of pre-Roman sunken lanes that support an policy and through policies relating to transport unusual range of flora and fauna. routes and highway design.

133

Policy SD13: International Sites

Reg 22 (1) (c) (iii) There were a total of 16 comments on this policy. These are summarised below. National Agencies Natural England fully support the approach taken within this policy to provide bespoke consideration for International wildlife sites and make the following comments:

 Strongly support the inclusion of a policy to consider the impacts of new development on the flightlines and foraging habitat of Barbastelle and Bechsteins bats. This is applicable to Ebernoe Common SAC, The Mens SAC and Singleton and Cocking Railway Tunnels SAC.  This policy provides a strategic approach to protecting key flightlines and foraging habitat for bats along with a suitable buffer to protect key habitat during construction and operation. Natural England fully supports this initiative and consider it demonstrates how the authority has carefully considered the impacts to these sites on a strategic scale. Advise that such an exemplar initiative will have additional benefits to wildlife on a landscape scale via the prevention of habitat fragmentation and climate change benefits for example.  Clear links should be made to the G.I framework which should also include this key habitat and ecosystems services also should be referenced here.  Para 5.134 cite specific requirements made for Duncton to Bignor Escarpment SAC. This should be amended to read Singleton and Cocking Railway Tunnels SAC as this policy refers to specific measures designed to protect the internationally protected bats which are utilising this site for hibernation.  Para 5.135 should remove reference to Duncton to Bignor Escarpment as this policy also pertains to Singleton and Cocking Railways Tunnels SAC.  Welcome the inclusion of bespoke policy regarding the Arun Valley SPA, Wealden Heaths Phase II SPA and the Solent Coast SPAs.  Suggest that Figure 5.7 should name all the international sites within the National Park for clarity. Borough, City, County and District Councils East Hampshire District Council made the following comments:

 EHDC are undertaking further work to determine the level of cumulative growth in housing that would not have a detrimental impact on the Wealden Heaths Phase II Special Protection Area (SPA) in consultation with Natural England. The initial work was undertaken for the Joint Core Strategy with Waverley Borough Council and the SDNPA.  Currently there is a limit of 30 net new dwellings (including Gypsy and Traveller pitches and plots) within 400m of the Wealden Heaths Phase II SPA for East Hampshire District (including the area that lies within the National Park) for the plan period to 2028 (see EHDC Local Plan: JCS Pre-Submission HRA Appendix 3). When this figure of 30 is reached no more net new dwellings will be allowed. The figure of 30 is fast approaching and there is a need to review the work that supported the JCS. It is important that the SDNPA monitor windfalls within the 400m SPA buffer in conjunction with EHDC and are a party to the updated work to meet the requirements of the Duty to Cooperate.  It is noted that the SDNPA’s Local Plan HRA relies on the Joint Core Strategy HRA in terms of the housing numbers tested. This approach is questioned for the reasons set out under their comments on Policy SD23

134

Horsham District Council welcomes the policy and note that the two key international sites (The Mens Woodland and the Arun Valley SPA) addressed in Horsham District Council’s HRA have been identified through the HRA work undertaken to support the Preferred Strategy. They note that a key legal requirement of HRA assessments is to ensure that the combination of impacts from a range of plans is considered. In light of the Planning Inspector’s decision to increase HDC’s housing requirement to 16,000 homes (800dpa) over the plan period to 2031 they suggest that the NPA may wish to review your HRA assessment to ensure that the impact of this additional housing figure and the in-combination impact is addressed if required. They are supportive of the bat foraging zone which is an approach HDC have also adopted although subject to more recent advice or studies from you may have undertaken and/or received from Natural England. They draw attention to a 2008 study on Barbastelle Bats which documents flight paths of over 10km from the Mens Woodland and into the SDNP, and suggest the NPA may wish to consider whether the 7km zone proposed is sufficient. They are unclear how the impact of water abstraction & quality on overwintering birds at the Arun Valley SPA is being addressed. We note there is another policy which addresses these points, but suggest further cross referencing between the two policies would help to make this point more explicit. Parish and Town Councils Arundel Town Council comment that the Arun Valley SPA is already a protected area for Bewick swans and no justification has been provided in support of criteria 2 which seeks to protect an even greater area in support of these swans. They consider this to be an unnecessary restriction and if there is a genuine need for a buffer zone, it should be restricted to just 1 km. Itchen Valley Parish Council request the addition of The River Itchen to Figure 5.7 as it has SAC status. Selborne Parish Council support the policy. Other Organisations The RSPB made a number of comments:

 They are seriously concerned that the Local Plan does not provide appropriate safeguards to protect the integrity of the Wealden Heaths Phase 2 SPA from the effects of increased recreational pressure and other ‘urban effects’ associated with new housing development. In the absence of a robust policy in respect of new housing, they consider that the Local Plan is unsound and inconsistent with the requirements of the Habitats Regulations. They recognise that this element of Policy SD13 is taken from the East Hampshire Joint Core Strategy, but the RSPB raised these concerns during the development of that Strategy.  For all other heathland SPAs in the south, it is recognised that it is not possible to mitigate urbanisation effects within 400m, and so all net new housing is excluded in this zone. It is difficult to see why people and pets would behave in a different way around the Wealden Heaths, and hence why a different approach should be taken here.  They recognises that the South Downs Local Plan does not allocate any housing within the 400m zone. However, windfall developments may be proposed, so the RSPB recommend amending the policy to make it clear that the effects of any net new housing in this zone could not be mitigated and so would not be supported.  Their view is that it is not possible to provide meaningful mitigation on a case by case basis within the 5km zone. The accepted approach to mitigation at other heathland SPAs is to put in place both suitable alternative natural greenspace (SANG) to divert residents away from the SPA, and provide wardens on the SPA. Neither of these approaches is viable for the types of relatively small developments likely in the National Park, as there is unlikely to be

135

space to provide a SANG and developer contributions to provide wardens in perpetuity would be prohibitively expensive. Therefore, the RSPB recommends amending the policy to put in place a strategic approach to mitigating recreational disturbance, whereby developers can pay into strategic SANGs and strategic access management. Friends of the Earth Brighton & Hove supports the policy. The Leconfield Estate consider that the requirements in criteria 1 regarding surveys are onerous and it is not clear that an appropriate evidence base has been used to inform this policy. They consider that In the majority of planning applications with the potential to impact on ecology would require ecological assessment and it is not clear why a specific policy requirement is required in this instance. The National Trust owns and manages part of the Singleton and Cocking SAC and a significant area around them north of Singleton. The Trust, in conjunction with the National Park Authority, has been undertaking further research into the bat activities that occurs at this SAC and would welcome discussion with the NPA as to how the conservation of the internationally important bat habitat can be achieved alongside the desire to complete the Centurion Way for pedestrians and cyclists to complete the link between Chichester and Midhurst. The Trust also considers that this further work that has been undertaken may enable the definition of a suitable buffer around the SAC, as has already been identified for The Mens and Ebernoe Common SACs. Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trust (joint response) support the inclusion of a policy on International Sites, but have a number of concerns:

 SACs supporting barbastelle and Bechstein’s bats (Strategic Policy SD13 part 1): Supporting text (paragraph 5.139) notes that there is an absence of information on bat flight lines and commuting distances from SACs into the surrounding countryside, which is essential habitat to support the populations. The supporting text correctly promotes the need for development likely to affect the bats populations to be assessed on a case-by-case basis. However Policy SD13 part 1 sets apparently arbitrary distance limits of 5km at Ebernoe SAC and 7km at The Mens SAC. This appears to contradict paragraph 5.139. Unless there is clear evidence to support the above cut-off distances, they suggest that a precautionary approach is taken. It is common practice for ecological assessments to screen for bat activity in the region of 20-30 km of a site designated for bats. They recommend that this is incorporated into Policy SD13 part 1 to be sure that significant populations of these Annex II bat species are properly safeguarded from negative impacts. This approach should also help to capture bat populations that occur on sites that have no statutory protection, but are functionally linked to SAC populations.  Arun Valley SPA (Strategic Policy SD13 part 2): The assessment of a sites for its suitability for a species such as Bewick’s swan is very subjective, and if it is only done on one date, or even over the course of one winter, the results could not be considered to be robust. They therefore recommend that this policy should require a minimum of three winters’ worth of survey work, as required by the SRMP for surveying sites where Dark-bellied Brent Geese may be present.  Wealden Heaths Phase II SPA (Strategic Policy SD13 part 3): The approach adopted for Wealden Heaths SPA to safeguard ground-nesting birds appears to be inconsistent with the approaches implemented for SPAs elsewhere in southern England to safeguard the same species (Dartford warbler, nightjar and woodlark). Consider that a consistent and strategic approach to mitigating recreational impacts on the Wealden Heaths should be adopted. This should include access management and monitoring measures aimed at addressing the in-combination effects of development on the SPA. The lack of a

136

strategic approach sends out a confusing message to developers; whereas the adoption of a strategic approach in the area would provide a clear method under which new housing could be delivered without impacts occurring on the SPA.  Solent Coast SPAs (Strategic Policy SD13 part 4): Suggest a number of specific amendments to the policy and supporting text. They also comment that the supporting text states that: ‘All new residential development within this zone of influence will be required to mitigate the negative impact.’ It is not legally compliant with the Habitats Directive to promote strategic measures to ‘mitigate the negative impact’ on a Natura 2000 site. The measures must be to avoid any impacts which are likely to have a significant adverse effect and thus may have a detrimental effect on the integrity of the site. To permit a negative impact is illegal unless the full extent of the Appropriate Assessment process, including the IROPI test, has been applied to the proposed plan or project which would give rise to the impact. It is important to use the term ‘avoid’, rather than ‘mitigate’ negative impacts in order to comply with the Habitats Directive and the UK implementing Regulations. The South Downs Society supports the policy. Upper Itchen Valley Society request that The Itchen Valley should be shown with a SAC designation on Figure 5.7. Agents and Developers There were no comments made by agents and developers on this policy. Individuals One individual suggests that the Medmerry site to the west of Selsey which would be due to become an SPA after 5 years of data has been collated and assessed and question whether Pagham Harbour not included within the zone of influence. They also question why 5km buffer for Ebernoe and 7km for the Mens. Suggest that buffer zone of 7kms across and outside the SDNP are established for international sites. They also comment that agricultural pollution comes off the SDNP affecting the Manhood Peninsula which currently has 3 internationally important wildlife sites and the Manhood Peninsula cannot deal with this without the active input of the SDNPA. One individual supports the policy and approach. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Map is revised to show all international sites  Policy is restructured and, in places, reworded, to provide greater clarity, particularly with regard to terminology.  The kilometre zones in relation to The Mens and Ebernoe Common SACs are amended to 9km and 7km respectively. This uses the third quartile distances travelled.

137

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Issue raised that the use of zones for The Mens The distances used reference those used in the and Ebernoe Common SACs are not HRA for the Local Plan and are based on appropriate and/or that a much bigger distance monitoring data for these SACs. They are should be used. essentially the average distances which radio- tracked bats travelled from each SAC. This has since been revised to use the third quartile distances travelled (see above). These distances are considered appropriate with regard to protecting the integrity of these sites and their bat populations. Protected bat species are also addressed through the Biodiversity and Geodiversity policy. Concerns raised about the effectiveness of the The position agreed with Natural England is approach to Wealden Heath Phase II SPA – that development proposals within 5km should particularly the application of the 400m (total be considered on a case-by-case basis through a permissions limited to 30 dwellings) and 5km project level HRA in the event that any (all application require project level HRA) development proposals come forward which zones. are sufficiently close and of sufficiently large scale that they will result in an adverse effect on their own. The East Hampshire JCS HRA has already concluded that no adverse effect will arise in combination based on current proposed housing levels. Comment that the Arun Valley SPA is already a The reason for this zone is set out in the protected area for Bewick swans and no Habitats Regulations Assessment. Due to the justification has been provided in support of highly mobile nature of waterfowl it is criteria 2 which seeks to protect an even inevitable that areas of habitat of crucial greater area in support of these swans. They importance to the maintenance of their consider this to be an unnecessary restriction populations are outside the physical limits of and if there is a genuine need for a buffer zone, the designated site for which they are an it should be restricted to just 1 km. interest feature. The 5km zone has been identified based on discussion with RSPB, WWT and NE. The Trust considers that further work undertaken on bat activities in the vicinity of Singleton and Cocking Tunnels SAC may enable the definition of a suitable buffer around the SAC, as has already been identified for The Mens and Ebernoe Common SACs. Concern that the assessment of site suitability It can be very easy to determine site suitability for Bewicks swan are too subjective and the – for example a site with hardstanding or policy should require a minimum of 3 winters heavily invaded by scrub or wasteland with of survey work. vegetation is very unlikely to be suitable and thus wouldn’t require a survey. The nature of the assessment and survey work would depend on the site.

138

Policy SD14: Green Infrastructure

Reg 22 (1) (c) (iii) There were a total of 31 comments on this policy. These are summarised below. National Agencies Detailed responses were received from two National Agencies, Natural England and Sport England and a response was received from the Environment Agency supporting the policy as worded. Natural England welcomed the policy but stressed the need for the GI Framework to be clearly referenced in the policy. This was a point echoed by a number of other respondents, specifically the Wildlife Trusts, Adur-Worthing Councils, ESCC and Horsham DC. Natural England (along with the Wildlife Trusts) emphasised the need to ensure that locations for recreational activities are not sited in areas which are already vulnerable to recreational impacts such as statutorily protected sites. It recommended that policy SD14 makes specific reference to the potential for recreational to impact on protected sites and policies SD12 and 13. Sport England object to the policy as currently worded as the current draft fails to adequately address provision, protection or enhancement of sports facilities in its current form and a robust and up‑to‑date assessment of the needs for open space, sports and recreation facilities and opportunities for new provision has not been made (para 73 of NPPF). The Local Plan needs to include policies relating to sport and helps to deliver healthy communities in accordance with NPPF. Borough, City, County and District Councils ESCC’s response focused on the GI Framework as mentioned above; HCC, was disappointed not to see a specific reference to providing a network of high quality experiences for adults with learning and physical disabilities. Public Rights of Way (PRoW) was a recurring theme in particular picked up by users groups of the network (see Other Organisations, below). Responses were received from 3 District Councils; Adur-Worthing, Horsham and Arundel. The former two stressed the need for the GI Framework to be more clearly referenced in the supporting text; Arundel DC considered paragraphs 2 and 3 of the policy provided unnecessary emphasis and could be deleted. Parish and Town Councils Bury and Selborne Parish Councils both expressed support for the policy as currently worded. Other Organisations West Sussex Local Access Forum has suggested that the policy would be improved by specific reference to PRoW as "green corridors”. The lack of profile afforded PRoW in the policy and supporting text was a recurring them in the responses with the British Horse Society making the same point about the value of PRoW as green corridors and the South Downs Local Access Forum recommending specific reference to PRoW as a means of linking greenspace. The Wildlife Trusts share NE views on the need to clearly reference the GI Framework and to differentiate between GI that is for recreation and that which is for nature conservation and also recommended an additional policy requirement for the long term sustainable management of green infrastructure. The South Downs Land Managers’ Group seeks a reference in the supporting text that the development of new green infrastructure projects needs to be progressed in consultation with the landowners. Friends of the Earth support the policy with a minor change; CPRE Friends of Lewes and the Wiggonholt Association all support the policy as currently worded.

139

Agents and Developers Green Village Investments support the policy, specifically using it as a basis for justifying the Bohunt Manor Development proposal. Individuals Comments from individuals were all broadly supportive and included individual requests to strengthen references to health and well-being benefits in the policy and supporting plan and maintain single track lanes as a means of joining green areas and PRoW. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The policy has been significantly restructured and, in places, reworded to provide greater clarity.  Sports and open space provision addressed in new policy  Reference to accessibility for all users incorporated into the policy  Reference to addressing potential user conflicts, between activities, and also between people and wildlife, is added.  Provision, protection or enhancement of sports facilities are addressed in the retitled Development Management Policy: Provision and Protection of Open Space, Sport and Recreational Facilities and Burial Grounds / Cemeteries.  Reference to inclusive multi user routes added.  Clarification on Public Rights of Way added to the supporting text.  Criteria added regarding future management.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Need for the GI Framework to be clearly The GI Framework is referenced in the referenced in the policy. introduction to this policy section. The criteria of the policy are in accordance with and correspond to the key principles of the GI Framework. Prior to the GI Framework being completed, it is not possible to make such specific references within the policy. Recommended that policy SD14 makes specific It is not considered appropriate for policies to reference to the potential for recreational to cross reference to other policies in the Local impact on protected sites and policies SD12 Plan – the Local Plan should be read as a whole. and 13

140

Policy SD15: Aquifers

Reg 22 (1) (c) (iii) There were a total of 19 comments on this policy. Eight of the comments received noted an omission in the policy to safeguard against development unsustainably depleting aquifers. All of the comments are summarised below. National Agencies Detailed responses were received from two National Agencies, the Environment Agency (EA) and Natural England (NE). The EA considered the policy very broad and lacking in the direction for developers and decision makers that was perhaps intended. Natural England advised that the policy is inconsistent with Water Framework Directive (WFD) duty to prevent pollution of groundwaters and recommended amendment to state that pollution to groundwater will be prevented. Borough, City, County and District Councils Only Brighton & Hove commented, simply stating for support for the policy, as worded. Parish and Town Councils Arundel Town Council expressed support for the policy as currently worded. East Dean & Friston Parish Council and Selborne Parish Council both provided responses related to the need to safeguard against development unsustainably depleting aquifers. Other Organisations The majority of comments received were from other organisations including: Alice Holt Community Forum; British Canoeing; CPRE; Friends of the Earth Brighton & Hove; South Downs Land Managers Group (SDLMG); all of which provided responses related to the need to safeguard against development unsustainably depleting aquifers with damaging effects on river quality and habitats. The SDLMG also suggested the inclusion of policy wording expressing support for the proposed development of agricultural reservoirs. Two water companies responded, as follows:

 Southern Water sought an amendment such that development proposals will safeguard ground water aquifers and surface water sources from contamination.  Portsmouth Water, in order to ensure that all of the risks to the aquifer and public water supply (including turbidity) are fully addressed, sought referral of any new development proposals which is located within a Source Protection Zone for a Portsmouth Water source for comment by staff at the earliest opportunity.

141

Agents and Developers No Agents, Landowners or Developers commented. Individuals One individual response was received that expressed support for the policy, as worded. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Polices SD15: Aquifers and SD16: Watercourses have been combined together to create one policy SD17: Protection of the Water Environment, with the wording of the policy and supporting text amended to provide greater clarity for developers and decision makers and to provide consistency with the rest of the Local Plan;  Reference has been made in the policy to water quality and quantity meeting the requirements of the European Water Directive Framework;  Additional policy criteria 2 and 3 have been added to protect the water quality of Groundwater Source Protection Zones (GSPZ) and to prevent pollution of these, in line with the comments from the Environment Agency and water companies. Additional supporting text has also been provided explaining the meaning of GSPZ’s and which areas in the National Park are affected;  Support for the provision of agricultural reservoirs to aid water management has also been included in the policy and supporting text as specifically requested by the SDLMG.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason N/A N/A

142

Policy SD16: Rivers and Watercourses

Reg 22 (1) (c) (iii) There were a total of 30 comments on this policy. These are summarised below. National Agencies The Environment Agency supported the policy. They suggest including reference to the Water Framework Directive and text relating to ground and surface water quality and quantity within the policy. Historic England support the policy and recognition of the importance of rivers. They suggest minor textural changes. Marine Management Organisation recommended including reference to the Marine Policy Statement, which is of equal status to the NPPF as a statutory framework for marine planning. They comment that the Marine Policy Statement and the forthcoming Marine Plans are directly relevant up to the tidal extent of estuaries and rivers Natural England welcome the policy but request that ditch systems and terrestrial wetlands are included. These could be addressed by calling them rivers, streams, winterbournes and water courses. They comment that there are no policies that promote natural processes and restoration of natural geomorphology in the river valleys and they propose additional policy wording to address the point. Borough, City, County and District Councils East Sussex County Council comment that there are 9 main rivers identified on the map but the text states there are 7. They also suggest broadening out the policy to include ordinary watercourses as it appears currently to focus on main rivers. Parish and Town Councils Bury, Selbourne and East Chiltington Parish Council support the policy. Selbourne Parish Council suggest including mention of water meadows and introducing wording to cover protection of the quantity of water in the rivers, chalk streams and watercourses. Liss Parish Council wish to see mention of pollution caused by soil erosion and agricultural activity. Arundel Town Council identify a small number of minor textural changes to make the policy more positively worded. Bramshott and Liphook Parish Council support the policy but wish to see it broadened to include other water bodies.

143

Other Organisations CPRE Hampshire, CPRE Sussex, Friends of Lewes, Friends of the Earth Brighton & Hove, South Downs Society, Sussex Wildlife Trust and Hampshire & Isle of Wight Wildlife Trust support the policy. CPRE Hampshire are concerned at a lack of focus on protection of aquifers and CPRE Sussex would like to see reference to increased water recycling. They note that this may require new connections through the National Park. British Canoeing agree with principle that developments shall not cause a loss of amenity and recreational public access to and along a waterway. They suggest that a slipway or landing stage may be incorporated into appropriate developments. They comment that the re-canalsing of the Rivers Arun, Ouse and the Rother should be viewed as restoration and not classified as new works. The NFU South East Region comment that paragraph 5.158 relates to existing navigable reaches where there are no private or disputed navigation rights. The South Downs Local Access Forum and Ricardo plc (South Downs Partnership Member) also raise the importance of access to and on waterways and the opportunity to restore them. The South Downs Local Access Forum notes that para 5.158 mentions re-canalisation & historical transport, but that this is not carried forward into the policy. NFU South East region recognise believe that many tidal stretches of watercourses have been heavily modified due to historic navigation and land drainage requirements and they consider greater emphasis should be paid towards retaining the economic value of rivers in providing passenger and goods access. They urge SDNPA not to overlook these economic uses of watercourse assets and they believe there is an economic justification for considering this option as the cost of restoring heavily modified stretches of watercourses to semi-natural conditions will be vast, unaffordable and would have extreme consequences for the value and productivity of farmland. Southern Water commented that paragraph 5.160 explains that there are future potential pollution pressures from urban and rural surface water run off and wastewater treatment works. They consider that this misrepresents the position with regard to wastewater treatment works (WTWs) because it is assumes that there is no spare capacity to accept additional flows. They also comment that it makes no reference to improvements that could be made to protect water quality objectives whilst at the same time treating greater volumes of flow. They make reference to the Water Cycle Study (evidence supporting the Preferred Options Local Plan), which demonstrated that (a) there is sufficient capacity in the environmental permits of all the WTWs serving anticipated development within the National Park, or (b) additional capacity could be provided. If volumes of incoming wastewater is expected to increase as a result of new development (above those that are currently permitted by environmental permits), Southern Water could apply to the Environment Agency for a new or amended permit and they anticipate that the Environment Agency would agree further permit headroom provided the overall pollution load is not increased. This approach would protect water quality objectives. Southern Water comment that paragraph 5.171 makes reference to storm discharges from the wastewater network but does not recognise that this would normally only occur during periods of wet weather and is part of the normal functioning of a combined sewerage system. The points in the network that release stormwater are consented by the Environment Agency and are permitted to in order to prevent properties becoming flooded. The environmental impact of these releases is limited because of the high level of dilution with surface water. They agree that new development has the potential to increase pressure on the sewerage system, if necessary infrastructure is not provided in parallel with the development. However, they comment

144 that they look to work with local planning authorities and developers so that necessary infrastructure is provided. They support efficiency measures in new and existing development and agree that this could theoretically reduce pressure on the sewerage system. However, they report that there is limited evidence that demonstrates a substantial effect in practice. They consider that removal of surface water that is currently allowed to discharge to the combined system would be more effective, as this could release capacity for increased foul water flows. This approach would require separate surface water drainage infrastructure and would need to be developed in partnership with other organisations that have responsibilities for surface water drainage. There may be opportunities for new development to contribute to this if it is a cost-effective option for the developer. In relation to the policy wording Southern Water are generally supportive but consider criterion e) should be amended to recognise that it is not always appropriate to require development proposals to incorporate measures to prevent pollution risks, if those measures would normally be delivered by a third party such as a statutory sewerage undertaker: The South Downs Land Managers Group raise the need to ensure that water availability is not diminished by development. This is especially important for livestock farmers for whom a plentiful supply of water is essential. They consider there is a need to consider the impact of climate change and comment that they hope that applications for agricultural reservoirs will be considered favourable and suggest the inclusion of further policy wording to that effect. Finally they note that river restoration might be funded through CIL. The National Trust consider that the inclusion of ‘other watercourses’ within the policy means that virtually every development proposals will have to comply with the policy. They question the evidence and ask that the term ‘watercourse’ be clarified. Agents and Developers No responses received. Individuals A Hampshire County Councillor supports the policy. They comment that the need to improve water quality does not just relate to fishing conditions and they would note that there is an opportunity to encourage leisure activities which do not effect water quality. A couple of comments are made on the quality of the map.

145

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Polices SD15: Aquifers and SD16: Watercourses have been combined together to create one policy SD17: Protection of the Water Environment as advised by the Environment Agency (EA). The structure of this section, wording of the policy and supporting text has been amended to provide greater clarity for developers and decision makers as well as to reduce repetition and to provide consistency with the rest of the Local Plan;  Reference has been made in the actual policy to water quality and quantity meeting the requirements of the European Water Directive Framework in line with the comments from the EA;  Old criterion 1.d) has been deleted and a new criterion 1.f) introduces the term seasonal variation, a key consideration in relation to abstraction from surface waters;  New criteria 2 has been introduced to stress the direct and indirect links between discharges from proposed development and the quality of water courses;  Southern Water’s comments relating to sources of pollution; misrepresentation of the position with regard to wastewater treatment works (WTWs) and limiting discharge of waste water have been addressed by creating a separate section in the supporting text on water quality and pollution that highlights the importance of protecting water quality and minimising pollution from urban and rural sources. The reference to waste water treatment works as a potential source of pollution has been removed. The importance of providing water efficiency measures and sustainable drainage measures in new development proposals to limit the amount water discharging to combined water and sewage systems and water courses has been retained and cross referenced to polices SD 48: Climate Change and the Sustainable Use of Resources and SD50:ustainable Drainage;  Reference to the Marine Policy Statement and the emerging South Marine Plan is included in the supporting text to Policy SD18: The Open Coast;  In response to Natural England’s comments, an additional criteria (b) has been added relating to enhancing the ability of water features to function through natural processes;  A new section on development proposals alongside waterways maximising opportunities for recreation, whilst ensuring biodiversity is conserved, has been provided in the supporting text in line with the comments from British Canoeing, the South Downs Local Access Forum and Ricardo plc;  Support for the provision of agricultural reservoirs to aid water management has also been included in the policy and supporting text as specifically requested by the SDLMG;  In response to the National Trust’s comments, the definition of what constitutes groundwater and surface water features has been clearly set out in the supporting text. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason NFU’s comments regarding watercourses that Over-elaboration on matters better explained historically have been modified for economic elsewhere e.g. PMP or background papers reasons and the expense and impacts on farmland of restoring these to semi natural conditions

146

Policy SD17: Flood Risk Management

Reg 22 (1) (c) (iii) There were a total of 24 comments on this policy. These are summarised below. National Agencies Detailed responses were received from two National Agencies, Environment Agency (EA) and Natural England (NE). The EA made specific comment in relation to Footnote 19 - requirements for when a site specific Flood Risk Assessment would be necessary; the inference is that the policy and supporting text could provide greater clarity for developers and the decision makers. NE suggested that solutions that work with natural processes should be promoted. Borough, City, County and District Councils East Sussex County Council (ESCC) and Hampshire County Council (HCC) responded; ESCC, consistent with the EA considered that the policy and supporting text needed to be clearer on the requirements for site-specific FRA. They suggested amendment to paragraph 5.176, as follows:

 For major developments, an FRA is likely to be required where there are known flood risks and critical drainage problems.  EA should be consulted within 20m of a Main River. For Ordinary Watercourses the LLFA should be contacted if any works to culvert or realign are anticipated, as planning permission does not mean that land drainage consent will be forthcoming. They also sought consideration of policies which would seek to reduce the surface water runoff for existing (brownfield) sites, including retrofitting Sustainable Drainage Systems (SuDs). HCC recommends that the policy is amended to reflect that flooding from all sources is a significant issue within the South Downs National Park. For example in Hampshire groundwater flooding can be extensive in the Hampshire chalk groups. It may be helpful to highlight examples of locations significantly affected by the different sources of flooding. The South Downs National Park Authority was advised to have regard to the Local Flood Risk Management Strategy. Comments were only received from 2 District Councils, Lewes and Chichester. Lewes District Council expressed support for the policy advising that reducing the district’s vulnerability to the flooding is therefore a key priority of the Council. Chichester District Council advised that Sequential testing may not be applicable for all scales of development.

147

Parish and Town Councils Comments were restricted to three councils. Selborne Parish Council and Arundel Town Council; both had comments solely in relation to paragraph 2 (which SDNPA officers are recommending is deleted). Cheriton Parish Council stated that flooding is a significant issue within the parish and sought support from SDNP to enhance flood maintenance. They suggested that the wording in paragraph 5.177 excluded development to enhance flood defences.

Other Organisations Responses were received from CPRE offices in Hampshire and Sussex and from Sussex and Hampshire & Isle of Wight Wildlife Trust. Their comments generally focus on the scope to improve and broaden the policy by making reference to the need to plan specifically for appropriate floodplain and opportunities for improved natural flood management. The Wildlife Trusts also sought the following changes:

 Strengthening of SD17 to address the impacts of climate change on flood risk, including opportunities to mitigate and adapt to impacts (NPPF paragraphs 94 and 100);  Reference is made in the policy to the need to take account of other relevant plans such as Surface Water Management Plans, River Basin Management Plans and Catchment Flood Management Plans.  The requirements in paragraph 5.179 should be reflected in policy to ensure the compliance of proposals.  Wording to encourage flood defences which adopt the principles of ecosystem services and have high regard for potential impacts on biodiversity; specifically an additional criterion to slot in between part 1 b) and part 1 c) as follows: ‘opportunities for improved natural flood management are identified and incorporated into development proposals’. British Canoeing stated that 1d i) should be changed to read: safe access and egress from the site; and the scope as an amenity for recreation as a second purpose. The Goodwood estate stated that landscape should feature alongside technical issues in consideration of flood risk management. The idea of allowing housing development up to the technical flood limit, for example, results in an inappropriate land use arrangement. Friends of the Earth Brighton & Hove commented solely in relation to paragraph 2 (which SDNPA officers are recommending is deleted). The South Downs Land Managers Group supports the policy as currently worded, in particular 1 b) and 1 c). Adur & Worthing Business Partnership wished to see reference made to EA flood defence schemes and the possibilities of compensatory habitat issues on schemes such as Adur tidal walls.

148

Agents and Developers There were no responses received from Agents and Developers. Individuals Comments were received from two individuals; one individual queried the need for including EA River Basin Management plans in the references. The other response expressed support for the policy as currently worded.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The policy on Flood Risk has now been moved to a new Local Plan chapter on Climate Change which encompasses policies SD48: Climate Change and the Sustainable Use of Resources, SD50: Sustainable Drainage and SD51: Renewable Energy. This reinforces the link between flooding and climate change as advised by the EA, CPRE and Wildlife Trusts and highlights the importance of this issue to the National Park. The connection between mitigating flooding through providing sustainable drainage systems which have multi- functional benefits has also been strengthened through this restructure;  The supporting text has been amended to provide greater clarity for developers and decision makers regarding when SFRAs are required and provides further information on NPPF tests, flood risks, mitigation in line with the EA’s and Lead Local Flood Authorities (LLFA’s) comments;  In response to Hampshire County Council’s comments to set out examples of locations significantly affected by the different sources of flooding; a brief introductory context on the type and location of flooding found in the SDNP has been provided, which draws on the key messages set out in the Strategic Flood Risk Assessment (SFRA);  The issue of Natural Flood Management is addressed through policy SD50: Sustainable Drainage and SD17: Protection of the Water Environment which seeks to ensure that surface water features are able to function through natural processes;  An additional policy criteria 1.c) has been added in response to comments of the CPRE, Wildlife Trusts and Goodwood estate. This seeks to ensure that the design of flood protection measures are appropriate to the degree of flood risk, the development site and adjoining areas;  A new criteria (3) has been added to the policy relating to proposed flood protection measures being supported by appropriate management and funding for maintenance in perpetuity;  A specific section has been created in the supporting text to highlight the importance of ‘Working with Others.’ This refers to the EA’s and Lead Local Flood Authorities (LLFA’s) management strategies and plans.

149

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Reference to creating opportunities for natural This is issue is addressed in SD:50 Sustainable flood management drainage and SD green Infrastructure British Canoeing’s comment regarding This issue has been addressed in Policy providing opportunities for recreation SD17:Protection of the Water Environment EA flood defence schemes and the possibilities This is issue is a specific matter for the EA and of compensatory habitat issues on schemes not for the SDNPA such as Adur tidal walls

150

Chapter 6: People Connected with Places

Policy SD18: Transport and Accessibility

Reg 22 (1) (c) (iii) There were a total of 81 comments on this policy. These are summarised below. National Agencies Historic England welcomed and supported the identification of the historic rural road network as a heritage asset, and proposed that this should include historic roads in market towns. Borough, City, County and District Councils Brighton & Hove City Council supported the safeguarding of the Lewes-Uckfield railway route, and asked for more reference to improving bus services and that transport assessments/travel plans should be jointly approved by the SDNPA and LHA. East Sussex County Council requested several changes of emphasis in the supporting text, and for the inclusion of reference to potential developments at Gatwick Airport. Hampshire County Council requested that we identify funding sources for improvements; consider the impacts of through traffic on the National Park; make more reference to LHA strategic documents; include policy text to take more account of cumulative impacts; map historic rural roads; and commit to working with HCC on a strategic countryside access network. West Sussex County Council requested that reference to following the principles of Roads in the South Downs be followed by the words ‘where appropriate’, and that we clarify the meaning of ‘major development’ in criterion 4a. Chichester District Council said that the policy should refer to encouraging zero/low emission transport. They also supported the identification of historic rural roads as heritage assets; and asked for this to be expanded to roads in market towns. East Hants District Council asked us to further define the meaning and location of historic rural roads. Horsham District Council would welcome further discussions on the potential impacts of cross park traffic between points outside the National Park. They also asked us to consider the impacts that protecting historic rural roads will have on alternative routes outside the Park (including Storrington AQMA). Parish and Town Councils Several parish and town councils expressed support for the policy on historic rural roads; others asked for it to be strengthened or expanded: - To refer specifically to sunken lanes - To require developers to protect and where possible enhance safety Twyford Parish Council requested further clarification and precision from this part of the policy; and proposed that the threshold be raised to 10 dwellings. Arundel Town Council also asked for the threshold to be raised.

151

We were asked to define the word ‘significant’ in criterion 1 of the policy. The improvement of public transport was supported. Other proposals included the addition of criteria/text on: - The protection of settlements in the NP from the traffic impacts of developments outside the boundary. - The protection of views from transport routes, including by hedgerow management and preventing ribbon development. - More detail and consideration of how to improve gateways to the National Park. - A proposed new car park and walkway in Midhurst Other issues raised included: - Speed limits: a blanket 50mph limit or a 20mph limit where there are no streetlights/pavements. - A strategy on inconsiderate behaviour by different road users - Liaison with Sat Nav providers on routing traffic through historic villages Other Organisations Many organisations- including those focussed on recreational uses, local amenity groups, and broader countryside groups- stated their support for the policy on historic rural roads, and expressed their views on the threats posed to the landscape and recreational value of such roads by increased traffic volumes. Changes proposed to this criterion included: - Request for a broad definition of historic rural roads; for the policy to cover all sizes of development; and for similar principles to apply to urban roads. - Definition of historic rural roads to include non-motorised routes and ‘lost ways’ - Requiring developer contributions towards passing places - Requiring developers to repair damage to historic rural roads caused by construction traffic - Preventing ‘improvements’ to historic rural roads to increase their capacity or speed - Not relying on car sharing or bus services as part of site specific travel plans or transport assessments. - Two requests to raise the threshold for the Design and Access Statement for agricultural developments, be more flexible about seeking temporary status for planning permissions in such cases, and specify that this does not apply to permitted developments. - Two requests for more allowance for traffic increases at existing rural tourist attractions, subject to certain proposed criteria. The references to Roads in the South Downs and to the NPPF requirement on rights of way were supported. We were asked to give a quantitative definition of the word ‘significant’ in criterion 1 of the policy. Comments were received from estates both supporting and opposing potential additions to the A27.

152

Other proposals included the addition of criteria/text on: - A potential Mid Lavant Relief Road - Hubs and gateways and their capacity; the potential of bus stations close to the boundary - More reference to cycling for utility purposes - The exact location of the proposed Lewes-Uckfield railway - Carriage drivers and their needs - Construction traffic, including vehicle size - Sport cycling - More on focussing development in centres served by public transport - Reference in policy to the strong presumption against road building - Requiring transport improvements to incorporate green infrastructure, biodiversity gains and the green retrofitting of existing roads - Relationships between different settlements - Changing vehicle ownership models - Water access for recreation - The economic importance of sustainable transport; relationship with devolution proposals Agents and Developers More detail was requested on the requirement for Design and Access statements. The damage done to sunken lanes by agricultural equipment, whose numbers are largely outside planning control, was raised. One developer supported the policy, claiming that their proposed development was in line with it. Clarity was requested on which branch of the Lewes-Uckfield railway is to be safeguarded. Individuals Two individuals expressed support for the criterion on historic rural roads. Clarification was requested on which branch of the Lewes-Uckfield railway will be safeguarded. The damage done to sunken lanes by agricultural equipment, buses and commercial vehicles was raised. One respondent expressed general opposition to encouraging recreational access. Other proposals included the addition of criteria/text on: - Encouraging cross park traffic onto the strategic road network / public transport and discouraging it from using smaller roads. - Local community buses that can serve both residents and businesses. - Preferential parking and charging points for electric vehicles - Carriage drivers and their needs - More emphasis on horse riding and its contribution to the rural economy - Green bridges for wildlife across roads and other barriers

153

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The request for more emphasis on focussing development in centres served by public transport has been addressed by what are now Criterion 1 and 2 of the policy, where more reference to sustainable modes of transport and public transport routes has been inserted.  The request for a definition of ‘significant’ in relation to vehicle movements has been addressed by paragraph 6.8, which refers to the thresholds for transport work set out in local highway authority guidance. The phrase ‘major development’ in relation to transport assessments/travel plans has been removed.  A request was made to qualify the reference to ‘Roads in the South Downs’. This reference has now been removed from the policy, to avoid duplication with policy SD21.  More reference to improving bus services was requested. There is limited scope to achieve this through planning policy, on top of what was previously proposed, but the text of what is now criterion 4 has been amended from ‘permitting’ to ‘supporting’ improvements to public transport facilities.  More detail and consideration on hubs and gateways has been incorporated, as requested, by broadening the references to transport interchanges in the policy. Significant new information on hubs and gateways has also been included in Chapter 3: Spatial Portrait and Spatial Strategy and in Appendix 1: Broad Areas and Rivers Corridors.  The widespread support for the policy on historic rural roads is welcomed. This topic area has been moved into Strategic Policy SD21: Public Realm and Highway Design. In response to consultation requests, the definition of such roads has been clarified in paragraph 6.27, and additional precision on how the policy will be applied is included in paragraphs 6.28-6.31, inclulding a requirement to consider cumulative impacts. Paragraph 6.31 addresses the impact of agricultural vehicles on historic rural roads, and how this policy would deal with agricultural developments, as raised by some comments.  A reference to the role of local highway authorities in agreeing Transport Assessments, Transport Statements and Travel Plans has been included in paragraph 6.9. It has not been considered appropriate to give local highway authorities an absolute veto over applications involving such documents but it is anticipated that their recommendations would be followed in the great majority of cases.  In response to comments, the safeguarding of the Lewes-Uckfield railway line now specifies that it is the original course which is safeguarded (i.e. that which joins the main line at Hamsey). This is also reflected on the policies map.

154

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Request for the definition of ‘historic rural Roads in market towns, while often valuable roads’ to be expanded to roads in market and important in landscape terms, by definition towns. cannot be described as historic rural roads and the vast majority are very different in character from the historic rural roads which are a distinctive feature of the South Downs National Park. Request that the threshold for applying the Given the rarity of windfall development sites historic rural roads tests be raised (to 10 over 10 dwellings in the National Park, in dwellings) particular outside the market towns, applying a threshold of 10 dwellings to this policy would severely limit its usefulness. Map historic rural roads Mapping historic rural roads would be a disproportionate use of resources given that maps showing these roads already exist for public view. Request that the threshold for applying the Requiring a study of the traffic impacts on historic rural roads tests be lowered to cover every development, including extensions, all sizes of development conservatories, etc, would be a disproportionately onerous requirement on developers. Definition of historic rural roads to include If non-motorised routes were included in the non-motorised routes and ‘lost ways’ definition it would be hard to draw a line and exclude, for example, footpaths. The amenity of non-motorised routes is covered by policy SD20 criterion 6. The investigation of lost ways is beyond the scope or resources of the Local Plan but may be a useful project for a community led plan. Requiring developer contributions towards Passing places are a method of increasing road passing places capacity that can cause the loss of existing verges and banks. A blanket encouragement for them would therefore be inappropriate, though they may be suitable in some situations. Not relying on car sharing or bus services as It would not be appropriate to rule out whole part of site specific travel plans or transport categories of solutions in the Local Plan; for assessments. example, while reliance on bus services would be inappropriate in some locations, there are other parts of the National Park that have a good bus service, which should be reflected in travel plans for developments in that area. Requiring developers to repair damage to Such a requirement would be a consequence of historic rural roads caused by construction proper application of the policy but this level of traffic detail in policy should not be necessary. Preventing ‘improvements’ to historic rural The policy approach is focussed on the roads to increase their capacity or speed protection and enhancement of National Park special qualities, rather than a blanket ban on

155

capacity increases which may be appropriate in some circumstances. Two requests for more allowance for traffic The policy does allow for traffic increases in increases at existing rural tourist attractions, principle, provided they do not reduce the subject to certain proposed criteria. biodiversity, landscape and amenity value and character of historic rural roads. Make more reference to LHA strategic Due to space constraints, reference to evidence documents base documents is limited in the Local Plan, however, these documents are referred to in the Transport Background Paper. Consideration of the impacts of traffic arising Await conclusions of HRA. outside the National Park Make reference to construction traffic, Construction traffic falls under the definition of including vehicle size traffic generated by development, and does not require separate treatment in the Local Plan. Policy should consider changing vehicle The NPA is not currently aware of any firm ownership models projections on vehicle ownership models, on which such a policy could be based, other than the TEMPRO data underlying the Local Plan Transport Assessment which is based on long term past trends. Alternative vehicle ownership models could well lead to reduced traffic levels, so the use of traffic projections based on past trends represents a more robust, precautionary approach. Commit to working with HCC on a strategic The National Park Authority works closely with countryside access network HCC on strategic countryside access, and projects for the improvement of this network are in the Infrastructure Delivery Plan. However, given constraints of space, a Local Plan policy is not the appropriate place to state this commitment. Inclusion of reference to potential Any developments which may take place at developments at Gatwick Airport Gatwick Airport would have only an indirect impact on the National Park, and would not have direct implications for the development of land in the National Park, which this Local Plan is concerned with. Supporting and opposing potential additions to Given national policy on road development in the A27 National Parks, it would not be appropriate to allocate land for works to the A27 in the Local Plan. Any such proposals will be dealt with by the SDNPA in accordance with the A27 Position Statement (2014) or its successor, as set out in the guidance. A potential Mid Lavant Relief Road This project would be inconsistent with both national and local policy. Identify funding sources for improvements Given the current financial climate, no specific improvements are proposed through the policy, which is intended to facilitate

156

improvements as and when funding may become available for them. A proposed new car park and walkway in The Local Plan specifically does not allocate Midhurst sites for new car parking. The proposed walkway would make little sense without the proposed car park. A blanket 50mph limit or a 20mph limit where The Local Plan cannot set requirements for there are no streetlights/pavements. speed limits. Policy SD21 requires new developments to comply with the Roads in the South Downs guidance document, one of the aims of which is to reduce traffic speeds through good design. Refer to encouraging zero/low emission Electric vehicles are encouraged through policy transport. SD22: Parking Provision. A strategy on inconsiderate behaviour by The Local Plan cannot set requirements for different road users driver behaviour. Policy SD21 requires new developments to comply with the Roads in the South Downs guidance document, one of the aims of which is to induce more considerate behaviour from road users through good design. Liaison with Sat Nav providers on routing This is not a matter for the Local Plan, though traffic through historic villages enforcement of travel plans (as required by SD19) can have a positive impact on this issue. Make specific reference to carriage drivers and Carriage drivers, like other users of roads and their needs the Rights of Way network, will benefit from the protections for those features in policies SD19-SD21, but it is not considered appropriate to increase the proportion of routes they share with walkers, cyclists and horse-riders. Make specific reference to sport cycling Sport cycling would be treated as a form of cycling for recreation, and would be likely to benefit from the policies in SD19 and SD20 aimed at catering to cyclists. Make specific reference to relationships The relationships between different between different settlements settlements are considered by the Settlement Facilities Assessment, which informed the selection of which settlements are considered in principle suitable for a certain level of development in Policy SD25. Make specific reference to water access for Waterways have many functions other than recreation transport, so access along them for recreation is covered as just one part of Policy SD17: Protection of the Water Environment. The exception is the Wey and Arun Canal, whose route is safeguarded by policy SD20 for potential future restoration. Make specific reference to the economic The policies attempt to reflect the economic importance of sustainable transport; importance of sustainable transport, especially relationship with devolution proposals by the increased consideration of cycle commuting. Devolution proposals in the area

157

are not yet at a sufficiently advanced stage to incorporate into the Local Plan. Requiring transport improvements to The effect of transport improvements (where incorporate green infrastructure, biodiversity covered by the planning system) on biodiversity gains and the green retrofitting of existing would be covered by Policies SD2: Ecosystem roads Services and SD9: Biodiversity and Geodiversity.

158

Policy SD19: Walking, Cycling and Equestrian Routes

Reg 22 (1) (c) (iii) There were a total of 56 comments on this policy. These are summarised below. National Agencies Network Rail raised the issue of safety at level crossings, the LPA’s duty to work with NR on this issue, and their plans to close level crossings. They requested the insertion of text requiring S106 contributions to safety improvements where development affects a level crossing. Natural England requested a revision to the policy in line with the Habitat Regulations Assessment, to safeguard Singleton and Cocking Tunnels. Borough, City, County and District Councils Brighton & Hove City Council requested that criterion 4 be expanded to apply to all types of development, and that theER,FR0=[-PR ROWIPs and the insertion of text from their own. Adur and Worthing Council suggested that we could use CIL to improve access across the A27, and requested that we identify opportunities for this. Winchester City Council supported the concept of safeguarding the two former railway lines identified in their district, but questioned the deliverability of the proposals. Chichester District Council said that the proposals for new routes connecting to the Centurions Way would also link up with their routes in the south of the district. Parish and Town Councils West Meon Parish Council support the retention and safeguarding of the Meon Valley Line as a non- motorised transport corridor. Liss Parish Council proposed that the Longmoor Railway between Liss and Bordon be added to the list of safeguarded routes. Warnford Parish Council requested that criterion 5 should mention Unclassified Country Roads. Arundel Parish Council proposed that criterion 4 should not apply to single buildings, and criterion 5 be phrased more positively. There were two requests to add references to additional promoted routes in the supporting text Two parish councils offered general support There was a request to replace the words ‘unacceptable adverse impact’ in the last criterion with ‘harm’.

159

Other Organisations There are several statements of support for the policy in general Safeguarding land for non-motorised multi-user routes: The extension of the Centurion Way was supported by two respondents. One other proposed an off-road path from Hamsey to the Jubilee path from Ditchling. There was a request for the NPA to identify funding for these routes. One respondent stated that they should provide for the different surfaces needed by cyclists and equestrians. Crossing points on strategic infrastructure: General support was expressed, as well as a desire for more emphasis on crossings of north-south routes and across the northern boundary of the National Park. There was a request for reference to improving existing crossing points Other responses included requests for:

 Limitation of the erection of height barriers at car parks, and reference to the forthcoming NPA best practice document on this issue  Prevention of cyclists using footpaths  Reference to carriage drivers and their needs  Reference to restricted byways  More focus on utility cycling, not just cycling for leisure.  Removal of the words ‘wherever possible’ and ‘unacceptable’  Ensuring cycle network signage is locally distinctive  Minor additions to supporting text Agents and Developers The agent for the owner of land lying across the former Midhurst-Chichester railway line stated that allocating that site for sixty houses would enable the conversion of that part of the line to a PROW. Individuals There was a proposal for an off-road path along the Lewes-Ditchling road, suitable for horseriders and ramblers. Support was expressed for the safeguarding of disused railway lines for multi-user routes. One respondent urged the Meon Valley Trail re-surfacing work not to be replicated elsewhere, and soft-surfaced bridleways to be at least partly protected as such, as heritage assets and for their value to horse-riders. Others urged the NPA to consider the inevitable conflicts between horse, bicycle, and pedestrian; and to consider giving farmers grants to maintain public rights of way. Three respondents raised the importance of lanes connecting the Downs with villages outside the Park boundary to horse riders: there were proposals that these be designated as Local Green Spaces, maintained with minimal traffic and no new dogleg style crossing points, and that if new development is allowed in exceptional circumstances to disrupt this access, it should provide parking spaces for horse boxes on the side facing the Downs/ Pegasus crossings.

160

There were requests to:

 Identify new horse box parking sites, between the Downs and the B2116. Sites for horse box parking should not be accessed along steep winding roads.  Protect existing car parks from height barriers.  Improve road signage where bridle paths cross; better management of gates  Encourage the conversion of stiles to kissing gates, potentially by paying landowners where appropriate.  Refer to carriage drivers and their needs (provides for people with limited mobility): promote circular routes to restricted byway status and ensure they have suitable parking for horse transport.  Consider the economic importance of horse riding to rural areas.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Requests relating to horse box parking and site barriers at car parks have been addressed through a change to what is now Policy SD22: Parking Provision, with the new criterion 4b which reads ‘All new public parking provision will… where located with good accessibility to the bridleway network, include provision for horse box parking’.  After further discussions with Natural England, wording has been inserted into the supporting text (paragraph 6.18) to make clear that development of a recreational transport route within the Singleton and Cocking Tunnels SAC will not be permitted; this is reflected on the safeguarded route shown on the Policies Map.  The widespread support for the safeguarding of former railway lines for non-motorised travel routes is welcomed. While funds may not be immediately available for the development of non-motorised travel routes, it is legitimate to safeguard the relevant land so it remains suitable for such development in future.

 At the request of one respondent, the route of the former Longmoor Railway has been added to the list of safeguarded routes. However, the section of this railway from Longmoor northward is considered in principle unsuitable for a non-motorised travel route due to wildlife and military constraints, so only the southern section is safeguarded.  There were two requests to add references to additional promoted routes in the supporting text  In response to the issues raised by Network Rail, what is now SD20 criterion 4 has been rephrased to include the enhancement (as well as protection) of existing crossings across major roads, railways, and watercourses, and support for proposals to upgrade the safety of such crossings. It is considered that this would provide an adequate lever for the extraction of development contributions where necessary.  Arundel Parish Council proposed that criterion 5 be phrased more positively. Another respondent proposed to remove the qualification ‘wherever possible’ from the criterion. These changes have both been carried out (also being in line with the revised policy writing principles).  Objections were made to the phrase ‘unacceptable adverse impact’ in Criterion 5, as allowing for some level of harm. This criterion has been re-written and now excludes that phrase, instead saying ‘…proposals will be permitted provided that they… conserve and enhance…’

161

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason More focus on utility cycling, not just cycling for More emphasis on utility cycling has been leisure. incorporated into the Transport topic paper; however, in general it is considered the policy is already designed to facilitate utility cycling, in particular through the safeguarding of off road routes connecting towns in and around the National Park. Ensuring cycle network signage is locally This is already addressed through the mention distinctive of ‘appropriate signage’ in Criterion 1, and through Policy SD21: Public Realm, Highway Design and Public Art. Consider the economic importance of horse The policy in general already reflects the riding to rural areas. importance of horse-riding to rural areas. More on this has been inserted into the Transport topic paper. Carriage drivers and their needs Carriage drivers, like other users of roads and the Rights of Way network, will benefit from the protections for those features in policies SD19-SD21, but it is not considered appropriate to increase the proportion of routes they share with walkers, cyclists and horse-riders. Encourage the conversion of stiles to kissing This is not a matter for planning policy, gates, potentially by paying landowners where although there are several rights of way appropriate. Better management of gates. improvement projects included on the Infrastructure Development Plan. Propose an off-road path from Hamsey to the The route of a potential path from Jubilee path from Ditchling or along the Lewes- Lewes/Hamsey to Ditchling is unclear and Ditchling road, suitable for horseriders and therefore cannot be safeguarded through ramblers. planning policy at present. Requests that safeguarded non-motorised This would be too much detail to include in the travel routes provide for the different surfaces policy. The policy has been changed to also needed by cyclists and equestrians. safeguard the existing use of these routes (where it exists) as non-motorised travel routes, and permit developments which facilitate such existing use. The agent for the owner of land lying across Housing sites will not be allocated in otherwise the former Midhurst-Chichester railway line unsuitable locations, simply in order to deliver stated that allocating that site for sixty houses non-motorised travel routes. would enable the conversion of that part of the line to a PROW. Adur and Worthing Council suggested that we The policy would facilitate the use of CIL to could use CIL to improve access across the improves access by sustainable means across A27, and requested that we identify the A27. However, the required evidence base opportunities for this. does not yet exist to allocate specific sites for such crossings, and we would not wish to restrict any windfall opportunities for such crossings which may come forward over the plan period.

162

Arundel Parish Council proposed that criterion Disagree; all development that generates 4 should not apply to single buildings footfall should be linked to the public rights of way and/or local footway network. Requests that criterion 5 should mention The majority of unclassified roads in the Unclassified Country Roads, or that various countryside are likely to be covered by Policy protections should be applied to lanes leading SD21 Criterion 2 (on historic rural roads), which towards the Downs. similarly protects landscape and amenity value. Prevention of cyclists using footpaths This is not a matter for planning policy.

A reference to restricted byways was No need is seen to make special reference to requested these routes, as opposed to the numerous references to the broader public rights of way network.

163

Policy SD20: Sustainable Tourism and the Visitor Economy

Reg 22 (1) (c) (iii) There were a total of 56 comments on this policy. These are summarised below. National Agencies Historic England suggests the addition of "historical significance" in criteria 1 (a) iii) between ‘character’ and ‘appearance’. Natural England comment that it is not clear how this policy has considered impacts on statutorily protected wildlife sites as no locations for example have been included here. They advise that this is amended. Borough, City, County and District Councils Chichester District Council recommend that there is further clarification relating to marketing requirements and demonstration of lack of viability (see Appendix E of the Chichester Local Plan for example). They also suggest that in order to determine when the benefits of tourism outweigh the risks, the Local Plan should set out a monitoring framework with appropriate triggers, including those related to the things that attract tourists. They also consider that the Local Plan should set out links and relationships with tourism in areas outside but close to the National Park, especially related to attractions accommodation and transport. East Hampshire District Council welcomes the commitment SDNPA have made to work with local authorities to support the visitor economy in and around the National Park. They also welcome the commitment to an enabling and flexible approach to tourism related development that fits with National Park purposes and does not harm the special qualities. They note there is a reference in para 6.34 to a gap in hotel provision in Petersfield and would recommend that suitable sites should be identified for a town centre hotel. They welcomes and supports the retention of visitor accommodation. East Sussex County Council suggest that the text in criteria 1(a) ii) is strengthened by replacing the word ‘encourage’ to ‘enable’. Hampshire County Council supports the intention of the policy but has concerns regarding the requirement for visitor accommodation and attractions to be in a sustainable location. They comment that farms seeking to diversify are often in remote, rural locations, and do not have connections to public transport; there is therefore a reliance on the car to travel any significant distance. This remote tranquillity is one of the attractions for visitors to the area, and there is an opportunity for farms to meet demand for accommodation and local attractions. They consider that criteria 1a)ii and 1b)iii inherently prevents any farm diversification from taking place in rural and remote areas and this may may affect the farm’s longevity and could have potential negative repercussions on the local rural economy based around the farm or holding. This is inconsistent with the positive approach to economic growth in rural areas set out in para 28 of the NPPF. In addition, Hampshire County Council make comments about their responsibility for a range of parks and other sites across the National Park and reference to the Hampshire Countryside Access Plan (CAP) 2015-25. They recommend that reference is made to the CAP as a statement within Chapter 6 as it will confirm the commitment of the NPA to work with the County Council to achieve the aspirations of the Hampshire Countryside Access Plan as a key partner. Horsham District Council support the aims of the policy. They note that in light of comments from the SDNP, HDC has amended the wording of our tourism policy to ensure that developments are in keeping with their sensitive surroundings in particular in the settlements of Pulborough, Storrington

164 and Steyning which are close to the park. Given the SDNPA’s support for this approach and the reference in para 4.35 to the context of the National Park within a wider network of settlements, it would be helpful to ensure that these two policies are ‘joined up’. They suggest additional wording in policy and supporting text to reflect the role that HDC settlements have in providing gateways with supporting services, businesses and workers to support the park. Lewes District Council support the policy and comment that the approach will help in achieving the Council’s own priorities and aspirations, as set out in its Regeneration Strategy: Building a Brighter Future (2012). Parish and Town Councils Arundel Town Council note that para 6.34 mentions the shortage of quality accommodation at peak times, and para 6.35 indicates that Gateways outside the Park play an important role. They welcome the proposal that local authorities should work with the SDNPA to “enable opportunities to support the visitor economy”. They suggest the deletion “clearly” as this is unnecessary emphasis. They also consider that the policy is far too restrictive, being based on the concept of “the control of visitor accommodation”. Instead, the SDNPA should be encouraging additional visitor accommodation without these restrictive measures. In particular, they suggest that the negative criteria 5 should be deleted. Barlavington Parish Council comments that the policy discusses the lack of accommodation for leisure activity. They support the pursuit of these activities and associated accommodation and recognise that many livelihoods depend on this sector. However, they comment that there needs to be a balance between small businesses and the mass outdoor tourism villages or holiday camps that often live in the landscape but are not part of it and consider theme parks, outdoor logged cabin settlement as industrial developments. They consider that the document needs to consider the compatibility of making the SDNP open for all to enjoy, but not destroy its very essence by considering the implications of such schemes. Madehurst Parish Meeting in general support the policy, but as a community are sensitive to the implications of this policy if not strictly applied given that there is a potential development proposal for Houghton Forest. In general they believe the policy does provide the level of guidance and support required. They would hope for more precise pointers against developments not already identified within SD22 and comment that given its geographic shape, the park can easily be accessed from accommodation outside its boundaries, enabling visitors to enjoy fully all its character without spoiling its special qualities by damaging tranquil areas. Rodmell Parish Council supports the proposal that it must be demonstrated that any proposed on- site facilities will not have an unacceptably adverse impact on the vitality of assets of community value. Selborne Parish Council consider that para 6.30 is written incorrectly and it implies that by contributing to economic growth, there is an opportunity to contribute to the second purpose. They consider this to be a flawed interpretation of the legislation and whilst contributing to economic growth may well contribute towards the National Park's Duty, under s.62 of the 1995 Act but in no way does it contribute to the second NP purpose, under s.61 of the Act. They also comment that there is not enough mention of visitors in the policy. They also comment that the impact on residents of the local area and on their amenity is vitally important and there should be more emphasis in the policy upon activities that contribute to the quiet enjoyment of the National Park. Suggest replace the words "unacceptable adverse impact" with the word "harm" and the word "centre" from "town or village centres" should also be removed, because it is not just the centres that might be affected.

165

Warnford Parish Meeting note that criteria 1(a)(ii) requires evidence that a proposal for visitor attractions and accommodation “… reduces the need for travel by private car….”. They comment that Warnford Parish (like many others in the National Park) has no effective commercial bus service and the only practical way in which this policy could be implemented, therefore, is if the facility was designed specifically for walkers and cyclists and (for example) without car parking. They believe that this should be spelt out more clearly in terms of development which will and will not be allowed in areas with no effective public transport. Other Organisations The Alice Holt Community Forum made the following comments:

 Need to reconcile environmental, economic and social objectives in relation to woodlands such as Alice Holt, particularly having regard to the Sandford Principle. For example, Alice Holt is at times at full capacity with visitor numbers, with all car parking spaces being used. Any significant increase in visitor numbers, particularly at weekends, would, in the view of the Forum, be unsustainable. Policies to encourage visitors to Alice Holt, particularly at peak times are not needed and would be inadvisable.  Strongly opposed to any form of built or tented development within Alice Holt Forest, including static or touring caravans, holiday villages, lodges, cabins, ecopods and other facilities providing overnight accommodation. Believe that such developments and their infrastructure would result in the loss of and damage to the ancient woodland, would be detrimental to the ecology and biodiversity of the woodland, would damage the tranquillity of the Forest, would interfere with access rights and the quiet enjoyment of the woodland by the public, would be inconsistent with the natural environment of woodlands, and would conflict with the first purpose and be contrary to the Sandford Principle.  Supports statement in para 6.43 regarding impact on quiet enjoyment of the National Park. Policy SD21 rightly acknowledges this. Request that this is also acknowledged within Policy SD20, since visitor accommodation has the potential to have similar impacts. The Angmering Estate, Cowdray Estate, Leconfield Estate and West Dean - The Edward James Foundation commented that the policy is generally supported subject to the following points being addressed:

166

In addition, West Dean - The Edward James Foundation commented that the policy does not currently recognise the substantial positive contribution that visitor attractions like West Dean College and its Parks and Gardens add to the local economy. They consider that this positive impact should be better recognised through the policy, including the potential for their growth and expansion. Arundel Chambers of Commerce note that para 6.34 mentions the shortage of quality accommodation at peak times and para 6.35 states that Gateways outside the Park play an important role. They state that Arundel Town Council and Arundel Chamber of Commerce would welcome the chance to work with the SDNPA to “enable opportunities to support the visitor economy.” Bignor Park Estate made a related comment on SD47, which considers that the wording in para 10.114 on tourist accommodation needs to be tightened to prevent dwellings being built as tourist accommodation which are then subject to change of use applications to residential a few years later. CPRE Hampshire commented that the supporting text suggests that economic growth contributes to the second purpose of the National Park which is not correct in terms of law. They consider that the last sentence in paragraph 6.30 should read "...... an opportunity to contribute to meeting the second National Park purpose and to sustainable economic growth". They agree that high numbers of visitors put pressure on some locations and "hot spots" by impacting on tranquillity and physical erosion and it is particularly important that new visitor attractions do not generate an increased level of activity which would detract from the Special Qualities. They note that this is inferred in Policy SD20 (1)(a)(iii) but it would be better to state this expressly, and to refer outright to cumulative impact with existing attractions. CPRE Sussex support the policy. CLA are concerned about the requirement for development to be reliant on public transport and other sustainable means of transport. They quote from the National Policy Statement for National Networks, published by the Department for Transport in January 2015 and NPPF regarding the realistic alternatives to private car journeys, particularly in rural areas. They are pleased that the reuse of existing buildings is encouraged. They note that redundant/ semi-redundant agricultural buildings are a plentiful and underutilised resource and this should be recognised when applications are made. They note that criteria 5 is non-specific and further clarification is needed. They have great concerns that this would be used to refuse permission on an adverse impact despite an overall net positive impact and the overall net impact should be the overall consideration. The Goodwood Estate commented that the policy is positive and enabling, but there is a danger that uses may be limited to a traditional view of tourist activity and not respond to changing fashion and taste. They consider that flexibility is required to allow providers to respond quickly and effectively to changing markets, whilst balancing this against environmental considerations. They suggest that the supporting text and policy is amended to acknowledge the changeable nature of the industry and that in some instances, with robust evidence, a more flexible approach is appropriate. Friends of the Earth Brighton & Hove suggest the removal of ‘unacceptable’ before ‘adverse impact’ in criteria 1 and 5 and deletion of ‘satisfactorily’ from criteria 1, because all development should be accessible by non-car modes otherwise this if too subjective and will undermine other policies in the Plan. Friends of Lewes Society support the policy. Marwell Wildlife support the policy, subject to suggest amendments to the policy and supporting text. They support the principle and its support for the tourism industry, but consider that the focus is on new tourism development. The suggest that the local plan should also provide clear support for

167 existing visitor attractions in line with the plan's objectives (Fig 3.2), and to complement the support for small scale rural business (policy SD27). They recommend that the policy if amended, or a separate policy added, to specifically acknowledge the positive contribution that existing large organisations make to the special qualities and vitality of the National Park and note the Winchester Joint Core Strategy policy MTRA5 (Major commercial and education establishments in the countryside). The National Trust objects to the wording of the policy and consider that as worded it does not comply with guidance contained in the NPPF at para 28 regarding supporting a prosperous rural economy. They made a number of comments:

 The National Park has many important cultural, heritage and landscape assets which visitors wish to come and experience and this has been recognised in Policy SD27. These are often sited in remote locations and whilst the Trust will support efforts to improve sustainable transport across the area, it has got to be recognised that there will be limitations in what can be achieved.  Concerned that the policy will unduly inhibit the provision or diversification of visitor facilities at established visitor attractions in the park as it is not possible to move the mansion house or iconic landscape to a more sustainable location and it would be highly unlikely that an applicant can guarantee public transport improvements.  The reference in the policy to complying with Policy SD22 would appear to preclude this opportunity as this policy does not permit new buildings in countryside areas and appears to apply tighter restrictions on development than the NPPF advocates in respect of rural businesses and duplicates some of the criteria that are listed under part (b). They considers that a more relevant policy for SD20 to be linked to is Policy SD27 which specifically relates to the rural economy, of which tourism is a key component.

The South Downs Society support the policy and trust that the wording of criteria 1 (a) iii) will include the capacity to challenge any proposed equestrian activity if it seems likely to result in excessive and unacceptable use of the nearby network of bridleways. They welcome the provisions of criteria 2 in requiring a robust marketing exercise before possible redevelopment of visitor accommodation to residential use.

168

The South Downs Land Managers Group and the Sompting Estate made the following comments:

 The Policy appears to favour new visitor accommodation in built up areas rather than rural locations and this has potential to exacerbate problems of public access on the rural fringes. Consider that it needs to be recognized that the majority of visitors to the National Park do so because of its rural location and it should be acceptable for visitors to come to the Park by car but then encouraged once there, to walk, cycle or ride.  As one of the main activities that visitors come to the National Park for is walking; accommodation in rural areas is ideally situated to make best use of public rights of way and is better able to meet purpose 2 and the enjoyment of the special qualities of the park.  Facilities and services in rural areas are often supported by visitors to the area. Restricting tourism development in rural areas could be detrimental to the survival or rural pubs and village shops.  Disagree, as it stands, with 1.b)iv). As recognized in para 6.51, it is not always in the interest of the Purposes to create a honeypot hotspot effect. In addition visitor accommodation which will allow users access on non-PROW tracks could be more of an asset to Purpose 2 than accommodation giving access only to existing rights of way, and this unnecessarily duplicates the reference to satisfactory connections for walking etc in 1.b)iii).

In addition, the Sompting Estate support the present wording of 6.40, in particular the final sentence, for the reasons given. Wiggonholt Association commend the policy. Agents and Developers Amberleigh House Limited noted that the Visitor Accommodation Review emphasised some gaps in current tourist accommodation provision, most notably hotel accommodation in Petersfield. They welcome the recognition of the importance of tourism to the future health and prosperity of the National Park. They note the emphasis in the policy for proposals to be located in sustainable or gateway locations is generally accepted. However, they consider that in order to be comprehensive, para 6.44 could acknowledge that a high proportion of visitors currently arrive by private vehicle, and that suitably located accommodation, could help reduce vehicle movements through the Park, providing alternative modes of transport to access the Park were accessible at this point. They suggest that this could also be acknowledge in Criteria 1.a) ii). Callstone Ltd commented that visitor and tourism accommodation is considered appropriate in a number of locations throughout the National Park, including for example the Shoreham Cement Works, as an established and acknowledged previously developed site. They make reference to the 2003 Appeal on this site, where an element of visitor and tourism / leisure accommodation, including a hotel, was supported. In these terms, they consider that the principle of these uses on Shoreham Cement Works should be acceptable, further as it would meet the Second Purpose of the National Park. Forest Holidays Ltd welcome the acknowledgment that tourism plays a vital role in sustaining the economy of the Park, and that, by enabling the provision of appropriate tourist accommodation, this will provide further economic benefits to the local economy. They support the recognition that for some tourism accommodation, it is necessary to be located outside of settlements, and instead focussed on a geographically fixed resource.

169

Green Village Investments support the statement in para 6.44 regarding the location of accommodation near to sustainable and gateway locations. However, consider that this is not reflected clearly in the Plan as it fails to acknowledge the unique benefits of Liphook as a sustainable gateway to the National Park. They make specific reference and detailed comments on the proposed development at Bohunt Park. They comment that the policy is not worded positively with respect to developing and enhancing sustainable tourism facilities in accessible and sustainable locations, such as Bohunt Park, making reference to para 157 of the NPPF. They also consider the policy to be defensive and inconsistent with the largely positive support in Policy SD18 and SD19 and suggest that the Policy is rewritten more positively and makes special acknowledgement of the positive importance of gateway locations to the Park, and the key role of sustainable transport links in planning strategically and positively for tourism and the visitor economy in the Park.

Smiths Gore comment that the policy is generally supported subject to the following points being addressed:

 Not clear how the requirement to increase the awareness, understanding and enjoyment of the special qualities of the National Park to this should be evidenced as part of a planning application. Clarity is welcomed.  Criteria 2 refers to explains that the location of development should reduce the need to travel. However, it should also be recognised that tourist and visitor accommodation sometimes requires a more remote location so that visitors can enjoy the peace and tranquillity of the National Park.  Important that planning policy is flexible and allows development to respond to changes in economic circumstances. As such, the timeframes prescribed in criteria 2 are onerous and should be more flexible.  The policy may unnecessarily constraining the tourist accommodation market by resulting in an oversupply of accommodation that does not fulfil the needs of the market. By allowing greater flexibility for certain types of tourist accommodation to change to different uses, new accommodation should come forward in places that will fulfil the market demand. Greater flexibility should also ensure the right type of tourist accommodation comes forward to fulfil market demand. Individuals One individual notes the acknowledgement in para 6.38 that the promotion of sustainable tourism is not a specific duty of national park authorities and, therefore suggests the SDNPA does not get involved. One individual commented that developments for accommodation should be described as small scale. Farm diversification, encouraging B&B and small scale good quality accommodation as well as supporting tourism in the neighbouring local authorities where there is a need for jobs and sustainable options for staff are key. Reference to examples of incredible small scale farm and derelict building solutions in Northumberland and the New Forest, which enhance the area. They suggest that development should be small and good quality vernacular build or low key and canvas or within major developments in the strategic sites within the park. They also suggest working with others to support pressure periods and promote options in neighbouring authorities as part of SDNP experience by creating a SDNP kite mark for nearby accommodation. Emphasise the importance of maintaining the vision and not allowing policy wording to be weakened over time (reference to examples of this in Lake District). One individual considers that the plan is weak on economic impact and it does not explain (in many places) where business tourism fits. They comment that Policy SD20 and 21 continues the

170 aspirations regarding less cars but has no practical solutions. They also question how an all year visitor economy will be achieved. One individual supports the policy and approach and commented on occasion a defensive approach may be required and essential. One individual comments that the Outcome 8 of the PMP is not reflected in Strategic Policy SD22. All visitor related development should seek to make it easier for people to become involved in caring for the landscape and to encourage changes in behaviour. One individual commented that it is imperative that the NPA consider the buffer areas around the South Downs which will provide accommodation and refreshments for people enjoying the Downs. They also comment that people will expect to stay in an appropriate property, such as traditional cottages, and will expect to be able to walk, ride and cycle to pubs along quiet country lanes. They make reference to potential development of the West of Hollycroft field in East Chiltington and the positive characteristics of local area which attracts visitors and is promoted as a destination and consider that development of this site will have a detrimental impact on the character of the village and country lanes and would deter tourists and thus would conflict with your policy of encouraging sustainable tourism. One individual commented that there are many derelict old barns in the park and questioned whether these could these be sympathetically converted in to homes with visitor accommodation.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Restructure and rewording of SD23 and supporting text in response themes within the comments received.  Addition of criterion 1 (g).  Criterion 5 deleted.  New criterion 4.  ‘Historical significance’ added to criterion SD23 1(c).  Details of marketing requirements set out in Appendix 3 and supporting text.  Inclusion of the Spatial Portrait and Spatial Strategy (Chapter 3) and supporting text in SD23 regarding gateways.  Sustainable transport means expanded upon.  Supporting text expanded to clarify how proposals may demonstrate a development provides opportunities for visitors to increase their awareness, understanding and enjoyment of the special qualities.  The policy and supporting text now recognises that tourist and visitor accommodation may be required in a more rural location, and criterion 1 (g) seeks to ensure that this is planned for appropriately, and encourages small scale accommodation and farm diversification schemes or whole estate plans.  Supporting text considers the retention and reuse of existing buildings  Policy and supporting text changed to show how the SDNPA will support a year- round visitor economy.

171

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason No consideration for impacts on statutorily This is addressed elsewhere in the Plan. protected wildlife sites Text in criteria 1 (a) (ii) should be strengthened The SDNPA are satisfied that by use of the by replacing the word ‘encourage’ with ‘enable’. word ‘encourage’ in this context is appropriate. No reference to Hampshire Countryside Given the policy is a strategic policy, it is Access Plan (CAP) 2015-25. considered more appropriate to reference the SDNPA’s Sustainable Tourism Strategy which provides relevant hooks to detailed actions and strategies. Not enough mention of ‘visitors’ in the policy There are references to visitors throughout the policy. The word ‘centre’ should be removed from Criterion 1 (b) deals specifically with proposals SD23 1(a) (v) as it is not just the centres that that are located outside of the centre in the may be affected. countryside (as defined on the Policies Map). No mention of quiet enjoyment in SD23 Supporting text and policy refer to the special qualities of the National Park, of which tranquil and unspoilt places is one. Timeframes in Criterion 2 are onerous and The SDNPA are satisfied that a minimum 12 should be more flexible month marketing campaign is required to robustly and fairly demonstrate whether there is a market demand for the existing use or an equivalent tourism use. No marketing campaign is required where the current development is considered to be harming the special qualities. Policy does not recognise the contribution that It is not the intention of the Local Plan to make West Dean College and its Parks and Gardens site specific references in the Policy or add to the local economy. generally the supporting text. Many institutions make a valuable contribution to the rural economy of the South Downs.

Suitable sites should be identified for a town Hotels are identified, on a sequential basis, as a centre hotel in Petersfield. ‘main town centre’ use in the National Planning Policy Framework (p.53). As such, there is no need for the plan to identify specific sites in Petersfield or elsewhere.

172

Policy SD21: Recreation

Reg 22 (1) (c) (iii) There were a total of 30 comments on this policy. These are summarised below. National Agencies Sport England object to the policy. They comment that the policy is restricted to outdoor recreation and is focussed on provision for visitors. They suggests this is broadened to meet the needs of the resident population for open space sport and recreation and informed by the NPPF Par 73 assessment (or the Local Plan includes a separate policy for formal sport and recreation, informed by the assessment) Borough, City, County and District Councils Brighton & Hove City Council commented that the National Park is not an island and its open space including its recreational facilities may meet the needs not only of the communities within the National Park but also those adjacent. They make reference to the example of the loss of the long standing level recreational facilities provided at Braypool and Waterhall, which could undermine the Duty to Co-operate and would result in a significant shortfall in the outdoor sports requirements within the City. Given that these facilities existed prior to the designation of the National Park it is considered they must meet the National Park criteria and should not therefore be considered to be out of keeping with the National Park. They requests that criteria 6 is amended by the replacement of the words: "which serve the Purposes of the National Park" with "without evidence to demonstrate the facilities are surplus to current and future requirements". Hampshire County Council repeat the comments made on Policy SD20. Parish and Town Councils Arundel Town Council considers that the whole of the policy is unnecessarily restrictive and suggests the deletion of criteria 2 to 6. Bramshott and Liphook Parish Council presume that "recreation" includes sports but in which case clarification should be made of the type of sports to be included (e.g. 'noisy' sports which would impact on tranquility or quiet enjoyment of the Park should not be encouraged). They also comment that proposals for recreational activities should not be dependent on major development to be achieved, and separate applications should therefore be rejected unless assurances of financial viability are given. This is evidenced in Liphook where a local football club is unable to access an approved new pitch without funding a significant roadway across the Park, or unless a major housing development is approved. East Chiltington Parish Council note that the loss of existing recreational facilities must be mitigated by provision of improved or equivalent replacement and comment that any proposals should also be required to have the full support of the community concerned. Cocking Parish Council comment on para 6.51 and note that cycling events are an important aspect of recreation in the South Downs area, especially along and around the South Downs Way. They comment that large cycle events, as opposed to small local groups of enthusiasts, need to be properly managed to avoid being a nuisance to others. Cycle check points and refreshment stops should be provided with portable lavatories. Cycle events charge an entry fee to participate and this should be used to provide and remove proper facilities as well as the clearing away of residual litter. Liss Parish Council comments that the plan needs to recognise that in neighbourhood plan areas the Policies Map will not define the extent of countryside.

173

Madehurst Parish Meeting support this proposal and specifically note criteria 4,5 & 6, which they feel will provide the level of protection required to ensure ongoing enjoyment of the SDNP without detriment to the special qualities. They note that Whiteways Picnic area is a key local spot which provides easy access to the country side in a contained and manged way. Selborne Parish Council notes that the policy refers to visitors' recreation but it is important that it should refer also to recreation by residents. They agree that the informal quiet enjoyment of the area must not be prejudiced, but the focus of the whole policy should be on the provision of informal quiet enjoyment and not on providing various forms of recreation that may possibly cause disturbance to local residents by reason of noise etc. for example. The suggest replacing “unacceptable adverse impact” with the words “cause harm” or just “harm” and removing the word “centres” from “town or village centres” in criteria 2 because the whole village can be affected. Other Organisations British Canoeing commented on para 6.49 and that the Sandford Principle is often misquoted and misinterpreted as "conservation has priority over recreation" and it is better summarised as, "where those two purposes cannot be reconciled by skilful management, conservation should come first" The British Horse Society support the policy, especially the protection of ‘informal quiet enjoyment of the National Park’. CLA repeat comments made on Policy SD20. CPRE Sussex supports the policy. Goodwood Estate commented that the policy is positive, with an emphasis on quiet enjoyment and the principle of protecting the environment as a key objective of the National Park. However, they consider there is a danger that uses may be limited to a traditional view of recreation and not respond to changing fashion and taste. Flexibility is required to allow providers to respond quickly and effectively to changing markets whilst balancing this against environmental considerations. The supporting text and policy should be amended to acknowledge the changeable nature of the recreation industry and that in some instances, with robust evidence, a more flexible approach is appropriate. Friends of the Earth Brighton & Hove supports the policy, but suggest deletion ‘satisfactorily’ from criteria 3c as all development should be accessible by non-car modes otherwise this will undermine other policies in the Plan and the term ‘satisfactorily’ is too subjective. Suggest removing ‘unacceptable’ before ‘adverse impact’ in criteria 5. Friends of Lewes Society support the policy. Leconfield Estate repeats comments made on Policy SD20. The South Downs Society support the policy. They question whether it would be more appropriate to require applicants to demonstrate a benefit to the local economy, rather than “not undermining …. town or village centres” in criteria 2d). They assume that the application of criteria 4 will enable the planning authority to take a view on a case by case basis of proposed shooting activity and its potential impact on local residents and businesses and those seeking quiet enjoyment. South Downs Land Managers Group support criteria 1 and reference to understanding, especially if this were to include understanding of land management and improve behaviour of visitors to the countryside. They refer to comments made on Policy SD20 and suggested amendments also apply to this policy. They consider that the wording of criteria 2.c) ‘make use of existing buildings, where possible’ is unduly restrictive and is inconsistent with the wording ‘make use of existing buildings,

174 where appropriate’ in SD20.1.a)iv), which they support. Possible but inappropriate reuse of existing buildings would not be consistent with Purposes or Duty. Comment that criteria 2d does not recognize the need to consider and protect existing rural businesses. Sompting Estate make reference to and repeats the comments made on Policy SD20. In addition, they consider that the wording of criteria 2.c) ‘make use of existing buildings, where possible’ is unduly restrictive and is inconsistent with the wording ‘make use of existing buildings, where appropriate’ in SD20.1.a)iv), which they support. It may be possible but inappropriate. Suggest extending the protection of criteria 2d to include rural enterprises which might be undermined. Agents and Developers Green Village Investments support the policy and consider that the proposals at Bohunt Park fully meet the criteria of the Policy and reflect the statutory duties of the National Park, particularly the duty to promote opportunities for the understanding and enjoyment of the special qualities of the National Parks by the public. They make a number of comments about aspects of the proposed development at Bohunt Manor as an interesting future model for the National Park as it seeks to facilitate public access for recreational purposes and enjoyment, whilst preserving the more sensitive areas of the Park. Individuals One individual commented that whilst the National Park plan has many laudable policies it appears that there is no attempt to tackle some of the current ‘conflicts’ within the countryside. They make reference to potential conflict between game shooting and other users of the countryside such as walkers and cyclist. Game shooting has increased in the South Downs, with rise in commercial shooting and the SDNPA should adopt a policy which attempts to minimise the conflict. One individual supports the policy and approach. One individual comments on how Carriage Driving offers recreation and enjoyment of the countryside in a way that may be prohibited to them such as walking, cycling & horse riding. Being on a carriage allows those with health, wellbeing or age issues to still get out and move around the area, enjoying the peace and beauty without the physical exertion that the other activities might require of them. They recommend that the NPA create multi-user routes (restricted byways) hopefully circular with parking for horse transport. One individual comments on the need to encourage all developments that are 'recreation' based to identify and contribute to the value of people getting involved with caring for the landscape - making improvements and increasing appreciation. One individual comments a stronger emphasis should be placed on sustainable tourism and the visitor economy as this is the future. They suggest the following proposals: creating village hubs (e.g. Selborne, Chawton, Greatham and Hawkley), promoting walks within this hub which benefits local business, promoting cycling (both mountain biking and road) between the village, promoting e-biking (older generation) and promoting the health benefits of each route and activity. One individual suggest the ‘shared identity’ should be referred to in the Local Plan.

175

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 SD21 (Recreation) and SD35 (Provision and Protection of Outdoor Space) are noW one policy, Policy SD46 (Provision and Protection of Open Space, Sports and Recreational Facilities and Burial Grounds/Cemeteries.  Criteria 2(c) deleted.  Criterion 6 replaced by Criterion 3.  Criterion 5 deleted, deletion of reference made to ‘visitors’ recreation’ and ‘town or village centres’.  Reference to the Sandford Principle deleted.  Consideration has been made in the re-wording of the policy to have a more flexible approach to the type of open space or recreational space required. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason No reference to Hampshire Countryside Access Plan (CAP) 2015-25. The policy doesn’t recognise that recreational The SDNP is the planning authority for only facilities outside of the Park boundary may still those areas within the national park boundary serve the National Park. however it does have a duty to cooperate with those authorities partly within the boundary. Policy does not have regards for large cycle events and the provision of facilities for such events. The plan does not recognise that in neighbourhood plan areas the Policies Map will not define the extent of countryside.

A policy should be adopted which attempts to minimise the conflict between game shooters and other users of the SDNP. Create multi-user routes (restricted byways) hopefully circular with parking for horse transport. A stronger emphasis should be placed on See Policy SD23 sustainable tourism and the visitor economy as this is the future.

176

Chapter 7: Towards a Sustainable Future

Preferred Options Policy SD22: Development Strategy Corresponding to Pre-Submission Policy SD25: Development Strategy

Reg 22 (1) (c) (iii) There were a total of 122 comments on this policy. These are summarised below. National Agencies No Comments received Borough, City, County and District Councils A wide range of comments were received from eight local authorities: Hampshire County Council – Objected to the policy, questioning why it was restricted to estates and large farms. Consideration should be given to including small and medium farms as well. Eastbourne Borough Council – Support the approach and in particular the protection of the downland landscape by containing development in East Dean and Friston to within the settlement policy boundary. Horsham District Council – Recent examinations of Local Plans shows a need to robustly demonstrate the ‘no stone unturned’ approach has been applied to the identification of land for housing, it is assumed that the SDNPA will be able to demonstrate that they have pursued this approach. Lewes District Council – The terms used to describe the scale of appropriate growth in SD4 Broad areas policies are not clear enough to guide decision makers (NPPF para 154). There is also concern that if the NDPs do not progress in time for the submission of the Local Plan that there will be a policy vacuum for the settlements of Lewes and Ditchling who are responsible for drawing their own settlement policy boundaries. The wording of clause 2 is open to broad interpretation which may lead to an increased number of S78 appeals. Adur & Worthing Councils – Further explanation and justification requested regarding the selection of sites close to the boundary of the National Park and adjacent to settlements outside the National Park, and whether these sites wouldn’t be better placed to serve the needs of the settlements they adjoined rather than of the SDNP in general. Would welcome recognition of the relationship between National Park residents and the surrounding urban centres and the access to services and facilities this provides. This would come under the Duty to Cooperate. Either way clarification is sought on the operation of the allocation of affordable housing. Chichester District Council – Consider it important to acknowledge the NPPFs support for exceptional quality and innovative design of new dwellings which is classed as a special circumstance for development as set out in paragraph 55. Winchester City Council – Commented that the tightly drawn Settlement Policy Boundaries restrict the implementation of the plan which says it allows natural growth within these settlements.

177

Parish and Town Councils Comments were received from 22 Parish/Town Councils. There was strong support from 10 councils for the list of and changed Settlement Policy Boundaries (SPBs). Support was also received for:

 Reduction of Settlement Policy Boundaries creates more opportunities for affordable housing development. The following comments were made:

 It is unclear why some settlements have had their Settlement Policy Boundaries removed and others haven’t.  Further clarity needed on how SPBs can be changed, in particular as NDPs for the Settlements listed are responsible for drawing their own SPBs and this needs to be acknowledged within the Local Plan.  Criterion 6 does not specifically mention a positive approach in favour of using brownfield land for more locally appropriate/less invasive uses such as housing or light industrial.  Further advice needed for NDPs who are not allocating housing in their NDP and where and how this will be addressed within the development plan.  The requirement for farm plans must be practical and proportionate to the scale of the farming operation.  The plan is missing maps for other settlements.  Concern over what may be considered “exceptional circumstances” and seek further clarity, specifically in regard to tourism and recreational facilities.  Strengthen criterion 3 by requiring robust evidence and that re-use of buildings should be “appropriate and beneficial”.  Remove unnecessary emphasis from criterion 4 (“exceptionally” and “clearly”)  Clarification sought on what would be considered a “small site” in criterion 5.  An additional policy is needed which governs the production and review of Whole Estate Plans. Objections were raised to the following:

 The removal of the East Worldham Settlement Policy Boundary, stating that this must be reassessed and proximity to nearby centres must be taken into account.  Due to the timing of the adoption of the SD Local Plan, it would override policies in Neighbourhood Plans which are more detailed and locally specific. The policy should acknowledge this.  Should clearly state that in NDP areas, the NDP will define the settlement boundary  There is no need to say that development may happen outside SPBs, there are always exceptions. If this remains, then greater clarity on what exceptions will be permitted.

178

Other Organisations 15 groups or organisations made comments on this policy:

 Given that the Plan supports sustainable development, why does it not mention/promote higher density development which is a characteristic of sustainable development and in making efficient use of brownfield land.  Several comments that the plan and this policy specifically need to strongly support and prioritise the re-use of previously developed land/brownfield land, in preference to greenfield land. This included one objection due to the weak position of the policy in relation to re-use of brownfield land.  The South Downs Society, South Downs Land Managers Group and National Farmers Union (South East Region) gave support for the principle of Whole Estate Plans although further clarity and guidance is required. The introduction of WEPs should not prejudice against those who are already providing ecosystem service benefits (i.e. support maintaining those benefits, not just seeking new/further benefits)  Support for the need to robustly evidence need for development in the open countryside, but this should be expressly written in to the policy (SD22 (3))  Further explanation of what the appropriate re-use for an existing building is. (SD22 (3d))  To be in accordance with the NPPF, reference should be made to the “exceptional quality and innovation” circumstances from NPPF paragraph 55.  Reconsider establishing SPBs for other settlements.  Safeguarding of iconic views of the Seven Sisters coastline, Seaford Head and the Cuckmere Estuary need protection from development outside the National Park.  Seek greater clarity of wording to prevent the loss of agricultural land, including reference to food security and reducing food miles.

Agents and Developers 31 comments were received. There were two key areas of focus: Whole Estate Plans and Settlement Policy Boundaries. The comments are summarised below:

 Whole Estate Plans are not always necessary and need to be appropriate to individual circumstances. They must not be overly complex and burdensome.  The introduction of WEPs should not prejudice against those who are already providing ecosystem service benefits (i.e. support maintaining those benefits, not just seeking new/further benefits)  Clauses 4a and b were considered to be repetitive  Questioned the exclusion of institutions and educational establishments, both often large land owners, from the Whole Estate Plans definition.  Disagreement with the tightening of the SPB surrounding the settlements of Cocking and Midhurst.  The tightening of SPBs puts the whole plan at risk of not being able to deliver much needed housing.  There should be a change to the wording of clause 4 from “exceptionally considered suitable” to “generally considered suitable”.  The Local Plan should set SPBs for all settlements, particularly where NDPs are not progressing quickly enough  There should be greater support given to the re-use of previously developed land / brownfield land. It is not enough to allocate strategic brownfield sites.

179

 Additional wording should also be added to clause 3: “Development proposals will not normally be permitted outside of settlement policy boundaries or outside of Strategic Sites…”  Support that East Dean and Friston has an SPB.  The SPB around East Dean and Friston should be redrawn to include other sites which would form a natural extension to the existing settlement.  Tourism and recreation should be listed as suitable exceptions to the policy.  The previous tiered approach to settlement classification gave much greater indication of suitability for future growth within settlements.  Concern that there is over reliance on small sites in unsustainable locations rather than on large sites in more sustainable locations.

Objections to policy SD22 are summarised below:

 The removal of an SPB from the settlement of Blackmoor appears unjustified when lower scoring settlements have retained their boundaries. The scoring for Blackmoor was also considered inaccurate. The text also referred to a wide number of studies that have been taken into consideration when determining the SPBs but it does not state what they are and they have not been made available for review.  Object to Swanmore not being included, as it is considered a sustainable settlement within the Joint Core Strategy.  Several comments were made, which noted the inclusion of the two sites on the boundary of the National Park, adjacent to settlements outside the National Park and questioning their inclusion when other sites on the boundary had not been allocated.  The requirement for an Estate Plan should not prevent or delay development which otherwise conforms with the development plan policies.  There are no allocations shown to meet Selbourne’s housing requirement. The SPB should be redrawn to include the site which was found suitable in the 2015 SHLAA. It should be noted that several specific sites were identified and promoted for inclusion. However no specific sites are named within Policy SD22 so these comments will be considered under either the relevant policy/allocation or the SHLAA update process.

180

Individuals 22 comments were received. Many focussed on the issue of Settlement Policy Boundaries (SPBs) Support was received for:

 Whole Estate Plans  Commended for making Landscape a priority in the Local Plan  Compton’s SPB and score in the Settlement Facilities study.  Selbournes revised SPB  The identification of Corhampton and Meonstoke as a sustainable location for growth

The following comments were made:

 The policy does not support sustainable development and therefore conflicts with policy SD1.  The policy is not compatible with encouraging sustainable farming or changes due to changes in farming practices.  It is not possible to know what will happen in the future regarding farming, therefore the requirement for Whole Estate or farm plans must be dropped.  Many comments were received stating that SPBs should not be drawn so tightly as to restrict all infill or windfall. Greater flexibility should be considered  By drawing the SPBs so tightly, it leads to conflict between SD22 (the boundaries) and SD23 which states that these settlements can accommodate growth.  Maintain existing SPB around Selbourne.  The Local Plan needs to acknowledge and give appropriate weight to the SPBs and allocations of NDPs  The differences in scores for the same settlements in the Settlement Facilities Study and the Settlement Hierarchy were questioned, as no explanation is given.

Objection

 Several individuals criticised the SPB review methodology as flawed as it does not consider implications on windfall; higher order settlements also serve lower order settlements; a broader range of facilities need to be included; transport times are not correct.  Under the Local Plan proposals, smaller villages will stagnate and local people will have to move away. Spread development more widely, fairly and equally.  Group settlements under the broad areas  There is no provision for “truly outstanding or innovative design” in accordance with the NPPF.  Policy SD22 does not clearly define “exceptional circumstances”  Several individuals criticised the Settlement Facilities Study methodology as flawed.  East Worldham and Exton should have SPBs.  The SPB around Corhampton and Meonstoke has been drawn too tightly and unnecessarily restricts any growth when there is a need for new housing. There were also 10 comments regarding a particular site in East Chiltington. These comments did not relate to the wording of Policy SD22 or the supporting text. They will be considered separately. One individual commented that the distribution of development appears arbitrary, relying on availability of land or previous local plan strategies. Most villages with 100 or more homes could

181 accommodate a small number of homes which would allow for an increase in much needed social housing. One individual commented that recent examinations of Local Plans shows a need to robustly demonstrate the ‘no stone unturned’ approach has been applied to the identification of land for housing, it is assumed that the SDNPA will be able to demonstrate that they have pursued this approach.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Comments noted that the distribution of development appeared to some as arbitrary, relying on availability of land or previous local plan strategies, and may not have fully evidenced that there has been ‘no stone left unturned’. Supporting text has been improved to clarify, in simple terms, how the distribution relates back to the spatial strategy. Chapter 3 of the Local Plan also sets out new text to better articulate the spatial strategy (under the heading ‘Spatial Strategy’). This is further detailed in the Development Strategy Background Paper.

 Concern regarding policy vacuums occurring (e.g. affecting settlement boundaries) has been addressed, by inclusion of text in Chapter 1 of the Plan. Paragraph 1.40 states that further DPDs may be taken forward if NDPs have not progressed in a timely fashion. However all NDPs relating to settlements relevant to this comment are highly likely to have been ‘made’ ahead of Local Plan adoption.

 Numerous comments concerning the inclusion of some settlements in SD22 and not others. The approach in the Preferred Options took account of the Settlement Facilities Study, and an assessment of landscape sensitivity. In light of comments made, the list of settlement to include was objectively reviewed ahead of pre-submission and resulted in the addition of two further settlements. There is considered to now be a clear and consistent approach. The Development Strategy Background Paper clarifies on this further, with details of the studies considered.

 There were comments on the relationship of NDPs being prepared both before and after adoption of the Local Plan, for example relating to settlement boundaries. Clarifying text is now included in Chapter 1 of the Plan. Paragraph 1.38 confirms that all NDPs need to be in general conformity with the strategic policies containied in the Local Plan. Paragraph 7.5 and Figure 7.2 describe and show how the Local Plan and NDPs fit together.

 Policy SD25 now includes a clear ‘brownfield first’ approach, alongside other high-level criteria. This is set out as 1(b) and also 2(d) of the policy.

 There is no policy requirement for large farm or whole estate plans, although SD25 has positive regard to them where they exist. Supporting text relating to these has been improved to clarify their status. Separate non-statutory guidelines have been published to support preparation of whole estate and large farm plans, which are straightforward, and do not require an overly burdensome approach.

 Clarification sought on what may be considered “exceptional circumstances” justifying development outside settlement boundaries. Policy SD25 part 2 now clearly sets out these exceptional circumstances.

182

 Criterion 5 relating to small sites on the edge of settlements outside the National Park has been deleted, as has corresponding supporting text. As no sites of this type are now being allocated, it is not considered appropriate to support such sites through the Local Plan.

 Taking account of comments made relating to higher density sometimes being more sustainable and better suited to brownfield, a new criterion 1(c) has now been included in Policy SD25. This requires that development makes efficient and appropriate use of land.

 There is now clear reference in the supporting text to the policy (paragraph 7.10) to the need for robust evidence and full justification for development in the countryside.

 Settlement boundaries have now been amended to include within the boundary all sites being allocated for development (or that part of the site allocation suitable for built development). Settlements in SD25 have now been grouped under the broad areas to which they relate.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Requests for minor clarifications to, or addition Specific changes of a minor nature have not of, wording to improve interpretation of the been addressed as there has been substantial policy and text. redrafting of the policy and text in any case, to improve clarity. Further justification requested regarding the There were two such sites provisionally selection of sites adjacent to settlements allocated in the Preferred Options, at Lancing outside of the National Park, to consider and Seaford. Both of these have now been whether such sites might be better to serve the removed following more detailed investigation, needs of settlements they are adjacent to therefore this comment is now less relevant. If rather than of the SDNPA in general. This point such a site were to come forward post- in particular relates to [the nomination rights adoption and, exceptionally, be considered for] affordable housing. suitable for development, it would need to meet the relevant policy criteria and address local development needs. Consider it important to acknowledge the It is not necessary to repeat national policy. NPPFs support for exceptional quality and innovative design of new dwellings which is classed as a special circumstance for development as set out in paragraph 55. Tightly drawn Settlement Policy Boundaries The rationale for the settlement boundaries is restrict the implementation of the plan which set out in the Settlement Boundary says it allows natural growth within these Methodology paper. Settlement boundaries are settlements. correctly tight around the built-up areas, reflecting the heightened importance of the form and setting of settlements within the National Park. Infill development may still occur within these settlements. Further advice needed for NDPs who are not The Local Plan has been and remains clear that allocating housing in their NDP and where and it is for the Local Plan to allocate an how this will be addressed within the appropriate level of development where an development plan. NDP has not already done this (or is well advanced in the process for doing so).

183

The plan is missing maps for other settlements. There are only maps for those settlements where they are needed to visually represent policies in the Local Plan. It is not for the Policies Map (or Local Plan) to show maps of settlements for general information – there must be at least one policy feature to show. An additional policy is needed which governs There are published guidelines for the the production and review of Whole Estate preparation of Whole Estate Plans, which sit Plans. separately from the Local Plan. Non-inclusion of settlement boundaries for In light of comments made, the list of some settlements that previously had one in a settlement to include was objectively reviewed district-wide Local Plan (e.g. East Worldham, ahead of pre-submission and resulted in the Blackmoor) addition of two further settlements. There is considered to now be a clear and consistent approach. The Development Strategy Background Paper clarifies on this further, with details of the studies considered. Whilst some settlements have been added, this is not the case for East Worldham or Blackmoor. The introduction of WEPs should not prejudice All proposals for change in the National Park against those who are already providing must, by law, conserve and enhance the natural ecosystem service benefits (i.e. support beauty, wildlife and cultural heritage of the area. maintaining those benefits, not just seeking It is therefore in line with Purpose 1 for Whole new/further benefits). Estate Plans to deliver multiple benefits, given Whole Estate Plans are not always necessary they may be used to support development and need to be appropriate to individual proposals that would normally be refused circumstances. They must not be overly because they are outside a settlement complex and burdensome. boundary. There should be further explanation of what This policy criteria has been superseded by one the appropriate use for an existing building is. referencing appropriate use of a previously developed site, excepting residential gardens, and which conserves and enhances the special qualities of the National Park. The test of appropriateness will be site-specific, in terms of contribution to the special qualities. Seek greater clarity of wording to prevent the The loss of agricultural land will be minimal but loss of agricultural land, including reference to is necessary to allow for implementation of the food security and reducing food miles. spatial strategy. Reference to food security etc. would introduce unnecessary detail. Question the exclusion of institutions and Such establishments have not been excluded educational establishments, both often large from the definition of Whole Estate Plans. land owners, from the Whole Estate Plans definition. There should be a change to the wording of It would not be appropriate to remove the clause 4 from “exceptionally considered ‘exceptional’ test even where a development suitable” to “generally considered suitable. proposal is supported by a Whole Estate Plan. This would not be in keeping with the development strategy. Wording added to SD22 to extend principle of Unnecessary, given strategic sites are being development to strategic development sites. positively allocated which clearly establishes the principle of development. The previous tiered approach to settlement Feedback from stakeholders and the public has classification gave much greater indication of indicated that a settlement hierarchy approach suitability for future growth within settlements. is not appropriate given the context of a

184

The differences in scores between the two landscape-led Local Plan. A settlement facilities studies are questioned. scoring approach allows more nuanced balancing of factors in determining levels of growth at settlement level. Concern that there is over reliance on small The development strategy has been tested sites in unsustainable locations rather than on through sustainability appraisal and public large sites in more sustainable locations consultation, and is considered the most appropriate and sustainable strategy. Smaller villages will stagnate and local people The development strategy has been tested will have to move away. Spread development through sustainability appraisal and public more widely, fairly and equally. consultation, and is considered the most appropriate and sustainable strategy. It is not possible to know what will happen in There is no requirement for Whole Estate the future regarding farming, therefore the Plans, although Policy SD25 encourages them. requirement for Whole Estate or farm plans Whole Estate Plans are a positive tool and will must be dropped. draw on standard estate forward planning strategies that are already widely employed.

185

Policy SD23: Housing

Reg 22 (1) (c) (iii) There were a total of 135 comments on this policy. These are summarised below. National Agencies Two National Agencies responded to this policy, Natural England who made comments and Historic England who expressed a strong objection. Their comments are summarised below: Natural England – Although landscape and ecosystem services are considered determining factors, concern was expressed that wildlife and wider biodiversity issues are not mentioned. The plan needs to clearly set out how these factors have been used in determining the location of housing. This includes, but is not limited to statutorily protected sites. This also applies to windfall development which must be required to consider impacts on wildlife and biodiversity. Specific reference must be made to the strict housing quotas around the Wealden Heaths Phase II SPA. Historic England – An objection was raised due to the uncertainty of a great number of allocations still to be determined. What evidence does the authority have that these settlements can accommodate the identified levels of growth without unacceptable harm to the historic or landscape character of each settlement. This is particularly significant in Midhurst, with a larger proportion yet to be identified, but applicable to all settlements where capacity has yet to be identified. Borough, City, County and District Councils Nine Local Authorities commented on this policy. Two expressed support for the Policy, one made an objection. All made comments, which are summarised below:

 Support was received for the overall principle of dispersed growth to support local communities and for setting out clear levels of growth for specific settlements.  The recognition of surrounding settlements and districts and that the National Park does not function in isolation was welcomed The following comments were made:

 Issues of capacity at Kingston and Rodmell, where sites have not been identified, which would lead to questioning whether there is capacity for growth at these settlements.  Capacity for windfall is further restricted due to the reduced Settlement Policy Boundaries (SPBs)  Concern over impact of NDPs not progressing in a timely fashion which would mean the SDLP was left with unmet housing requirements. What contingency is in place if this should happen?  There seems to be little flexibility to respond to changing circumstances which risks that SD23 is unachievable/undeliverable.  The SDLP does not appear to address the unmet housing need generated within the SDNP  There must be clear, robust justification of why the SDNP cannot meet its own Objectively Assessed Need (OAN).SHLA  The SDLP must clearly state both the OAN figure and the total affordable housing need  That the SDLP states that affordable housing is the primary focus for housing delivery, but the level of affordable housing to be delivered in the Plan does is lower than the affordable housing need figure in the SHMA.  Adur, Worthing, Winchester and Waverley stated that they would not be able to meet any additional housing need generated within the National Park. Adur, Worthing and Waverley

186

noted that they were unable to meet their own districts OAN so did not have any further capacity to accommodate further growth.  Unclear as to how the affordable housing need figure has been generated.  Note that the total housing figure is not disaggregated, but taking the requirements and allocation figures the proportion of housing to be delivered within Chichester area accords with the CDC Local Plan figures.  Highlighted the conflict between the requirement for 40% of housing to be affordable, but that SD24 would only apply this to developments of 6 dwellings or more.  Sought clarity on whether housing delivered on exception sites would count towards meeting a settlements requirement figure (as shown in SD23).  The housing data used to support the SHMA will soon be out of date and more up to date information is now available.  Concern over lack of explanation in the Plan of how the requirement for each settlement had been reached  Surprise expressed that the SDNPA have left identifying specific sites until the Publication stage, which risks causing delays to progression of the Plan.  There is a need to underpin the allocations with specific transport modelling, including for key junctions.  As sufficient capacity has yet to be identified in many settlements, the SDNPA cannot demonstrate that they are in compliance with delivery 100 in other villages as required by the East Hampshire JCS.  Noted that there is an error in the affordable housing tenure split (66% and 33%, leaving 1% unaccounted for in paragraph 7.39)  Issues regarding under delivery of agreed housing figures within the East Hampshire part of the National Park, over the lifetime of the JCS.  An objection was raised due to the lack of planning for an ageing population and specifically no allocations for older persons accommodation.

187

Parish and Town Councils 25 Town and Parish Councils/Meetings commented on this policy. 12 supported the policy, whilst 5 objected. All made comments which are summarised below: Support was received from Bury, Corhampton & Meonstoke, Cheriton, Woolbeding with Radford, Twyford, Bepton, Patching, Harting, Selbourne, Lavant Parish Councils and Iford and Warnford Parish Meetings Comments received are summarised below:

 A request that the SDLP still recognises Areas of Special Housing Character (saved policy H9 in the East Hampshire JCS)  Current planning permissions (or applications if approved) should be counted towards meeting the requirements as shown in SD23)  The policy must include specific accommodation which is needed for the elderly, and retirement accommodation.  More is needed to ensure a supply of smaller market and affordable homes, as in policy CP11 of the East Hampshire JCS, which will be lost once the SDLP is adopted.  It is unclear why some settlements have SPBs but no housing requirement.  There should be more development in the settlements of Cheriton (6 is not enough) to sustain the local community and attract/keep young families/economically active population.  Suggest more cross referencing between policies to guide users of the Plan.  Whilst settlements accept that they are suitable locations for growth, it must be acknowledged that the housing requirements in SD23 are not the only development pressures that they face. Many already have approved planning permissions for housing as well as non-residential development and the impacts of development in surrounding areas (particularly felt in areas close to major settlements outside the National Park)  Concern over the large number of settlements where capacity has yet to be identified.  The Local Plan should look at sites of less than five to meet the identified growth levels.  There needs to be the associated infrastructure provided alongside housing to support the growth of Midhurst (150 new units)  The requirement for Sheet should be stated as a maximum, rather than a minimum.  The requirement should be reduced from 8 to 6 dwellings in South Harting, which could be more sustainably accommodated on the allocated site.  Supported the focus on housing to meet local needs, with the focus on affordable housing.  Support was given for the landscape and ecosystem services approaches throughout the Local Plan.  Whilst supporting the text and policy, questions why the level of affordable housing expected is not higher (suggest 60%), given the National Parks stated focus on delivering affordable housing.  The National Park should be encouraging rather than restricting growth in the smaller villages.  The list should also include the 12 dwellings to be delivered in the area of Arundel within the National Park (allocation in the Arundel NDP).  Querying whether the requirement for 11 dwellings in East Dean & Friston includes the planning permission for 10 new dwellings at The Fridays, or is in addition to this.  Additional text needs to be added to clause 6, to include Parish Meetings.

188

Objection

 As no capacity was found in Kingston in the recently examined Lewes JCS, the requirement for Kingston should be removed. Reliance on windfall will also prove difficult given the contraction of the SPB.  Findon Parish Council object to the level of growth allocated to Findon (20 units). This is still felt to be unattainable and should be reduced further.  Itchen Valley Parish Council objected to the allocation of housing to only one settlement within their area. More growth is required and should be distributed more evenly across the parish’s settlements.  Stedham with Iping Parish Council objected to the allocation of affordable homes in Stedham. As neither the Parish Council nor the SDNPA can identify a suitable site, the requirement for 6 additional dwellings should be removed.  Rodmell Parish Council objected to the proposed allocation for 11 new homes in Rodmell.. Since 1997 the housing stock has increased by 17% which is higher than national average and seems inappropriate. They also questioned whether by contracting the SPBs, the SDNPA were trying to direct development outside the boundary, to be delivered as 100% affordable housing sites. If this is the intention then this should be clearly stated.  Clarification was sought as to what constitutes an estate or large farm, and what would be considered ‘appropriate diversification’.

Other Organisations 10 organisations, groups or societies responded to this policy. One gave support for and one objected to the policy. All made comments which are summarised below: Lavant Residents for the Relief Road - Comment made that Lavant could accommodate considerably more growth than currently proposed in SD23, around 100. Support was also given for a relief road around Lavant. CPRE Hampshire – Fully support the provision of housing to meet local needs and that the starting point must be affordable housing. Acknowledged that setting local targets for settlements seemed reasonable. Agreed with the support in the SDLP for Neighbourhood Development Plans allocating sites for housing in their own settlements. Strong support for the allowance for windfall within housing delivery. CPRE Sussex – The SDLP should state that where no sites have been identified for housing within the Plan, that either NDPs or local communities should determine where the housing in their settlement should be built. Will there be an opportunity to cionsider other settlements which have not got a settlement policy boundary or housing requirement in the draft plan. Sustainable settlemtns such as Glynde or Falmer? Fittleworth & District Association – Support was given to the principle of delivering affordable homes, but that the 20 dwelling requirement in SD23 was not high enough to secure sufficient affordable housing for the village, if indeed any at all if sites are very small. Sussex and Hampshire & Isle of Wight Wildlife Trusts (joint response) – Commented that the proposed modest levels of growth may be acceptable as long as they do not compromise the natural capital of the National Park. Highlighted the national issue of reducing household size, leading to an increase in demand from the same size population. As the population continues to grow the demand for housing escalates. Need to address levels of occupancy and models of home ownership, to

189 reduce the need to build more homes. The Plan makes clear that the SHLAA does not include residential gardens, however there is no further mention of protection for residential gardens from future development, which given the landscape led approach adopted in the Plan, would be consistent with Paragraph 53 of the NPPF. Wiggonholt Association – Accepts the overall figure and distribution for development across the National Park, but it is not clear how additional (unmet) need is to be met outside the National Park. Portsmouth Water – requested that they be consulted on development proposals within their water catchment areas. South Downs Society – Support for the overall principles and approach to development across the National Park. Understand the SDNPAs position that they cannot accommodate their full OAN, but urge caution given the Inspectors decision at the recent hearings for the Lewes JCS, who added an additional 1000 dwellings to the overall housing requirement. Objection to the allocation of Old Malling Farm as this goes against National Park Purposes. And concern expressed over requirements for settlements where sites/capacity has not been identified, which could lead to speculative applications from developers, which could jeopardise the National Parks Purposes. Friends of Lewes Society – Whilst there is support for the provision of affordable housing and accept that there will be some market housing required. Strongly object to the requirement for 835 new dwellings in Lewes as this relies on the allocation of Old Malling Farm, an important greenfield site. Brownfield land should be exhausted before any greenfield sites are considered for development. An extensive search for sites should be conducted to find suitable alternatives to Old Malling Farm. Friends of the Earth (Brighton & Hove) – Support the strategic polices with the exception of the requirement of 835 and Lewes as this relies on development at Old Malling Farm, which is an unsuitable greenfield site which should not be developed.

190

Agents and Developers 33 comments were received from developers, landowners and agents. 11 gave support for and10 objected to the policy. All made comments, which are summarised below: Support

 Confirmation was given for several allocations, confirming that they were still available.  Many gave support for the overall approach of dispersed growth to support smaller rural settlements. Comments

 Should be acknowledged that small scale infill development can make a valuable contribution to housing supply without compromising the landscape character of the National Park.  The Policy needs to make reference to the NPPF paragraph 55, which promotes sustainable development in rural areas to support the vitality of rural communities.  The SHMA is not properly referenced in the supporting text and it is not clear how it underpins the figures quoted in the SDLP.  Acknowledgement that the National Park is heavily constrained, which is broadly in line with the NPPF.  The plan underestimates capacity for sustainable growth within the National Park.  Housing requirements seem to be SHLAA led, rather than based on landscape capacity, and the targets then retrofitted.  The generic reasons of “adverse impact on landscape character / historic setting” as explanation for excluding or rejecting a SHLAA site is not robust justification. The Sustainability Appriasal does not provide any further robust justification either.  The policy should acknowledge that institutions, estates and educational facilities may be exceptions where development outside a settlement policy boundary may be acceptable (clause 5).  Many expressed concern over the reliance of the Local Plan on NDPs identifying allocations.  Support was given for the statement that the National Park Authority will allocate land if NDPs have not sufficiently progressed (paragraph 9.4).  The deliverability of allocations is questioned.  The SDNPA should adopt a more positive approach to encouraging housing on Previously Developed Land (brownfield land).  The housing requirements should be re-worded so that they are the minimum of growth expected.  The NPPF still requires all Local Planning Authorities to establish their OAN and then says that the full OAN should only be achieved “as far as it is consistent with the policies set out in this Framework”.  The “other” SHMAs that the SDNPA SHMA is based on, are inconsistent in approach and in the dates that they cover.  The rejection of sustainable sites on the edge of the National Park fails on the grounds of Duty to Cooperate.  Other allocated sites are less sustainable than specific sites on the boundary of the National Park, adjacent to existing sustianbale settlements just outside the National Park boundary.  There is no contingency for non delivery of sites within the Plan  The SHMA does not make it clear how the OAN/affordable housing figures have been reached. Should be clear and easily understandable. What is meant by the phrase “augmented the previous studies” in relation to the bespoke model used by GL Hearn in the SHMA?

191

 There are issues of double counting between overlapping authorities.  What is the authority doing to proactively address the significant undersupply generated within the National Park?  There should be specific recognition of the need for student housing within the National Park.  The assumptions behind the OAN figures are too conservative, resulting in an underestimate of need.  The plan places to great a reliance on windfall, especially given the tightening/removal of Settlement Policy Boundaries.  Specific numbers should not be applied to individual settlements, but rather a focus on high quality design and enhancing/maintaining the National Park. Objection

 The overall housing figure is too low.  Whilst DEFRA Circular 2010 says that the Government doesn’t provide general housing targets for National Parks it is still necessary to establish what the OAN is for the National Park area and then to decide what level or proportion of OAN the NPA proposes to meet and where the unmet balance will go.  From recent statements to the Chichester and Lewes Local Plan Examinations it is clear that other authorities are unable to plan to meet their own OAN and others consider that they have no spare capacity exists to deliver unmet housing need generated within the National Park.  The reference to “low cost market housing” should be removed and replaced with “intermediate housing” to align with The Community Infrastructure (Amendment) Regulations 2014 Reg 7 49a (2a).  Part of the housing delivery figure is made up of 765 dwellings resulting from windfall planning permissions. This figure is based on historical analysis of similar permissions granted in the period 2004 - 2014. The figure takes no account of the proposed changes in settlement boundaries which will reduce the potential for windfall development. For this reason the figure of 765 is flawed.  The SHMA figure for affordable homes need has not been calculated using up to date local authority affordable housing lists. It is an exercise that is not robust and yet it has become the basis of the Plan’s housing requirement. This flawed approach gives no confidence that the conclusion of the SHMA is accurate, nor truly reflective of fostering the social well-being of communities.  The Coastal West Sussex SHMA of 2012. That document is or soon will be out of date and should not be relied upon as sound evidence. Likewise the Chichester District “Housing Requirements Study 2011” by DTZ was based on the 2001 census and the 2009 ONS mid- year census population estimates, which do not reflect the current circumstances.  The SHMA 2015 briefly touches on housing register figures but uses data from various years and is inconsistent. The SHMA is thus not reflective of the current needs.  The tenure split of 66% rent to 33% intermediate leaves 1% of affordable housing unaccounted for. In any event Registered Social Landlords and developers are now working on the basis of a 60/40 split of rent/intermediate tenures.  The SHMA does not sit comfortably with the SHMAs that have been prepared for adjacent districts or the OAN housing numbers they have adopted.  The Plan is providing for 4,596 net new dwellings over 18 years equating to only 255 homes per annum. It is not clear from the information available how the figure of 255 dwellings per annum was derived or whether it is supported by robust evidence and justified.  The period of the Local Plan is to run takes little account of existing adopted plans. In East Hampshire the adopted Joint Core Strategy runs to 2028 and the Preferred Options Plan runs to 2032. But the latter borrows the housing requirement in the former. The Petersfield

192

NDP but makes no provision to cover the missing years. The Preferred Options should explain exactly how it embraces and extends objectively assessed need in pre-existing plans to the end year of 2032.  The housing requirements for settlements in the Local Plan do not match the levels of housing in the recent East Hampshire JCS. Sheet has a figure for a minimum of 100, in the Local Plan it is 20. It is unclear what this change is based on.  Without that explanation the Plan is unsound due to uncertainty.  The Plan has not been positively prepared in the spirit of the NPPF.  The NPPF says that economic, social and environmental gains should be sought jointly, not that one “strand” should be given primacy over the others (environmental in this case).  The Plan is also deficient in not having any means of identifying the shortfall in the National Park's OAN and housing requirement and how that is being taken up by adjacent authorities.  Policy SD23 sets a target to deliver approximately 1,840 affordable homes across the National Park over the period 2014-2032, whilst Policy SD24 sets a target of at least 40% of all net dwellings on schemes of 6 or more units will be provided as affordable homes in perpetuity. The proposed target of 1,840 affordable homes assumes that 40% of all planned housing (4,596 dwellings) will be affordable, whereas Policy SD24 only seeks an affordable contribution on schemes of 6 or more dwellings. There is therefore a mismatch between the two policies.  The settlement housing numbers in policy SD23 have no substance in the inadequate SHMA and appear in many cases to be guess work – for example Amberley, Corhampton, Selborne and others and the striking common use of numbers 6 and 11. There appears to have been no analysis of housing needs in settlements or parishes and how those needs will be met. At the very least, if the Plan is to be considered sound, an analysis of the housing need and potential capacity per settlement is needed.  Leaving unidentified capacity (requirements and allocations) and large reliance on windfall is not a proactive approach to housing delivery.  The suggested housing number for Selborne or any other settlement is not based on any data or analysis and has no sound planning base. In common with all other parish/ settlement numbers no attempt has been made to understand or establish local affordable housing need and relate that to the parish/ settlement and the development potential thereof. The parish/ settlement housing numbers are arbitrary and make little sense in the context of the inadequate Settlement Analysis. The parish/ settlement figures should be based on the size, services and functions of settlements and their capacity to serve lower order/ less sustainable parishes and settlements as provided for in paragraph 55 of the NPPF. Above all the Local Plan should understand what the affordable housing need for each community is and be seeking to maximise the delivery of such homes in conjunction with realistic analysis of the degrees of landscape impact.  Redrawing settlement policy boundaries will leave settlements with very little, if any, opportunity for windfall development.  The changes to settlement policy boundaries and the reliance on windfall development to make up 16.6% of the Park housing requirement is unsound. This is especially so given that the NPA are not discounting existing permissions in its housing supply calculations. It is assuming that 100% of new dwelling planning permissions will be implemented when it has no evidence to demonstrate that that is the case now or will be the case in the future.  The Whilst understanding that housing growth in the National Park will be modest, sustainable settlements that can accommodate more growth should be given higher requirements (e.g. Lavant)  There needs to be sufficient housing supply of the right tenure/size, for young people and to retain/attract enough economically active people.  The Plan does not respond positively to an ageing population.

193

 Proposed allocations in smaller, unsustainable locations should be removed and the 240 (approx.) dwellings, redistributed to the larger settlements of Petersfield, Lewes, Liss, Midhurst and Petworth.  The requirement for Itchen Abbas is inconsistent with other similar or smaller settlements requirements. Settlements which scored lower in the Settlement Facilities Assessment have been given higher requirements.  Specific objection to Swanmore not being included as a sustainable settlement for growth. There is capacity for further housing.  The policy should express the 700 figure for Petersfield as a minimum.  The plan must address housing provision for the elderly.  Housing growth should be focussed on the larger settlements. At the least, the figures for the larger settlements should be expressed as a minimum.

Individuals 32 comments were received from individuals. 9 supported the policy, 18 objections were received, all made comments which are summarised below: Support

 Support for the level of affordable housing growth.  Support for growth in Midhurst, although feel SPB should be widened.  Support for the identification of several settlements as suitable locations for housing growth.  Support for the policy and approach, providing local need can be demonstrated.  As higher density development may not be appropriate within the existing context of settlements, this provides a good opportunity to encourage single storey dwellings, for older persons in particular.  A quantity of affordable housing should also be flocated in the countryside to accommodate workers at or close to retirement, who are leaving tied housing. Comments

 Steyning/Bramber/Beeding should be included within the list of settlements, even though it is acknowledged that they are outside the National Park.  The document needs to be amended in light of the West Berkshire High Court Decision (affordable housing)  Housing should not be within the remit of a National Park.  Insufficient justification of the total housing requirement.  Insufficient justification and explanation of why the National Park is not planning to meet its OAN.  No justification of why SDNPA should seek to meet their OAN through the Duty to Cooperate.  Concern over the SHLAA assessments for sites in/around Petworth. Do not agree with the reasons/assessments given.  The policy must address housing for the elderly  Support for a maximum of 6 dwellings in Cheriton  Although support for several settlements being identified as suitable locations for growth. They can accommodate further growth than currently planned for (Compton, Selbourne, Itchen Abbas, Twyford, Droxford)  The figures for Fernhurst, need to relate to the figures in the NDP.  Non-viability of development should not be a consideration/exception within the National Park. Land costs are not fixed and allowing for this only allows land costs to rise.

194

 The selling of socially rented homes within the National Park should be resisted to ensure ongoing availability of affordable homes. Objections

 There is a mismatch between the requirement for 40% affordable housing and the application of this policy to developments of 6 dwellings or more.  The settlement requirements appear random and not based on local housing need. Question whether local need and settlement capacity have been analysed.  Whilst DEFRA Circular 2010 says that the Government doesn’t provide general housing targets for National Parks it is still necessary to establish what the OAN is for the NP area and then to decide what level or proportion of OAN the NP proposes to meet and where the unmet balance will go.  From recent statements to the Chichester and Lewes Local Plan Examinations it is clear that other authorities are unable to plan to meet their own OAN and others consider that they have no spare capacity exists to deliver unmet housing need generated within the National Park.  The reference to “low cost market housing” should be removed and replaced with “intermediate housing” to align with The Community Infrastructure (Amendment) Regulations 2014 Reg 7 49a (2a).  Part of the housing delivery figure is made up of 765 dwellings resulting from windfall planning permissions. This figure is based on historical analysis of similar permissions granted in the period 2004 - 2014. The figure takes no account of the proposed changes in settlement boundaries which will reduce the potential for windfall development. For this reason the figure of 765 is flawed.  The SHMA figure for affordable homes need has not been calculated using up to date local authority affordable housing lists. It is an exercise that is not robust and yet it has become the basis of the Plan’s housing requirement. This flawed approach gives no confidence that the conclusion of the SHMA is accurate, nor truly reflective of fostering the social well-being of communities.  The Coastal West Sussex SHMA of 2012. That document is or soon will be out of date and should not be relied upon as sound evidence. Likewise the Chichester District “Housing Requirements Study 2011” by DTZ was based on the 2001 census and the 2009 ONS mid- year census population estimates, which do not reflect the current circumstances.  The SHMA 2015 briefly touches on housing register figures but uses data from various years and is inconsistent. The SHMA is thus not reflective of the current needs.  The tenure split of 66% rent to 33% intermediate leaves 1% of affordable housing unaccounted for. In any event Registered Social Landlords and developers are now working on the basis of a 60/40 split of rent/intermediate tenures.  The SHMA does not sit comfortably with the SHMAs that have been prepared for adjacent districts or the OAN housing numbers they have adopted.  The Plan is providing for 4,596 net new dwellings over 18 years equating to only 255 homes per annum. It is not clear from the information available how the figure of 255 dwellings per annum was derived or whether it is supported by robust evidence and justified.  The period of the Local Plan is to run takes little account of existing adopted plans. In East Hampshire the adopted Joint Core Strategy runs to 2028 and the Preferred Options Plan runs to 2032. But the latter borrows the housing requirement in the former. The Petersfield NDP makes no provision to cover the missing years. The Preferred Options should explain exactly how it embraces and extends objectively assessed need in pre-existing plans to the end year of 2032.  The Plan is also deficient in not having any means of identifying the shortfall in the National Park's OAN and housing requirement and how that is being taken up by adjacent authorities.  Policy SD23 sets a target to deliver approximately 1,840 affordable homes across the National Park over the period 2014-2032, whilst Policy SD24 sets a target of at least 40% of

195

all net dwellings on schemes of 6 or more units will be provided as affordable homes in perpetuity. The proposed target of 1,840 affordable homes assumes that 40% of all planned housing (4,596 dwellings) will be affordable, whereas Policy SD24 only seeks an affordable contribution on schemes of 6 or more dwellings. There is therefore a mismatch between the two policies.  The settlement housing numbers in policy SD23 have no substance in the inadequate SHMA and appear in many cases to be guess work – for example Amberley, Corhampton, Selborne and others and the striking common use of numbers 6 and 11. There appears to have been no analysis of housing needs in settlements or parishes and how those needs will be met. At the very least, if the Plan is to be considered sound, an analysis of the housing need and potential capacity per settlement is needed.  Leaving unidentified capacity (requirements and allocations) and large reliance on windfall is not a proactive approach to housing delivery.  The suggested housing number for Selborne or any other settlement is not based on any data or analysis and has no sound planning base. In common with all other parish/ settlement numbers no attempt has been made to understand or establish local affordable housing need and relate that to the parish/ settlement and the development potential thereof. The parish/ settlement housing numbers are arbitrary and make little sense in the context of the inadequate Settlement Analysis. The parish/ settlement figures should be based on the size, services and functions of settlements and their capacity to serve lower order/ less sustainable parishes and settlements as provided for in paragraph 55 of the NPPF. Above all the Local Plan should understand what the affordable housing need for each community is and be seeking to maximise the delivery of such homes in conjunction with realistic analysis of the degrees of landscape impact.  Redrawing settlement policy boundaries will leave settlements with very little, if any, opportunity for windfall development.  The changes to settlement policy boundaries and the reliance on windfall development to make up 16.6% of the Park housing requirement is unsound. This is especially so given that the NPA are not discounting existing permissions in its housing supply calculations. It is assuming that 100% of new dwelling planning permissions will be implemented when it has no evidence to demonstrate that that is the case now or will be the case in the future.  Whilst understanding that housing growth in the National Park will be modest, there needs to be sufficient housing supply of the right tenure/size, for young people and to retain/attract enough economically active people.  The reliance on windfalls without identifying allocations/requirements puts the plan at risk.  There is no flexibility within the plan for local communities to bring forward housing to meet local needs / community led developments.  Querying why sites which respondent consider suitable, have not been allocated to meet the requirement for Corhampton and Meonstoke.  The policy lacks clarity on the type, size and tenure mix of dwellings in individual settlements.  The policy doesn’t reference viability considerations  The policy is not compliant with paragraphs 173 and 174 of the NPPF.  The consultation is invalid due to non-publication of the SHMA.  Both Petersfiled and Liss can accommodate more growth than proposed in draft plan.

196

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Natural England were concerned that the Local Plan be explicit in the need to consider statutorily protected sites, wildlife and biodiversity in determining the location of housing. This has been more fully and explicitly stated in other policies, namely Policy Strategic Policy SD9: Biodiversity and Geodiversity, and Strategic Policy SD10: International Sites. The housing provisions take full account of impacts on designated sites, as set out in relevant background papers.

 Historic England were highly concerned that housing provision was made for settlements without sufficient capacity having been identified for these new homes, and asked whether development can be accommodated without unacceptable harm to character and setting. This has been resolved through working through the detail of sites’ landscape sensitivities in preparing the SHLAA, and these landscape assessments, which take into account historic landscape character, are published in summary form the SHLAA 2016. All settlement housing provisions are now met through the allocation of specific sites.

 Kingston and Rodmell housing provisions have been reassessed in light of site specific assessments. A site is identified in Kingston for 10-12 dwellings. No suitable site could be identified in Rodmell, therefore Rodmell is no longer required in the Local Plan to make provision for housing other than suitable, as-yet unidentified windfall.

 Concern over policy vacuum with regards housing supply is addressed through inclusion of paragraph 1.40 in the introduction to the Local Plan, which clarifies that additional DPDs will be take forward if NDPs have not sufficiently progressed.

 Concern over lack of flexibility in Policy SD23 has been addressed by substantial rewording of the policy, which strikes the right balance between providing certainty to communities and developers, whilst being flexible with respect to numbers stated. This is demonstrated by the numbers being stated as approximate.

 Whilst the Local Plan does not fully address the full unmet housing need within its own strategy (as the plan is capacity-driven), there is significantly more explanation now added throughout the Local Plan setting out Duty to Cooperate arrangements to address the unmet need as far as possible. Additional text has been added under the Spatial Strategy to more clearly justify why the full need cannot be met (paragraphs 3.114 to 3.128). The Interim Duty to Cooperate Statement published alongside the pre-submission Local Plan provides further detail.

 The affordable housing need is clearly referenced to the HEDNA 2017 in the supporting text.

 The proportion of affordable housing from market developments is acknowledge to not meet the full affordable housing need. However Policy SD28 now seeks affordable housing from sites of 3 or more homes, thereby reducing the gap between the need and units delivered.

 There is now clearer explanation as to how the housing provision numbers were arrived at (paragraph 7.24). The detailed methodology is given in the relevant background paper.

 Transport modelling has been undertaken to test the impact of additional traffic arising from growth on road junctions. This shows that the level of growth proposed is appropriate, when considered against general background growth in traffic.

197

 The allocation of sites makes provision for approximately 151 new homes in the East Hampshire part of the National Park, which is significantly greater than the 100 homes provided for in the Joint Core Strategy. This will deliver a greater supply of housing than previously seen in this part of the National Park.

 There is no site-specific provision or allocation for older person’s accommodation, however Policy SD27 includes a new policy clause that seeks the provision of homes suitable for older people on sites of 5 or more dwellings.

 Comments made regarding housing types to meet need, and in particular, the need for sufficient supply of sizes and tenures for young people and to retain/attract enough economically active people. To ensure a supply of smaller homes as part of a mix of dwelling types to meet different needs, Policy SD27 – Mix of homes has been introduced into the Local Plan. The Local Plan also seeks to maximise affordable housing.

 The Cheriton provision is now for 14 homes rather than the 6 homes stated in the Preferred Options.

 Concerns over the need for associated infrastructure for Midhurst (and other locations) has been recognised in transport technical work. Policy SD42 Infrastructure has been significantly strengthened and improved.

 The provision of 11 homes at Rodmell has now been removed, reflecting that there are no suitable sites for delivering these homes.

 Suggested that where no sites had been identified in the Preferred Options for a settlement’s housing provision, NDPs and local communities should determine the sites. Text supporting NDPs determining sites is supported in the Local Plan (provided that the NDPs are of a sufficiently advanced stage), and there is further flexibility for NDPs allowed for in part 4 of the policy, which allows NDPs to identify additional sites/capacity within settlements thus exceeding the local plan provisions.

 Comments made by Sussex and HIOW Wildlife trust have been addressed as follows. Reductions in household size is a national issue, and cannot reasonably be addressed by local plans, which are required by national guidance to recognise changing population and household patterns and respond positively. However Policy SD27: Mix of homes seeks to provide a mix of dwelling sixes to reflect changing needs, for example provision of predominantly smaller homes which facilitates downsizing. Policy SD25 addresses pressure on residential gardens by clarifying that they will be treated in the same way as greenfield/open countryside.

 There is more explanation in the introduction to the Local Plan relating to the Duty to Cooperate as the main mechanism for meeting unmet need.

 Comments made by the South Downs Society are addressed as follows. Regarding pressure to meet full objectively assessed needs (OAN), it is very widely acknowledged that National Parks should not be expected to meet full OAN, but instead focus on meeting local needs and delivering affordable housing. This is different to the situation in Lewes and the Lewes JCS, as much of Lewes district is outside of the National Park, and there are significant opportunities presented by the town of Lewes. It should be noted that the full housing provision anticipated from individual settlements is now on identified allocated sites.

 More clear acknowledgement of the role of windfall development (i.e. small-scale infill).

198

 Comments made that the way figures have been apportioned to the settlements is arbitrary and/or entirely SHLAA-led, rather than based on proper analysis of the settlements’ capacities or to properly address local affordable housing needs. Whilst this is not accepted, the figures have been refined to reflect the considerations set out in paragraphs 7.26 and 7.27. With regards affordable housing need, the strategy recognises that all settlements within the National Park have such a need to some or another extent, and the allocation of appropriate sites based on landscape capacity helps to address this. Further detail is found in the relevant background paper.

 Some have commented that the SHMA, which provides key evidence on objectively assessed need (OAN), is based on out of date base data, and that it relies on other SHMAs (e.g. Coastal West Sussex) that are based on a different time horizon. SDNPA has now produced a Housing and Economic Development Needs Assessment (HEDNA) which uses the most recent releases of CLG household projections and ONS mid-year population estimates. The SHMA/HEDNA uses a bespoke model applied to the SDNPA and is not reliant on other SHMAs. The relationship of the HEDNA to the Spatial Strategy is explained in the Spatial Strategy section (paragraphs 3.114- 3.123).

 Referenced to ‘low-cost housing’ have been removed and reference instead made to ‘affordable rented tenures’ and ‘intermediate tenures’.

 It has been commented that the affordable housing target was based on 40% of the entire housing target, whereas an affordable housing requirement was only applied to sites of 6 or more homes. The affordable housing target figure has been removed from the Local Plan as the clear objective is now to maximise delivery of affordable housing on all sites.

 Concern over lack of clarity in relation to how overall housing target has been arrived at. Supporting text has been improved, and a background paper has been prepared to explain the history and process followed.

 A comment was made that figures in SD23 need to relate to NDP figures. Figures in SD23 align with made NDPs where relevant, reflecting the sites allocated in the relevant NDP. Strategic housing allocations are also added.

199

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Capacity for windfall considered optimistic The windfall assumption has already been given more tightly drawn settlement discounted compared with historic levels, to boundaries. take account of National Park status and more tightly drawn settlement boundaries. The level of affordable housing to be delivered Given the very high level of affordable housing in the Local Plan is lower than the affordable need in the National Park, the Local Plan cannot housing need figure in the SHMA. meet the whole need whilst remaining deliverable. However the policies seek to maximise affordable housing delivery, for example on smaller sites. Clarity sought on whether housing delivered on Policy SD26 makes housing provision for the rural exception sites count towards meeting a settlements based on the sites allocated, and settlement’s requirement. their capacity for housing. These numbers do not therefore include rural exception sites. This is clear in the policy. Local Plan should recognise Areas of Special Policy SD4 – Landscape, and Policy SD5 – Housing Character Design provide a strong framework for upholding local character including housing. Current planning permissions, and applications The baseline for counting extant permissions if approved, should count towards the SD23 towards SD26 settlement-specific housing figures. provisions is 1st April 2015. If permission has been granted before that date, they will have been counted as ‘commitments’ and do not count toward SD26 numbers. Permissions granted on or after this date may count but only if relating to a site of 5 or more dwellings (as less than 5 dwellings are counted as ‘windfall’ development). It is important to apply this consistently to ensure clarity and certainty across all settlements. Unclear why some settlements have settlement Settlements have necessarily tight settlement policy boundaries but no housing requirement. boundaries to ensure that the special qualities of the National Park are upheld. The boundary only includes site allocations where these can be successfully integrated into the landscape. Where there are no sites allocated, there can be no housing provision. However there may be infill opportunities for small schemes within the settlement boundaries, therefor some settlements have a boundary but no specific housing provision. Should be better acknowledgement of It is agreed that these exist, but it is not development pressures other than those set necessary to detail these in SD26 supporting out in the Local Plan. text. The sustainability appraisal and other technical background work has considered cumulative impacts of development.

200

The Local Plan should look at sites of less than 5 It is not feasible to allocate large numbers of to meet identified growth levels. very small sites. This would be unmanageable in strategic plan-making terms, and counter to best practice guidance. Request for settlement provisions to be treated The settlement provisions are approximate, as a maximum not a minimum. which is appropriate to ensure flexibility. Treating them as maxima would run the risk of a significant undersupply of housing overall. Reduce South Harting provision from 8 to 6 South Harting is a large village with good dwellings. services and facilities, and suitable sites. The South Harting provision is now set at approximately 14 dwellings. The National Park should be encouraging not It would not be appropriate to allocate housing restricting small village growth. sites in or near every small village, as this would most likely encourage less sustainable living, and would do less to sustain village services and facilities where they already exist. It would also be inappropriate in landscape terms. Local Plan should include 12 dwellings in The dwellings allocated in Arundel NDP in the Arundel NDP. South Downs are to have occupancy conditions that preclude them from meeting the Local Plan’s objectives. They are therefore excluded. Lewes JCS found no capacity in Kingston A suitable housing site has now been found to therefore housing provision should be accommodate approximately 11 homes. removed. Object to the 20 dwelling provision for Findon. Consideration of sites and the capacity of This should be reduced. Findon to accommodate some modest growth on two allocated sites, has led to the provision being 30 dwellings. Object to growth in Itchen Valley parish being It is not considered feasible nor sustainable to restricted to just one settlement. More growth distribute the housing too sparsely. is required and should be spread across the parish’s settlements. The provision of 6 homes in Stedham and Iping The Local Plan now states that 18 homes are to should be removed. be provided in Stedham, reflecting that there is now a suitable site for mixed housing and employment development that has capacity for this scale of development. Comment submitted that Lavant is capable of Lavant has a provision in the local plan for 20 accommodating approximately 100 new homes. However the Lavant NDP is understood homes. to be proposing significantly more than 20. This is allowed for in Policy SD26 (part 4). The 20 dwelling requirement for Fittleworth The Preferred Options figure for Fittleworth may not be enough to provide affordable was 6 dwellings not 20. This provision has been housing for the village. carried through to the final Local Plan, which is considered appropriate for the settlement which is small in size with limited facilities. Object to provision of 835 new dwellings for The 835 figure incorporating Old Malling Farm Lewes town as this relies on the allocation of was considered at length during the JCS Old Malling Farm. Brownfield sites should be examination and found appropriate, and, subject to the further Habitats Regulations

201 considered and exhausted ahead of any Assessment work, there has been no further greenfield allocation. evidence to suggest the approach is not the correct one. Further brownfield site are bing considered in detail by the Lewes NDP, but there is only likely to be enough brownfield land to meet a portion of the Lewes requirement. The capacity of the rural area of the National The Local Plan already positively promotes an Park has been underestimated. NPPF paragraph appropriate level of development to sustain 55 promotes sustainable development in rural rural communities. However this has to be areas. balanced with the environmental and landscape capacity. Educational institutions outside settlement There is no reason why educational sites boundaries may be exceptional cases suited to outside settlement boundaries should be accommodating development. treated differently to other similarly located employment uses with regards alternative uses. There is over-reliance on NDPs delivering the An important part of the strategy is giving SDNP’s housing. opportunity for community-led planning. Paragraph 1.40 ensures that there will be no ‘policy vacuums’ in this respect. Housing requirements should be given as This would be inappropriate for the National minima. Park as the figures are capacity-based. Sites within the SDNP but on the edges of Draft allocations were considered at Seaford settlements just outside the SDNP should have and Lancing, but both have subsequently been been considered as these are likely to be more found unsuitable/undeliverable. The focus is in sustainable. any case on meeting the local needs of communities living within the SDNP, and settlements within the SDNP are therefore generally more sustainable with regards this objective. There is no contingency in the event of sites SDNPA has worked to positively identify sites to not being delivered. fulfil the development strategy in the context of a national park, and these are fully expected to come forward. The potential supply of sites (housing trajectory) is greater than the overall Plan target therefore the Plan has built-in contingency. SHMA affordable housing need estimate is Affordable housing need estimate is based on a flawed as it is not based on housing registers. number of factors, including backlog of need, new household formation, and future population increase. This is fully explained in the HEDNA. Concern that SDLP period does not align with The development plan process is dynamic so it other plans e.g. East Hampshire JCS and is unlikely there will ever be perfect alignment. Petersfield Neighbourhood Plan. As the development plan within the South Downs is capacity-based, this is not a critical factor. The settlement specific housing provisions It would not be realistic to base the figures only should be based on the affordable housing on the affordable housing need, given the need need. to have a deliverable strategy, the inevitable fluctuations in localised affordable housing

202

need over time, and reliance on market housing coming forward to cross-subsidise affordable housing provision on many sites. A discount should have been applied to Given the National Park status setting an permitted sites when calculating housing overall presumption for upholding the National supply. Park’s purposes over delivering development, it has been judged as unlikely that permitted sites will fail to come forward in future. Smaller settlement apportionments should be The spatial strategy is for a medium level of redistributed to larger settlements e.g. growth dispersed across the National Park. The Petersfield, Lewes, Midhurst and Petworth. alternative suggested was tested through sustainability appraisal and found to be less sustainable, chiefly due to landscape impacts. Settlement facilities scores point to a different The Settlement Facilities Study was only one distribution of housing locations, to steer piece of evidence, and has to be considered development to more sustainable locations. alongside landscape context and availability of sites. Swanmore should not have been excluded from Swanmore is just outside the National Park and being a sustainable settlement, as it has was therefore not considered in the settlement capacity to accommodate further development. facilities study. The development strategy is focused on meeting the local needs of communities within the SDNP. Comments disagreeing with site specific SHLAA The SHLAA has been updated since Preferred assessments Options consultation. However as SHLAA is a technical and independently conducted exercise, consultation responses have not led to changes in the SHLAA unless relating to a factual inaccuracy. However evidence arising from consultation and engagement on sites has been considered as additional and important evidence informing the allocation of sites. Non-viability should not be considered in the Viability has been carefully considered to Local Plan as this only allows land costs to rise. comply with national guidance and ensure policies can be delivered. The selling of social rented homes should be This is not strictly a planning matter given the resisted. Right to Buy. However the draft Local Plan already referred to affordable housing to be provided in perpetuity (this may not always be achievable where the Right to Buy exists). Sites considered suitable by respondents in Sites have been allocated to make provision in Corhampton and Meonstoke have not been accordance with Policy SD25, and in a way that allocated. does not compromise landscape or otherwise conflict with the special qualities of the National Park. Policy lacks clarity on type, size and tenure mix The appropriate way of establishing locally in individual settlements. appropriate housing mixes is through a neighbourhood plan. Otherwise it is appropriate to apply a universal policy approach based on an overall assessment of needs. New Policy SD27 – Mix of homes provides this high level policy.

203

Policy SD24: Affordable Housing

Reg 22 (1) (c) (iii) There were a total of 58 comments on this policy. These are summarised below. National Agencies None Borough, City, County and District Councils Various District Councils felt that the policy should be reviewed following national threshold rules changing. Various District Councils felt that the policy should apply to “gross” increase in housing rather than “net” (various District Councils). Winchester City Council asked what is meaning of “at least 40%”. Chichester District Council suggested various edits relating to national policy changes . Wealden and East Hants District Councils queried the implementation mechanism and ability of SDNPA to manage allocations. Parish and Town Councils General with some queries about the implementation. Strong support for the principle of ensuring local connection but some confusion about the criteria. Various Parish Councils raised concerns that pooling commuted sums (to be spent in other locations) will lose benefit to original parish. Threshold issues identified by various councils and requests for clarification of some of the policy criteria which has been incorporated. Various Parish Councils raised concerns about the risks of the Right to Buy initiative to affordable housing in perpetuity. It should be specified that affordable housing has to be provided on site.

204

Other Organisations CPRE Hants expressed a need to ensure viability appraisals are robust, and support for CLT as a delivery vehicle. Various organisations supported for measures that enhance affordable housing provision and further threshold policy change advice. Various organisations rasied concerns about the risks of the Right to Buy initiative to affordable housing in perpetuity.

Agents and Developers General criticism of “at least 40%” requirement because of viability and its interpretation, especially on smaller sites. Goodwood Estate feel that flexibility is needed for estate housing. Thakeham Homes commented that the Local Plan is unsound as it does not meet NPPF Objectively Assessed Need. Individuals Requirements should be 50% affordable housing and have higher sustainability requirements. Confirmation that low cost market housing, starter homes and self-build are not currently in the NPPF definition of affordable housing. Suggestion that Para 7.65 dependence on Registered Providers will give developers an excuse not to provide housing when there are alternative delivery vehicles.

 The document needs to be amended in light of the West Berkshire High Court Decision (affordable housing)

205

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The policy has been comprehensively reviewed. The review took account new evidence, in particular a more detailed Whole Plan Viability Study, and a detailed review of the outcome of the Court of Appeal judgement relating to nationally set threshold for affordable housing planning obligations.  The policy has now been amended to refer to gross capacity to provide X number of homes (not net). It also refers to a “minimum” proportion of homes to be affordable.  The cascade has been reviewed to only seek affordable housing on the development site itself, or a financial contribution in lieu if this is not achievable.  Supporting text relating to local connection conditions has been re-examined and now clarifies that local connections will be assessed in a cascade manner to relate to as local an area as possible, and that local connections will be determined by the Authority, parish council and relevant housing authority to have regard to the relevant local housing register allocations policy.  In response to concerns that affordable housing remains as such in the face of the Right to Buy policy, the policy has been clarified to state that where feasible, affordable housing will remain in perpetuity. Whilst there are limits to the amount of influence planning decisions have on this aspect, in reality many housing associations use the discretion afforded to them to not accept the Right to Buy.  The policy and supporting text are now stronger in requiring on-site delivery of affordable housing (rather than off-site or financial contribution), with the exception of sites of 3 dwellings for which a financial contribution is appropriate in viability terms.  Supporting text in relation to viability appraisal is much strengthened, to ensure that these are robust.  A number of representations expressed that the SDNPA should be seeking a higher proportion of affordable housing (e.g. 50%). The headline minimum requirement (for sites of 11 or more homes) has been increased from 40% to 50%, which is supported by viability evidence.

206

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason SDNPA should top-up viability with S106 It would not be appropriate to include such a commuted sums held. mechanism in the local plan, as it would undermine the influence of planning policy on land value expectations (by leading the market to expect public subsidy towards affordable housing provision on market-led sites). Concern that commuted sums will be spent Commuted sums in lieu of on-site provision will outside of the parish. only exceptionally be accepted (except for sites of 3 dwellings gross). Guidance will be produced in due course to supplement the local plan policy, which clarifies how this money will be spent. Registered providers work on a tenure split of The tenure split in Policy SD28 is based on the 60% rented, 40% intermediate when delivering evidence of need contained in the SHMA. affordable housing schemes. Question appropriateness of requiring “at least It is appropriate to require a minimum 40%” affordable housing, because of viability proportion of homes as affordable to provide and its interpretation, especially on smaller clarity to users of the policy. There are sites. flexibilities within the policy to allow for viability barriers. Should confirm that low cost market housing, The SDNPA takes a flexible approach to what starter homes and self-build are not currently counts as affordable housing, albeit the policy in the NPPF definition of affordable housing. makes clear that the majority of affordable housing should be rented affordable tenures. Guidance to be produced in due course to support the policy will provide detailed guidance on this matter.

207

Policy SD25: Rural Exception Sites

Reg 22 (1) (c) (iii) There were a total of 40 comments on this policy. These are summarised below. National Agencies The National Trust commented that open market housing should be allowed on Rural Exception Sites to support viability, as allowed by NPPF paragraph 54 . Borough, City, County and District Councils (Hampshire County Council ask for clarification on “site specific sustainability appraisal process”. (East Hants District Council and Winchester) comment that open market housing should be allowed on Rural Exception Sites to support viability, as allowed by NPPF paragraph 54. Chichester District Council state that open market housing should not be allowed on Rural Exception Sites, and S106 commuted sums should be used to top-up viability . Parish and Town Councils General support for this policy by overwhelming majority of Parish Councils including endorsement from existing successful schemes. One objection from East Dean & Friston Parish Council, stating it does not give the local community enough discretion over housing types. Several requests for clarification of terms and concern about risks from Right to Buy. Other Organisations General support for this policy. Open market housing should be allowed on Rural Exception Sites for local people (CPRE Hants). Agents and Developers Starter Homes should be allowed on Rural Exception Sites as allowed in Government’s Rural Productivity Plan (Leconfield Estate)

208

Individuals Open market housing should be allowed on Rural Exception Sites to support viability, as allowed by NPPF paragraph 54 (multiple individuals). Suggestion that rural exception sites should only be allowed on employment grounds if the employer doesn’t own market housing in the settlement. Clarification requested for some terms and criteria. Concerns about protecting affordable housing “in perpetuity”. Suggestion that the rent levels of affordable housing should be based on local income and not market prices.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The clarity of requiring “site specific sustainability appraisal process” was questioned. The wording has been changed to refer to “the most suitable available site in terms of landscape, ecosystem services and overall sustainability.”  An objection was received stating that the policy does not give the local community enough discretion over housing types. Part 2 of the policy has improved wording to make clear that the sizes, types and tenures of dwellings proposed will be based on robust up-to-date evidence of communities’ needs, whilst part 1(d) requires that effective community engagement has fed into the design, layout and types of dwellings proposed.  Concerns raised regarding risks from Right to Buy for availability of affordable housing in perpetuity. Whilst such risks are unavoidable, the policy has been worded to clearly state that affordable housing on rural exception sites should be provided in perpetuity.  Request that starter homes should be allowed for on Rural Exception Sites is allowed for as the policy is flexible on affordable housing tenures, provided that it is a local need that is being met.

209

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Open market housing should be allowed on The NPPF states that local planning authorities rural exception sites to support viability, as should consider whether allowing some market allowed by NPPF paragraph 54. housing on rural exception sites would facilitate the provision of significant additional affordable housing to meet local needs. However in the context of a national park, this must be read alongside the Vision and Circular which states Government’s expectation that new housing will be focused on meeting affordable housing requirements, supporting local employment opportunities and key services. In the case of rural exception sites, the value of land will be low (i.e. agricultural land value) as there is no expectation that the site is suitable for housing. Therefore 100% affordable housing will be viable in most cases, and delivery as such to meet priority local housing needs will be appropriate. This approach is supported by the Whole Plan Viability Assessment. Rent levels of affordable housing should be Whilst supporting text to Policy SD28: based on local income and not market prices. Affordable Housing states a strong preference for social rented housing, Policy SD29: Rural Exception Sites is focused on meeting local needs through appropriate tenures. All Local Plan policies must take account of Government definitions of affordable housing, which have moved towards pegging rent levels to market rents rather than incomes. Unclear how allocations policy will work with There should be no conflict provided that Choice Based Lettings and HCA funding allocations policy set by the local housing conditions. authority continues to prioritise local need and local connections.

210

Preferred Options Policy SD26: Gypsies and Travellers and Travelling Showpeople Corresponding to Pre-Submission Policy SD33

Reg 22 (1) (c) (iii) There were a total of 18 comments on this policy. These are summarised below. National Agencies The Environment Agency supported the recognition within the policy of foul water drainage infrastructure and Historic England supported the refusal of permission for proposals that would have an unacceptable adverse impact on the National Park. Borough, City, County and District Councils

 Lewes District Council are concerned that no sites have been allocated for Gypsy and Traveller use within the National Park and stress the need for the SDNPA to make every effort to identify and allocate sites.  Brighton & Hove City Council support the need to identify sites to meet the needs of Gypsies and Travellers and look forward to progressing with the joint site assessment work with the SDNPA.  Winchester District Council seek some clarification in terms of the policies map (yet to be published) and the tables of figures listed in the supporting text. They also refer (as do others) to the need to update the policy in line with the new Planning Policy for Travellers Sites (2015).  East Hampshire District Council considers that the policy is not sufficiently proactive in identifying sites for allocation.

Parish and Town Councils

 Bury Parish Council support the policy in principle but comment that many claims of traveller status do not stand up to scrutiny and local evidence should be sought. They wish to be alerted to impending controversial applications and consulted closely during the processing of an application. They also ask that the results of the “call for sites” be published so that they are able to provide further evidence. Finally they wish to see the proposed criteria in the policy strongly enforced.  Itchen Parish Council do not support both the provision of sites within the National Park for Gypsies and Travellers nor the number of sites proposed. They consider that the current legal framework does not support local communities or landowners who suffer the consequences of poorly managed sites and illegal encampments and they believe that the housing needs of this group must be accommodated outside the park area.  Selbourne Parish Council suggest replacing "unacceptable adverse impact" with "cause harm". They report that the Government has recently said that national parks are now exempt from having to have a 5 year land supply for Gypsies and Travellers and consider the policy needs updating accordingly.  Bramshott and Liphook Parish Council suggest the policy should make reference to the potential impact of development proposals on designated sites.

211

Other Organisations CPRE Hampshire note the need to update the policy and supporting text in line with the new Planning Policy for Travellers Sites 2015. The Gilbert White Museum highlights a lack of key to the map and Friends of the Earth Brighton & Hove make a number of small suggestions to the detailed text of the policy. Southern Water welcomes recognition that sites should be capable of providing essential services, such as water supply and wastewater disposal. They also welcome recognition within the supporting text that neighbouring land uses should be appropriate and not have a significant impact on the amenity of future occupants of sites. They suggest additional criteria to the policy to reflect this position.

Ricardo plc consider this an issue to be addressed at a sub-regional level. Agents and Developers No comments received. Individuals Two individuals responded. One noted that there has been some abuse of the system by some parts of this community and that the current legal framework does not support local communities or landowners who suffer the consequences. They believe that provision of space for Gypsies and Travellers will lead to legal expenses for the National Park Authority and that the housing needs of this group must be carefully considered and accommodated by the local authority outside the park area. One noted the need to take into account the revised Planning Policy for Traveller Sites 2015. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 General re-write of policy to make it shorter, remove repetition with other policies in the Local Plan and make it more positively worded.  Criteria added to require a local need for pitches to be identified in support of any application for sites not allocated.  The lack of allocated sites in the Preferred Options Local Plan was a concern to a number of Local Authorities. This has now been addressed insofar as it can by the allocation of sites within the Local Plan and the identification of the number of pitches expected to be delivered. This has also enabled the level of unmet need to be calculated which forms the basis of discussions with Authorities through the duty to cooperate.  The joint site assessment work with Brighton & Hove City Council has been completed.  References to PPTS12 replaced with PPTS15.  Criteria f added in response to Southern Water request for the amenity of occupiers and their neighbours to be considered.

212

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason The National Park is not a suitable location for The under-provision of sites in the National sites for Gypsies and Travellers, they should be Park is a matter that is addressed insofar as accommodated outside of the Authority area. possible with other Authorities through the preparation of joint evidence and the duty to cooperate. This is a sub-regional issue, sites outside of but The GTAA and the site assessments have been close to the National Park are not considered. undertaken jointly with appropriate neighbouring authorities. This has enabled a cross boundary approach to be taken from the outset. National Parks exempt from needing a 5 year PPTS15 states that if a local planning authority supply cannot demonstrate an up–to-date 5 year supply of deliverable sites, this should be a significant material consideration in any subsequent planning decision when considering applications for the grant of temporary planning permission. The exception is where the proposal is on land designated as Green Belt; sites protected under the Birds and Habitats Directives and / or sites designated as Sites of Special Scientific Interest; Local Green Space, an Area of Outstanding Natural Beauty, or within a National Park (or the Broads). This does not however mean that the National Park is exempt from making provision where it is appropriate to do so. Reference to impact on designated sites Not needed, covered in other policies in the plan.

213

Policy SD27: Sustaining the Rural Economy (Policy SD34 in the Pre-Submission Version)

Reg 22 (1) (c) (iii) There were a total of 45 comments on this policy. These are summarised below. National Agencies Historic England supports policy SD27(2). Borough, City, County and District Councils Lewes District Council supported SD27 and SD28 as they will help to achieve the district council’s priorities and aspirations. Winchester District Council questioned that there was no reference to change of use applications for large commercial or institutional buildings. East Hampshire sought clarification on what ‘other relevant policies’ were, was supportive of green businesses but not at the expense of other business types and sought clarification on what constitutes an unacceptable adverse impact.’ Brighton & Hove City Council supported the approach to meet the objectively assessed needs for employment.

Parish and Town Councils Buriton, Bury, Patching Parish Councils supported SD27. Woolbeding and Reford Parish Council support SD27 with a change to remove the policy caveat on home working. Twyford Parish Council objected to SD27 on the grounds that Criteria 1(b) to (f) do not apply in national parks. They also requested a narrow definition of ‘smart economic growth’ and a definition of what is a rural business.

Bepton Parish Council supported SD27 with the comment that more needs to be done to improve broadband coverage in rural areas.

Harting Parish Council, Rowlands Castle Parish Council and Iford Parish Meeting commented on the importance of superfast broadband and connectivity.

Madehurst Parish Meeting supported SD27 and welcome efforts to improve rural broadband.

Selborne Parish Council supported SD27 with changes that the socio economic duty is in pursuit of the purposes (para 7.104) and that farming should be referenced as a key sector in SD271a.

Arundel Town Council thought that the second criterion of policy SD27 was unnecessary and should be deleted.

214

Other Organisations Farm Operation objected to SD27 on the grounds that it should protect all businesses and not just those that are small and green. CPRE Hampshire sought clarification that the National Park’s duty is in pursuit of the purposes and thought that SD271(a) should include farming.

CPRE Sussex supported reference to superfast broadband and sought clarity required on whether all criteria apply to an application.

Friends of the Earth Brighton & Hove supported SD27 but commented that the word ‘unacceptable’ should be deleted in SD27(2).

The South Downs Society supported SD27 particularly the commitment to small businesses, home working and superfast broadband. However, they thought that SD27 fails the statutory duty of national parks by not recognising the importance of other economic enterprises particularly in the market towns such as car repairs and joiner. This was originally raised as an objection to Lewes being included in the National Park.

The South Downs Land Managers Group supported SD27 with the following changes. Agriculture should be referenced under SD27(1)a. Support for rural supply chains welcomed but it should be referenced that they extend beyond the National Park. Positive encouragement for development on brownfield land and former agricultural units which are defined as greenfield. Welcome support for superfast broadband. Additional clause on protecting rural businesses and building resilience required.

NFU South East commented that SD27 overlooks the need to provide support for existing established farm businesses, particularly where these provide existing employment and deliver existing appropriate land management activity. Existing farm and food production businesses must have the ability to expand and adapt to be able to increase productive output over longer periods of the year. In many cases it is only through a continuous programme of expansion and modernisation that farms are able to retain their position in the marketplace. The viability of many rural enterprises, and the continuity of the jobs they provide, depends on this. They suggested detailed policy wording. Ricardo plc commented that the plan was weak on economic impact and should include details on the size and type of businesses in the National Park.

The National Trust supported policy SD27.

EM Horn & Sons supported SD27 with the following changes. The policy should be expanded to support all existing enterprises to secure future resilience and protect existing rural jobs. Support the need for superfast broadband.

215

Agents and Developers Goodwood Estate commented that this plan should not perpetuate past policies that created problems of rural housing and jobs and suggested that the role of estates in the long term stewardship of land should be acknowledged. Folkington Estate commented that farming should be referenced as a small business (para 7.119). West Dean - The Edward James Foundation commented that SD27 should reference estates that make a substantial contribution to the rural economy. The Sompting Estate supported SD27 with the following changes that farming should be referenced as a key sector in SD271a. Support for rural supply chains welcomed but it should be referenced that they extend beyond the National Park.

CLA supported SD27 with the following changes. SD271(a) should include farming. There should be positive encouragement for development on brownfield land and former agricultural units which are defined as greenfield. They stressed the importance of superfast broadband to farming and the need for the NPA to permit related infrastructure.

The Leconfield Estate commented that SD27 should reference estates that make a substantial contribution to the rural economy. Individuals The following comments were made by individuals

 Support policy SD27 and the general approach  Farming should be referenced as a key sector in SD271a  Supportive pf policy SD27 and ask for and additional section on micro businesses that employ fewer than 5 people.  SD27 should protect all businesses and not just those that are small and green.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Title of SD27 changed from ‘rural’ to ‘local’ due to confusion over what is meant by ‘rural’.  Changes to the introduction to include that the socio-economic duty is in pursuit of the purposes.  Policy SD27 (1) re-worded for greater clarity over which of the criteria will apply and due to confusion over what is meant by ‘rural’ and ‘other relevant policies’.  Reference made to farming as a key sector in criterion SD27 (1) (a) and in the supporting text in order to recognise the importance of farming to the National Park and the need to promote and protect the key sectors.  Criterion SD27 (1) (c) reworded to recognise how rural supply chains extend beyond National Park boundaries and in response to representations.  Criterion SD 27 (1) (d) and supporting text reworded to recognise the importance of micro businesses as well as small businesses in the National Park.  New Policy criterion SD27 (1) (e) added to recognise the importance of building resilience for established businesses.  New policy Criterion SD27 1 (f) added to encourage the more efficient use of brownfield land (including change of use) with an intensification of uses.  Policy criterion and supporting text on homeworking deleted as it duplicates other policies.  Criterion SD27 (2) deleted.  Definition of smart economic growth added to supporting text.

216

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason The South Downs Society thought that SD27 SD27 makes reference to small and micro failed its statutory duty by not recognising the businesses and expands on this in the importance of other economic enterprises supporting text. particularly in market towns such as car repairs and joiner.

Ricardo PLC commented that the plan was SD27 and the supporting text set out the key weak on economic impact and should include sectors, green businesses, rural supply chains details on the size and type of businesses in the and small and micro businesses. SD35 (SD28 in National Park. the Preferred Options) addresses the economy, and employment land requirement. The Employment Land Review identifies a number of general employment sites. The key general employment sites are identified in the Policies Map and safeguarded under SD28.

Goodwood Estate suggested the role of Estates No change made to this policy, but the in the long-term stewardship of land should be importance of estates is recognised in Policy acknowledged. SD25.3: Development Strategy.

Folkington estate commented that farming The supporting text cross references Policy should be referenced as a small business in the SD40: Farm and Forestry Diversification which supporting text. deals with small businesses as part of farm diversification. The Edward James Foundation and Leconfield No change made to this policy, but the Estate commented that SD27 should reference importance of estates is recognised in Policy estates that make a substantial contribution to SD25.3: Development Strategy. the rural economy.

217

Policy SD28: Employment Land

Reg 22 (1) (c) (iii) There were a total of 34 comments on this policy. These are summarised below. National Agencies Portsmouth Water commented that there did not appear to be any employment allocations in Source Protection Zones to any of our public water supply boreholes. Portsmouth Water should be consulted immediately if this should change.

Borough, City, County and District Councils Chichester District Council supported the safeguarding of existing employment sites. It advised that further guidance is required in SD28 on evidence to be provided by applicants to demonstrate that there is no market demand for business premises. It also suggested that consideration should also be given to extending the required marketing period from 12 months to at least 2 years and that consideration should be given to requiring evidence that alternative employment uses for the site/premises have been fully explored and marketing requirements. East Sussex County Council queried what the minimum marketing period was. Hampshire County Council thought that key employment sites to be safeguarded should be shown on the Policies Map. They objected to SD28 on the grounds that greater flexibility required on the rationalisation of existing sites and proposed alternative wording.

Winchester City Council thought that there was no need to set a requirement that can be met from existing permissions and that the emphasis should be more on safeguarding existing employment than developing more.

West Sussex County Council advised that a selectively targeted transport study is required to support the proposed employment allocation and requested further information on allocated sites.

East Hampshire District Council considered that the employment land requirements should be more specific and not approximate. They also provided detailed comments on safeguarding employment land with suggested new wording.

Parish and Town Councils Twyford Parish Council supported with changes SD28 as follows: All commercial sites should be safeguarded and not just those in B usage. There is no policy on the redevelopment of existing premises or their expansion. Businesses should only be allowed to redevelop and/or expand if they are in accordance with National Park objectives. Expansion and redevelopment should look at alternative opportunities outside the National Park. Neighbourhood plans should not be overridden by Local Plan policies.

Harting Parish Council commented that the use of agricultural buildings for business should be prioritised above housing.

Selborne Parish Council suggested detailed policy wording for change of use applications.

Liss Parish Council objected to SD28 as it is unduly restrictive on employment.

Arundel Town Council queried whether the allocation of Mill House Farm in the Arundel Neighbourhood Plan was supported in SD28.

218

Rowlands Castle Parish Council Policy said that a policy was required on training and skills, that this section of the Local Plan should be renamed ‘employment’ rather than ‘sustainable economic development’ and further details required on what sites are being allocated.

Other Organisations Callstone Ltd supported SD28 with the following changes. Shoreham Cement Works can make a substantial contribution to employment (para 7.128). Employment land requirement should be increased to compensate for loss of offices to residential and other losses of commercial land.

CPRE Hampshire suggested detailed policy wording on SD28(2).

CPRE Sussex commented that the employment land requirement is not sufficient to support the socio-economic duty of the National Park. They are concerned by proposed increase in warehousing and noted that new enterprise is needed particularly in the larger settlements.

Friends of Lewes Society and Friends of the Earth Brighton & Hove supported SD28.

NFU South East Region commented that the employment requirement is too low and would prevent economic growth. Numerous opportunities for employment in redundant farm buildings and yards. Recommended that policy SD28 should be amended to recognise that new employment sites can be created in rural areas over and above the limited site allocations proposed, especially where these are commensurate with a farm or estate plan.

Ricardo plc commented that table 7.3 should include jobs as well as floorspace.

Agents and Developers

Gentian Developments Ltd commented that they are supportive of concept that ‘employment’ refers to more than traditional B uses. They noted that Para 6.4 of ELR includes the caveat that detailed site appraisals and assessments have not been carried out. Further work is required on deliverability of sites particularly Buckmore Farm.

Stedham Sawmill objected to SD28, provided detailed comments on the sawmill and said that further work is required on deliverability of sites such as this.

The Leconfield Estate provided detailed comments on the extension to Hampers Common Industrial Estate, Petworth to be allocated in the Petworth NDP. The allocation should not be restricted to B8 usage but should be tested at application stage.

The allocation of just a few hectares of employment land within such a large area is too restrictive and should be reconsidered.

Individuals There were no individual comments on SD28.

219

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 More detailed marketing requirements are set out in appendix 3.  Changes made to wording of SD28 (2).  Local and Principal Employment Sites to be safeguarded are named in paragraphs 7.152 and 7.153 and shown on the Policies Map.  A Transport Study that takes into development levels across the National Park has been prepared as part of the evidence base.  The chapter title changed from ‘Sustainable Economic Development’ to Employment.’ The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason A number of bodies questioned the level of The employment land requirements have been employment land provision. formulated in response to the evidence provided in the ELR and HEDNA. Job figures should be provided as well as Job figures are provided n the ELR and HEDNA employment floorspace figures Twyford Parish Council recommended changes SD28 seeks to accommodate employment land so that all commercial sites are safeguarded and which is B use. The Policy does seek to not just those in B usage. safeguard all existing employment sites and allocations that are fit for purpose. Harting Parish Council commented that the use The conversion of agricultural buildings is of agricultural buildings for business should be addressed in Policy SD41: Conversion of prioritised above housing. Redundant Agricultural or Forestry Buildings.

Selbourne Parish Council suggested detailed The policy and supporting text are considered policy wording for change of use applications. to provide sufficient detail to deliver the outcomes of the policy. Liss Parish Council objected as it is unduly The SDNPA believes that policies SD34 and restrictive on employment. SD35 achieve the right balance between safeguarding and promoting business in the National Park. Arundel Town Council queried whether the The employment allocation in Arundel NDP is allocation of Mill House Farm in the Arundel taken into account in table 7.7. Neighbourhood Plan was supported in SD28.

Rowlands Castle Parish Council said that a Training and skills are addressed in the policy on training and skills is required and Partnership Management Plan further details on what sites are being allocated.

Callstone Ltd suggested it is mentioned that Shoreham Cement Works has its own policy, Shoreham Cement Works can make a SD56 and details policies will be contained in substantial contribution to employment. the Area Action Plan.

They also suggested that employment land requirements should be increased to compensate for loss of offices to residential and other losses of commercial land.

Leconfield Estate commented that Hampers Dealt with in Petworth NDP Common Industrial Estate should not be

220 restricted to B8 usage but should be tested at allocation stage.

221

Policy SD29: Town and Village Centres Corresponding to Pre-Submission Policy SD36 and SD37

Reg 22 (1) (c) (iii) There were a total of 24 comments on this policy. These are summarised below. National Agencies Heritage England welcomed the recognition of the National Park’s historic town centres but queried the accuracy of some of the descriptions / historic origin information. Borough, City, County and District Councils Lewes District Council supported the policy approach, stating that it would help the Council to achieve its own priorities and aspirations. Chichester District Council considered that the policy would benefit from additional guidance on requirements and what evidence should be provided by applicants to demonstrate that there is no market demand for business premises. They feel that consideration should be given to extending the required marketing period from 12 months to at least 2 years and requiring evidence that alternative retail uses for the site/ premises have been fully explored. They feel that a requirement to demonstrate a lack of viability would enhance policy and that further guidance should be provided on marketing requirements related to loss of existing retail units in smaller village centres. Finally Chichester District Council query the accuracy of some of the descriptions / historic origin information relating to Midhurst. They also noted some inaccuracies on the inset maps. Parish and Town Councils

 West Meon Parish Council supports the policy in particular the smaller village centres section 3b. The village has a local community shop and post office, pub, butchers and cafe which the Parish Council would like to be safeguarded from non-retail uses and development.  Rowlands Castle Parish Council consider it is unrealistic to expect farmers market stallholders exclusively to only sell products that they have grown or made themselves. There needs to be greater flexibility and greater diversification adds to the chances of business success.  Twyford Parish Council suggest that Twyford Village Centre should be recognised within the policy. It is currently drafting policies to support the centre as part of the preparation of a Neighbourhood Plan for the Parish. The Parish Council consider that wording should be added to the policy to make it clear that neighbourhood development plans can define village centres and make policies for them in addition to those identified here. They put forward a number of detailed wording changes to reflect this view.  Bepton Parish Council express disappointment that Waitrose have withdrawn from the Grange in Midhurst and suggest that the SDNPA should be proactive in promoting viable retail alternatives.  Selbourne Parish Council suggest the wording ‘unacceptable adverse impact on" should be replaced by "cause harm to".  Steyning Parish and Arundel Town Councils wish to see mention of the importance of their town centres to communities within the National Park.  Liss Parish Council make a number of comments relating to the range of good available within their shops and the use or otherwise by people within and outside of the immediate community. They consider that it is unlikely that within such a community the scale of

222

development likely to occur will lead to the regeneration of the retail and service centre. They also comment on the need for the Neighbourhood Development Plan to consider the village centre boundary.  Midhurst Town Council confirms that land next to the Grange has potential for a medium sized supermarket and is keen to see this proceed. Other Organisations

 CPRE Sussex consider that some elements of the policy are overly restrictive.  Friends of Lewes Society consider that the scope of uses reflected in the policy should include commercial facilities to reflect the role of Lewes. The South Downs Society consider that wholesalers, banks, building societies, surgeries and community facilities should also be identified as important.  Friends of the Earth (Brighton & Hove) suggest removing the word unacceptable from before ‘adverse impact’ within the policy.  The South Downs Land Managers Group supports the retention of markets.  The South Downs Local Access Forum suggest that reference to the existence of a small supermarket in Liss should be rephrased as ‘convenience store’.  Arundel Chamber of Commerce wish to see mention of the importance of their town centre to communities within the National Park. The Cowdray and Leaconfield Estates comment that there may be circumstances where it is appropriate to allow change of use from ground floor shopping (Class A) to a residential use (where this is not in a primary shopping frontage). There may also be instances where upper floors would benefit from a change of use to residential as recognised by Part 3 Class O of the GPDO. The policy should be amended to recognise this and introduce flexibility in appropriate locations. The Leaconfield Estate suggest that the supporting text in relation to Petworth should not overly focus on the antique trade and should refer to the diverse and specialist retail offer available. They also question how many people shop elsewhere as they consider the current convenience store to be well supported and successful. Finally they comment that if the town is to remain in a high position in the retail hierarchy then it is important that residential development comes forwards in order to support it. This relationship should be recognised in the plan. Agents and Developers None Individuals There were few comments from individuals but those that were received generally supported the policy. One person commented that a lack of jobs in the Midhurst area, combined with and exacerbated by increasing rents, makes it more important to achieve cheaper public transport that runs later into the evening to locations outside the area (especially Haslemere). One person commented that the historical information was correct.

223

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The historic origin of Midhurst / historical details of other centres are contested and therefore many of the detailed points have been removed. They are not necessary to the understanding of the policy and are lengthy. The information is available from many other sources.  Guidance on what evidence should be provided to demonstrate no market demand is now included in the Local Plan Appendix.  The policy has been divided into two parts in order to clearly set out what elements are strategic and which are more development management in nature.  The marketing for retail units within smaller village centres has been extended to two years in response to a representation and evidence in the Retail Evidence Study on behalf of South Downs National Park Authority, July 2016. This notes that there are very few if any opportunities to provide new premises in the small centres and their loss is likely to be permanent. It also allows for seasonal variation. It is because of these reasons that this is a highly restrictive policy.  In response to requests to refer to specific activities, the policy has been clarified and now refers to Non-retail main town centre uses. Town Centre uses are defined in the NPPF and therefore this policy will remain up to date if the NPPF changes.  Reference to farmer’s market stallholder’s only selling products grown or made themselves was in supporting text and has been removed.  Text included in introduction highlighting the ability of communities doing NDPs to identify centres and prepare policies within their plans.  The introduction referred to a number of centres outside of but important to the National Park. There were requests to add to this list. However, it is likely to become very lengthy and are not necessary to the understanding of the policy. The paragraph has therefore been removed.  A number of respondents identified specific uses that might be accommodated within parts of a centre. This list was becoming lengthy and therefore reference has now been included in the policy to non-retail main town centre uses. Main town centre uses are defined in the NPPF and therefore this policy can remain up to date as a result of any changes to the Framework.

224

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Flexibility requested over change of use of This is allowed for in secondary centre but not ground floor A Class units primary. The National Park has tight, compact and historic retail centres in almost all cases. Opportunity for expansion does not exist in most. Therefore lost units cannot be replaced. Very limited levels of vacancies show there is a market for retail units. Some centres currently have no vacant retail units. The town centres are features of the National Park and attractions in their own right. There is no need to refer to matters covered by the GPDO. Twyford is not a defined centre Would encourage them to consider it through their NDP. Their shops are to be covered by the ‘shops outside centres’ policy. The link between housing and the strength of The relationship between growth of the retail centres should be recognised with community and the strength of the town centre reference to Petworth. is recognised in the Petworth NDP and is a key part of their vision.

225

Policy SD30: Strategic Infrastructure Provision

Reg 22 (1) (c) (iii) There were a total of 13 comments on this policy. These are summarised below. National Agencies Portsmouth Water promoted their Havant Thicket Reservoir proposals for identification within this policy. Borough, City, County and District Councils West Sussex County Council supported with recommendation to remove “only” from “strategic infrastructure proposals will be accepted only in exceptional circumstances. East Sussex County Council requested external pressures, such as housing growth and A27 improvements, be acknowledged by the policy and judged favourably. Parish and Town Councils Rowlands Castle Parish Council questioned that renewable energy generation schemes could be restricted by the policy. General support with a few minor edit suggestions for the policy text (several parish and town councils). Other Organisations Friends of the Earth Brighton & Hove raised concerns that insensitive highway schemes would be permissible under this policy. The Sussex Wildlife Trust & Hampshire & Isle of Wight Wildlife Trust ask that the policy should consider cumulative impacts. Ricardo plc ask that A27 improvement and Gatwick airport expansion should be identified as strategic infrastructure pressures. General support from other organisations. Agents and Developers None Individuals Support from 1 respondent.

226

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Policy and supporting text significantly revised and amended to provide suitable approach towards infrastructure  The new draft Local Plan policy (SD42: Infrastructure) combines Regulation 18 ‘Preferred Options’ draft Local Plan policies SD30 (Strategic Infrastructure) and SD54 (Supporting Infrastructure for New Development)  The rubric ‘strategic’ infrastructure has been removed as there is no clear definition of what comprises strategic – and what does not.  The supporting text has been comprehensively revised. Paragraph 7.218 sets out that some infrastructure proposals will be considered major development by the National Park Authority and as such will be subject to the tests in policy SD3.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Havant Thicket reservoir The reservoir is located outside the National Park in Havant to provide water supplies, primarily to urban areas outside of the National Park. The Havant Local Plan allocates the site (Policy CS16) and safeguards land from inappropriate development (Policy AL6). As such it is considered that there is no need for a specific policy reference in the draft Local Plan. Insensitive highway schemes would be The Local Highways Authority deal with such permissible under this policy development proposals. Paragraph 7.219 of the Regulation 19 draft Local Plan sets out that: ‘All proposals relating to strategic roads will be dealt with in accordance with the National Park Authority’s Position Statement on the A27 or any successor guidance. This also applies to other major infrastructure proposals’. Renewable energy generation schemes could be The draft Local Plan is clear that renewable restricted by the policy, but are encouraged by energy proposals would be subject to draft policy SD56. Policies SD42 (Infrastructure) and SD51 (Renewable Energy), and any other relevant policies. The policy should consider cumulative impacts. Other relevant draft Local Plan (such as, for example, SD9 Biodiversity and Geodiversity) would be relevant to infrastructure proposals. Moreover, larger proposals would have to consider cumulative impacts through Environmental Impact Assessment (EIA) regulations. A27 improvement and Gatwick airport The Local Highways Authority deal with such expansion should be identified as strategic development proposals. Paragraph 7.219 of the infrastructure pressures. Regulation 19 draft Local Plan sets out that: ‘All proposals relating to strategic roads will be dealt with in accordance with the National Park Authority’s Position Statement on the A27 or any successor guidance. This also applies to other major infrastructure proposals’.

227

The draft Local Plan sets out the context of the A27 at paragraphs 3.73 and 7.309. There is no current Government proposal to expand Gatwick, and as such it is not considered necessary for the draft Local Plan to speculate on this possibly occurring at a later date in the plan period.

228

Policy SD31: Climate Change and Sustainable Construction

Reg 22 (1) (c) (iii) There were a total of 32 comments on this policy. These are summarised below. National Agencies Support was given by Historic England. The Environment Agency emphasised that the South Downs National Park is within a recognised water stressed area and it is considered that there is enough evidence supporting this classification to justify higher water efficiency standards. Borough, City, County and District Councils The following comments were received from five local authorities: Lewes District Council commented that The South Downs National Park is classified as a water stressed area. There is justification for the SDNPA to seek higher water efficiency standards. Brighton & Hove City Council acknowledge the significant impact transport has on carbon emissions and climate change. Cross reference to policies SD18 and 19 as well as recognition of the importance in switching to sustainable transport modes to reduce carbon dioxide emissions and effects on climate change. Hampshire County Council objected to the policy on the grounds that the cost of achieving BREEAM excellent can be prohibitive and there should be greater flexibility. The supporting text still refers to the Zero Carbon Buildings Policy which is no longer being implemented. East Sussex County Council make reference to the contribution that can be made by the provision of multi-functional green infrastructure. Chichester District Council point out that orientation of dwellings can also be beneficial (solar gain). This should be added to the supporting text. Parish and Town Councils Support was received from Bepton and Selbourne Parish Councils Other Organisations Support was received from Friends of the Earth (Brighton & Hove) and Sussex and Hampshire & Isle of Wight Wildlife Trusts. Southern Water - emphasised that the South Downs National Park is within a recognised water stressed area (as defined by the Environment Agency) and it is considered that there is enough evidence supporting this classification to justify higher water efficiency standards. CPRE Sussex – Much of the weight of the supporting text has been left out of the Policy wording itself, which is therefore weaker. If there is justification then Local Authorities are allowed to go above the standards set out in Building Regulations. Support the inclusion of the BREEAM standard for major non-residential development, but would recommend that they policy should set a standard for small non-residential developments. There should also be standards set for refurbishment proposals. Cross reference with SD56: Renewable Energy would strengthen this policy. Would also suggest replacing ‘environmentally friendly’ with ‘development which meets the highest environmental design standards’, as a more objectively justifiable phrase.

229

South Downs Society – disappointed that the strength of the supporting text is not carried through to the requirements within the policy itself, but rather that the policy only encourages high standards. The desire for high BREEAM standards is understandable but it should allow for exceptions where they can be justified. There should also be greater encouragement for the incorporation of renewable energy measures in new developments. South Downs Land Managers Group – Questioned the lack of design/sustainability standards for “other” types of development. Agents and Developers The following comments were made:

 The cost implications of BREEAM excellent can be prohibitive, impacting on viability. Therefore more leniency is required  Some low carbon technology can be detrimental to scenic beauty, this could hinder achievement of top sustainability standards.  Policies pushing to exceed national standards will act as a disincentive to development within the National Park. An objection was received on the grounds that the requirement to achieve BREEAM excellent affects the viability of a scheme and can be prohibitive. It should require that development proposals meet the highest standard that is technically and financially feasible. Individuals Support for the policy was received from five individuals The following comments were also made:

 Policy is ambiguous and hard to understand. Do not over generalise  It is important to encourage good sustainability qualities and future proofing against climate changes, but be cautious when as trying to specify technical solutions.  National Building Regulations are prepared in conjunction with technical specialist and it is not necessary or straight forward for local authorities to make additional requirements, which may often be misinformed.  The policy should include encouragement for developments that are wholly or in part water/energy independent  Any reduction in the need for overhead power lines should be a priority  The SDNPA should seek to be an exemplar for energy and water efficiency and link this to education and increasing awareness of the challenges faced, types of solutions and mitigations available.  Suggest that all (not just major) developments should have to meet BREEAM standard  Support/encourage current owners to make their property more energy/water efficient  Sponsor new technology options for business development  Specifically support (including financial support) owners of listed properties to improve the efficiency of their homes without the bureaucracy of the planning system. One individual objected to the policy on the grounds that BREEAM excellent costs are prohibitive

230

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The title of policy has been widened to the use of sustainable resources rather than just construction techniques to address other environmental issues including efficient energy and water use when living in the building. This will help to reduce the local causes of climate change and support the aims of the SDNPA Climate Change Adaptation Plan (CCAP);  There are a number of conflicting comments relating to meeting sustainable building standards. Some requiring the highest possible and others raising concerns that these can be too onerous and will affect the viability of developments. In response to this, Criterion 2 has been expanded to set out specific achievable energy and water requirements in new development and for the need for all new development to address climate change, through zero/low carbon energy technology and sustainable design principles. Where possible the highest standards are required, based on the recommendations set out in the SDNP’s ‘The Whole Plan and Affordable Housing Viability Assessment’ (2017) and ‘Renewable and Low Carbon Energy Report’ prepared by Aecom (2013). In addition criterion 2 also allows for flexibility in standards where it is demonstrated that these cannot be met for technical or viability reasons;  Criterion 3 has been added to ensure that major development proposals fully address their potential to adapt and mitigate climate change;  A number of consultees refer to other climate change impacts, such as transport, that are not covered by this policy and how these might be addressed. It is recognised in the Local Plan that climate change is a cross cutting theme and references to other relevant policies that suitably address this issue have been added;  A separate section covering retrofitting has been added to the text to highlight the contribution this can make to reducing carbon use and in response to the CPRE’s comments. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason The SDLMG comments regarding ‘other’ types The policy is not limited to a specific type of of development meeting sustainable building development such as housing. It clearly refers design and construction. to all new development proposals. The definition of what constitutes development is very broad as set out in the planning legislation.

231

232

Chapter 8: Strategic Sites

Reg 22 (1) (c) (iii) There were a total of 79 comments on this chapter (including 17 comments on Policy SD33: Syngenta which has now been deleted from the Local Plan). 11 were general comments relating the introduction and need section of the chapter. These are summarised below. National Agencies Natural England are seeking clarification about how harm to strategic wildlife sites from strategic sites will be avoided and additional information about mitigation measures. Borough, City, County and District Councils West Sussex County Council advised that site specific principles will need to be tested through the development management process. Parish and Town Councils Steyning Parish Council support the re-development of Shoreham Cement Works. Other Organisations The Design Review Panel were unclear about the rationale for the guidance for the strategic sites and whether the SDNPA were being reactive or proactive. Sussex Wildlife Trust and Hampshire & Isle of Wight Wildlife Trust (joint comments) support the inclusion of strategic sites. Ricardo plc/ South Downs Partnership member raised concerns that the policies do not address the issue of business tourism and any proposals should be making more of rivers. Agents and Developers Callstone Ltd raised concerns about: viability being more important than innovative development; shift from adopted policy; lack of realistic approach to sites financial dynamics and affordable housing should be case by case and take into account exceptional costs. Individuals 1 individual supported the paragraph relating to restoration. 1 individual expressed concerns about ‘hidden’ housing need from tied housing and ensuring that data is up-to-date in relation to tied housing to enable housing needs to be met.

233

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The wording of the introduction and need sections (and subsequent policies) have been amended to provide clarity and consistency with the rest of the Local Plan;  The wording of the policy and supporting text for the Shoreham Cement Works site (now policy SD56) has been amended to reflect the new approach to produce an Area Action Plan which will address in more detail the constraints and opportunities including land restoration, environmental impacts, transport, flood risk, cultural and heritage, design considerations, viability and phasing of delivery;  Wording has been added to the Strategic Site policies to ensure that any adverse impacts (either alone or in combination) are avoided, or, if unavoidable, minimised through mitigation with any residual impacts being compensated for. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Amendments sought to ensure actual level of No specific change has been made to this affordable housing will be determined on the chapter as the issue of affordable housing is individual merits of the cases, which will be addressed elsewhere in the Local Plan. informed by a viability assessment; particularly in light of any exceptional cost. Amendments sought in relation to specific No specific change has been made to this consideration of business tourism chapter as the issue is addressed elsewhere in the Local Plan.

234

Policy SD56 (formerly SD32): Shoreham Cement Works

Reg 22 (1) (c) (iii) There were a total of 34 comments on this policy (or comments on other sections of the plan which directly related to this policy). These are summarised below. National Agencies Environment Agency are seeking clarification on the potential for contaminated land in relation to Shoreham Cement Works and how it would be addressed by any redevelopment. They support the references to conservation and enhancement of biodiversity and recommend that redevelopment takes into account the protection of water quality of the River Adur. Historic England welcome interpretation of the historic origins and significance of the site in any development that comes forward, the need to conserve the pre-historic cross-ridge dyke scheduled monument and criterion 3 (b). They suggested some detailed wording changes to improve the policy.

Borough, City, County and District Councils West Sussex County Council advised that selectively targeted transport study is needed to provide evidence to support the proposed allocations, as well as further information on the proposed park and ride facilities. Brighton & Hove City Council and Adur and Worthing Council consider that the site should support uses that serve the local economies of Adur and Worthing and the coastal conurbations. Brighton & Hove City Council suggested the deletion of criterion ‘f’ and amended text to provide flexibility within the policy. Adur and Worthing commented on the significant housing shortfalls in Adur and Worthing and considered the policy too restrictive in relation to employment types and were seeking further information on transport impacts and green travel measures. Horsham District Council support the restoration and development of the site but consider it should be an employment site and an assessment should be undertaken to ensure that the proposals do not conflict with nearby settlements and retail centres. Parish and Town Councils Steyning Parish Council, Upper Beeding Parish Council and Madehurst Parish Meeting support the Shoreham Cement Works policy. Other Organisations South Downs Society and Wiggonholt Association support the policy. Sussex Wildlife Trust and Hampshire & Isle of Wight Wildlife Trust (joint comments) support the policy with some minor changes to strengthen the policy to include ‘net gains’ for biodiversity. Ricardo plc/ South Downs Partnership member, raised concerns about housing pressure and the apparent lack of ‘Duty to Cooperate’ in terms of housing, economic viability, implementation timescales, deliverability and conflict with environmental growth hub for Shoreham.

235

Agents and Developers South Downs Project Ltd raised concerns about: lack of support from local stakeholders or potential landowner, deliverability; lack of ambition; viability and the policy is a compromise. Group have proposed an alternative scheme. Callstone Ltd raised the following issues: they consider site is a sustainable location for housing; restoration of area D would address SDNPA’s purpose 1; sub-areas could accommodate different development solutions; lack of evidence to support the policy; policy and supporting text too onerous and unreasonable. They also object to the reference to a specific scheme without any viability assessment to back it up. Callstone Ltd also commented on the identified constraints, retention of buildings, access and mix of uses, suggested additional wording on history of the site and planning status and alternative wording for the policy. They would support an alternative mixed use scheme similar to the 2003 Appeal scheme. Individuals 1 individuals supported the potential for creating visitor attractions and tourist centre. 1 individual (Sompting Estate) raised concerns about the impact on dark night skies and suggested an additional criterion which ensures there will be no significant detriment to the eastward vies of the night sky from the downs above Lancing and Sompting.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The wording of the policy and supporting text has been amended to provide clarity and consistency with the rest of the Local Plan;  The wording of the policy and supporting text has been amended to reflect the new approach to produce an Area Action Plan which will address in more detail the constraints and opportunities including land restoration, environmental impacts, transport, flood risk, cultural and heritage, design considerations, viability and phasing of delivery;  Amendments have been made to the supporting text to make specific reference to protecting water quality.  Amendments have been made to policy (at 1(b)) to include the wording ‘historic significance’;  Amendments have been made to the policy (at 2(b)) to refer to businesses uses which support the rural economy, with a focus on environmentally sustainable activities, supporting local communities and providing opportunities for entrepreneurship;  An addition criterion has been added (at 2(c)) which sets out that other types of development may be supported if they would enable the environmentally-led restoration of the site, and  Amendments have been made to the policy (at 2(g)) to ensure that any adverse impacts (either alone or in combination) are avoided, or, if unavoidable, minimised through mitigation with any residual impacts being compensated for.

236

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Delete criterion ‘f’ – ‘include no more It is not considered appropriate to delete development than is necessary to secure the reference, albeit the wording has been slightly satisfactory restoration of the site’. amended and renumbered as criterion 3, as this is to ensure that the environmentally-led restoration of the site is the priority and that any development is consistent with the purposes of the National Park. Policy should make specific reference to The National Park’s priority is to see the housing as suitable use for the site (and to meet environmentally-led restoration of the site with the needs of neighbouring authorities), level of uses compatible with the purposes of a affordable housing and housing mix recognising National Park. Criterion 3 of the policy that viability is a key challenge to deliverability. provides sufficient flexibility to address the issue of viability and deliverability. It is not appropriate for National Park to meet unmet housing need from elsewhere outside of the National Park. The issue of affordable housing and housing mix are addressed in other policies in the Local Plan, there is no need to repeat it in this specific policy.

Add another criterion to ensure no significant Additional criterion is unnecessary as the issue detriment to eastward views of the night sky of the Dark Night Skies is addressed via policy from the downs above Lancing and Sompting. SD8: Dark Night Skies.

237

Policy SD33: Syngenta

Policy SD33: Syngenta has been deleted from the Local Plan as the site is allocated for a sustainable mixed-use development incorporating residential (approximately 200 homes), commercial development and other suitable uses in the Fernhurst Neighbourhood Development Plan (NDP), which was made on the 14th April 2016.

Policy SD57 (formerly SD34): North Street Quarter

Reg 22 (1) (c) (iii) There were a total of 17 comments on this policy. These are summarised below. National Agencies The Environment Agency supports the wording of the policy in relation to flood risk (which is consistent with the Joint Core Strategy). Historic England supports in particular the criteria related to the historic environment. Borough, City, County and District Councils Lewes District Council state that it is crucial allocation is made to help meet some of the identified needs in Lewes and reflects the Joint Core Strategy. East Sussex County Council comment that the policy should be more explicit about the need to protect, mitigate and enhance biodiversity interest, incorporate references to Green Infrastructure and include provision of sustainable urban drainage schemes (SUDS) as criteria. Parish and Town Councils Lewes Town Council want to ensure that meeting local needs is central to the affordable housing element of the policy. Other Organisations CPRE Sussex comment that the housing allocation for whole site already provided for by recent planning application for northern part only. Eastgate area (south of Phoenix Causeway) should be considered for 50 homes. Southern Water support in particular the need for additional sewerage infrastructure, noting the site is within groundwater Source Protection Zone (Zone 3) and requires the Environment Agency approval. The Friends of Lewes Society believe that the policy should be more ambitious and allocate higher densities and be more specific as to the tenure mix of the affordable housing. The South Downs Society raised concerns about the loss of low-cost industrial floorspace for start- up and creative businesses. Sussex Wildlife Trust and Hampshire & Isle of Wight Wildlife Trust (joint comments) state that the policy should be more explicit about the need to protect, mitigate and enhance biodiversity and incorporate references to Green Infrastructure. Lewes Phoenix Rising suggest that the Eastgate area (south of Phoenix Causeway) should be in a separate policy, the North Street Quarter allocation should protect the existing uses, the policy should reflect the emerging policy being produced as part of the Neighbourhood Plan. They also raised concerns about genuine affordability or nationally defined ‘affordable homes’ which are still very expensive when set as a percentage of local housing market prices.

238

Agents and Developers Santon North St Ltd commented that the policy mirrors the Lewes Joint Core Strategy which has considerable weight having been examined. Individuals 1 individual states the policy should ensure that any development enhances the character of the town. 1 individual raised concerns that the Zero-carbon references in the supporting text are not reflected in the policy wording and that the policy should specifically refer to the Planning & Energy Act 2008. 1 individual supported the policy and the evidence base. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The wording of the policy and supporting text has been amended to provide clarity and consistency with the rest of the Local Plan, for example the specific reference to affordable housing has been deleted as this issue is covered elsewhere in the Local Plan and it is not necessary to repeat it within this specific policy;  The wording of the policy and supporting text has been amended to reflect the planning permission granted in May 2016;  Additional criteria has been added (at 3(f) and 3(n)) to refer enhancing biodiversity / green infrastructure and ensuring that any adverse impacts (either alone or in combination) are avoided, or, if unavoidable, minimised through mitigation with any residual impacts being compensated for;  Additional criterion has been added (at 3(m)) to refer to incorporating sustainable surface water management systems;  Specific references to zero-carbon has been deleted from the supporting text as these issues are addressed elsewhere within the Local Plan and it is not necessary to repeat it within this specific policy, and  Additional criterion has been added (at 4) which sets out that whilst the preference is for a comprehensive redevelopment of the whole site, it is recognised that planning applications may come forward separately or in phases. Therefore it is expected that any application will demonstrate how the proposals would accord with the policy and be consistent with any other permissions granted. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Policy should have a specific breakdown of the The issue of affordable housing and housing mix affordable housing requirements are addressed in other policies in the Local Plan, there is no need to repeat it in this specific policy. Have two separate policies, one for the North Adjoining areas have similar opportunities and Street Quarter area and another policy for the constraints (and shared solutions) therefore the Eastgate area preference is look at the sites in a comprehensive way. However, the policy has been amended to provide flexibility in the recognition that schemes (or phases) could come forward separately.

239

240

Chapter 9: Site Allocations

Reg 22 (1) (c) (iii) There were a total of 264 comments on this chapter. These are summarised below. Comments on Introduction

There were a total of 33 comments received on the Introductory section of this chapter. National Agencies Historic England supported and welcomed the references to and acknowledgement of the historic origins, development and character of the settlements within the National Park. Recognising that there are still a significant number of sites to be allocated, Sport England put forward strong objection to the future allocation of any sites which would result in the loss of sports facilities (unless compliance with NPPF paragraph 74 was demonstrated). Borough, City, County and District Councils One district and two County councils responded on the Introduction. It was noted that further information would be required regarding transport infrastructure requirements in support of the allocations proposed in the draft plan. It would also be helpful to clarify that the Infrastructure Delivery Plan is a ‘living’ document which would regularly change and be updated (paragraphs 9.16 – 9.17). A specific site in Midhurst was also suggested (Bepton Depot). It should be noted that this site has been submitted and will be assessed through the Strategic Housing Land Availability Assessment). Parish and Town Councils Five Parish/Town Councils commented on the Introductory section. The majority of comments concerned the Neighbourhood Planning process:

 Recognition that in Neighbourhood Development Plan (NDP) areas, it is the responsibility of the NDP to allocate sites, and explanation of the relationship with the NDPs and the Local Plan is needed.  The site allocation process is overly complex  Continued active engagement with the SDNPA is required  Cross-boundary issues for NDP areas which are partly within the National Park, noting that exhaustive searches outside the SDNP have not resulted in suitable sites, and that proposed sites within the National Park are a last resort.  Changes to the Settlement Policy Boundary for Midhurst, support for the proposed allocations within the town and pre-emptive support for an allocation for mixed use development, including a nature reserve at the Bepton Depot.

241

Other Organisations Eight organisations made comments:

 Friends of the Earth (Brighton & Hove) – Encouragement for higher density development, to make better use of land. A greater level of affordable housing  SOS Bohunt Manor Community Action Group – Support for the exclusion of Bohunt Manor estate as an allocation within the draft plan, highlighting the proximity of the estate to the Wealden Heaths SPA.  Sussex Wildlife Trust & Hampshire and Isle of Wight Wildlife Trust (joint response) – The specific development requirements for each site allocation are too limited. Further detail required.  The Gilbert White Museum – Considered it a well produced document, although the maps could be improved / made clearer.  Two estates commented that they are in the process of preparing Whole Estate Plans in accordance with policy SD22. One noted that this had unfairly led to their sites being rejected from the 2014 SHLAA as they were not being actively promoted. These sites have been resubmitted with confirmation that they are being actively promoted, which should lead to proper assessment through the SHLAA update.  It was noted that several key evidence base documents had not been made available when the Consultation was launched including the Tranquillity Study and Strategic Housing Market Assessment.  Specific objection was received to the Syngenta Strategic Site allocation and to the SHLAA methodology which, they considered, excluded suitable, sustainable sites. Developers and Agents Four comments were received from developers. The comments were as follows:

 Several specific sites were proposed to meet levels of development sited in Policy SD23:Housing. These have also been submitted through the call for sites and will be assessed through the SHLAA process.  Support for growth in Selbourne  Questioning why sites that were found suitable in the 2014 SHLAA have not been allocated.  One response recommended an increase in the housing requirement to at least 5447, with this increase being accommodated in Lewes, Petersfield, Midhurst and Liss. Promoting a specific site in Liss for allocation in the Local Plan, whilst acknowledging the role of Neighbourhood Plans. Individuals Seven individuals commented on the Introduction:

 Confusion over relationship between Findon and Fernhurst NDPs and the Local Plan allocations. Lack of allocations identified in either the Findon NDP or the local plan (for Findon) means the Findon NDP is not in conformity with the Local Plan.  Concern that the threshold of six units or greater within the SHLAA excludes small sites which could assist with windfall.  Due to the historic nature of settlements such as Midhurst and Petersfield, it would seem inappropriate to burden them with excessive development when settlements like Liss can accommodate more without detriment to the environment.  Support for the clear definition of sites in the Plan

242

Reg 22 (1) (c) (iv) The representations have been taken into account as follows:

 Each allocation site has addressed, where potential is identified, Ecosystem Services;

 The allocations set out a range of housing units that each site, in the view of the Authority, could deliver – taking into account the local townscape, predominant residential typologies and density of built form  Suggested sites now included as allocation sites include: WSCC Depot/Brickworks and Holmbush Caravan Site (both Midhurst), Land at Pulens Land (Sheet), Land at Ramsdean Road (Stroud) and two sites in Findon.  New Road garage site in Midhurst and Kiln Lane, Buriton have been removed as housing allocations The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason This paragraph needs to recognise, inter alia, Disagree. Shoreham Cement Works is the current site ownership of Shoreham addressed in the respective policy SD56. Cement Works and, further, that any scheme proposals are deliverable.

Given the high level of environmental Disagree. The Regulation 19 Local Plan is clear protection promoted in the plan’s core and – Paragraph 9.6 (p.219) – that each allocation strategic policies, the specific development site policy must be read in conjunction with the requirements for the Site Allocation Policies full suite of policies. A balance has been struck seem limited. between providing sufficient site specific information and not repeating criteria in ‘global’ policies. An example of this is the HOUSING MIX policy (SD27).

There is currently insufficient evidence to Since the Regulation 18 Plan was consulted support the proposed allocations, therefore the upon the SDNPA has undertaken new highways County Council considers that a selectively assessments to support the site allocations. targeted transport study is required. However, This is set out on the SDNPA website. this does not need to be based on a strategic network transport model. It will be sufficient to identify areas within the SDNP in West Sussex where cumulative impacts will exceed or approach Transport Assessment (TA) thresholds and then to analyse the impacts within those local areas. The Town Council requests that the Fraser The sites are located within the Midhurst Nash site on Bepton Road be designated for settlement boundary where the principle of mixed retail and housing development and the development is established; proposals could Old Court House site in Grange Road be come forward without the need for allocation. designated for housing. Land north of Hill Brow Road, Liss should be Housing allocation sites for Liss and Twyford included. Land East of Bourne Lane, Twyford are set out in their respective Neighbourhood should be included. Plan and as such there is no need in the case of Liss & Twyford to provide extra sites in the SDNP Local Plan.

243

Policy SD-SS03: Land at Old Malling Farm, Lewes

Reg 22 (1) (c) (iii) There were a total of 117 comments on this policy/chapter. These are summarised below. National Agencies Three national agencies commented on the site allocation: Environment Agency noted that parts of the western and northern boundary of the site are directly adjacent to flood zone 3 areas. A site specific flood risk assessment would be needed to establish the exact developable area. Natural England made several comments on the location of the allocation, being adjacent to Offham Marshes SSSI, within the floodplain and on a greenfield site raising concern that these constraints had not been fully explored. Historic England – support was given for criteria 7 and 15, but no comment was given on the principle of development of the site. Borough, City, County and District Councils Lewes District Council wrote in support of the allocation as it, along with other sites in the town were crucial in meeting identified housing needs. East Sussex County Council would need to be consulted on sustainable drainage schemes within the site and that green roofs should be considered to reduce the visual impact of development. Parish and Town Councils Lewes Town Council objected to the site allocation stating that there needed to be a breakdown of affordable housing across the National Park to enable people to live in their towns and parishes. Other Organisations Eight organisations/ groups commented on this. There was one representation supporting the allocation and six objected, raising several common concerns:

 The site is of high landscape value outside the current development boundary and very visible from the Ouse Valley.  The allocation is contrary to the strategic policies of the draft local plan (Policies SD7 and 9 were specifically mentioned) due to the negative impact on landscape, views, tranquillity.  The potential for archaeology is high given its location within the setting of the Conservation area.  The site is on the edge of Lewes and quite some distance from the services and facilities in the town centre.  The loss of high quality agricultural land which acts as a green wedge/finger into the town  It was noted that the site was found unsuitable within the National Park’s own SHLAA and the findings of the Sustainability Appraisal which said development of the site would have significant negative effects were endorsed  There should be a requirement for net gains to biodiversity and enhancement of the adjacent SNCI.  The recommendation to state that additional local sewerage and water infrastructure would be required.

244

Agents and Developers No comments received Individuals 94 individuals objected to this allocation. The majority gave reasons for their objection as follows:

 National Parks are not suitable locations for development and should be preserved for future generations. Development should happen outside a National Park. Given the designation, there should be stronger protection against development within the SDNP  There are no exceptional circumstances which would be required to meet the test for major development within the National Park  Development on this site would adversely impact the Special Qualities, the rural tranquil character of the Ouse corridor and the views of the site from surrounding higher ground to the west, north and east.  Negative impact on the setting of the conservation area of Malling Deanery and concern over the potential archaeological significance of the site  Would cause permanent harm to wildlife and the environment, the adjacent SSSI and SNCI  Brownfield land should be used for housing before any greenfield land, particularly high quality agricultural land which is scarce within East Sussex.  Unsuitable development into the floodplain  Would lead to an increase in an already very congested and hazardous road network particularly during the construction phase with an increase in large vehicles, noise and pollution  Increase in pressure on schools and health facilities as well as waste water infrastructure.  Would have negative impacts on existing residents.  The Ouse Valley was specifically included within the National Park at the Inquiry to provide a high quality setting for the town of Lewes.  Disjointed planning with this site, South Downs Road, Tesco development and expansion of Police HQ and would result in over-development  Concern that SDNPA are being pressured into allocating this site, querying what has happened since the previous rejection of the site  The Sustainability Appraisal supports the exclusion of this site  Need to protect against amalgamation of towns and cities  The requirement for 50% affordable housing is not financially viable, whilst others questioned why the level of affordable was not higher.  The Phoenix Quarter should be developed rather than Old Malling Farm There were a small number of positive comments and one in support of the development:

 There was acknowledgement of housing need and in particular for low cost housing for young people  Given the high value of this development there should be a higher level of affordable housing required.

245

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The wording of the policy has been significantly amended to provide clarity and consistency with the rest of the draft Local Plan allocation policies. This includes changing the formatting from a long set of bullet points to numbered paragraph and lettered sub headings used in other policies.  Supporting criteria within the policy which is addressed through other draft Local Plan policies has been removed, including the first criterion which sets out an affordable housing requirement  That the Design Brief should be ecosystem services led and include a Green Infrastructure Strategy and Site Masterplan The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason National Parks not suitable locations for It is not considered appropriate not to plan for development. a suitable level of development with the SDNP. The draft Local Plan does not set out a development strategy which would provide a level of residential development compatible with the ‘objectively assessed needs’ (OAN) of the National Park. Instead, it is considerably below the OAN and as such neighbouring local authority areas may have to provide additional housing to compensate. Nonetheless, in line with the medium, dispersed development strategy set out in the draft Local Plan it is considered appropriate to provide some significant housing in Lewes, which is one of the two largest settlements in the National Park (the other being Petersfield).

There are no exceptional circumstances which The SDNPA originally considered that this site would be required to meet the test for major should not be developed and would not meet development within the National Park. the major development test. It did not therefore include it as a strategic site in the Lewes Joint Core Strategy (LJCS). However, the Inspector at the Examination had a different view and requested that a Modification be made to the plan in respect of this site if he was to find the JCS sound.

However, in the light of the need for housing, especially affordable housing, within Lewes and the importance which the LJCS Inspector attached to meeting this need as far as possible, it is considered that an exceptional circumstance can be demonstrated in terms of need. Moreover, the LJCS has demonstrated that this need cannot be fully met outside the designated area of the National Park, although sites at Ringmer and Cooksbridge do make a contribution.

246

Development on this site would adversely The 2012 Landscape Assessment sets out impact the Special Qualities, local views and various ways in which the adverse landscape landscape. impacts can be mitigated and these are included in the criteria set out in the draft policy for consideration as a modification by the LJCS Inspector. The criteria also address the other potential adverse impacts. Subject to these criteria and the Inspector maintaining his view, following further examination, that the site should be allocated for development, it is accepted that the tests for exceptional circumstances in the public interest are met.

Impact on heritage assets, designated sites, local Additional policy criterion are considered ecology, highways, infrastructure and flooding. unnecessary as these issues are also addressed in various draft Local Plan policies.

247

Policy SD-WW03: Land at New Road, Midhurst

Reg 22 (1) (c) (iii) There were a total of 4 comments on this policy/chapter. These are summarised below. National Agencies Historic England support the reference to archaeological investigation, but seek more specific requirement on this. They also note the site is close to Midhurst Conservation Area. Borough, City, County and District Councils West Sussex County Council commented that the allocation will displace existing parking which will need to be considered at the application stage. Chichester District Council note the constraints on this site – the nearby conservation area and trees on and to the north of the site. Parish and Town Councils No comments received Other Organisations South Downs Society support the allocation but consider it to be overdevelopment, they suggest development should be restricted to 3 new homes. Agents and Developers No comments received Individuals No comments received Reg 22 (1) (c) (iv) The representations have been taken into account as follows. The proposed allocation has been removed from the Regulation 19 draft Local Plan. It is unclear whether the site could actually provide at least five new dwellings, sufficient parking and amenity space for new residents and address the loss of existing parking spaces through the demolition of existing garages. Nonetheless, as previously developed land in an urban location development proposals could be bought forward in principle without the need for allocation in a development plan. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason n/a n/a

248

Policy SD- WW04: Land at Petersfield Road, Midhurst

Reg 22 (1) (c) (iii) There were a total of 2 comments on this policy/chapter. These are summarised below. National Agencies No comments received Borough, City, County and District Councils No comments received Parish and Town Councils No comments received Other Organisations Southern Water support the allocation with changes to recognise additional sewerage infrastructure would be required to accommodate development. They also note there is existing underground wastewater and water infrastructure which will require a 6m easement allowance in the layout and design of the development. South Downs Society support the allocation with changes to recognise the existing mature landscaping of the site. Agents and Developers No comments received Individuals No comments received Reg 22 (1) (c) (iv) The representations have been taken into account as follows. The proposed allocation has been removed from the Regulation 19 draft Local Plan. The site is no longer available. Nonetheless, given the location of the site within the Midhurst settlement boundary, development proposals could be bought forward in principle without the need for allocation in a development plan.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason n/a n/a

249

Policy SD- WW05: Land at Lamberts Lane, Midhurst

Reg 22 (1) (c) (iii) There were a total of 4 comments on this policy/chapter. These are summarised below. National Agencies Historic England welcome the references to the Conservation Area, Grade II listed building and requirement for a Heritage Statement. No changes sought. Borough, City, County and District Councils West Sussex County Council state a Road Safety Audit would be required. Parish and Town Councils No comments received Other Organisations South Downs Society support the allocation with changes to provide a more direct footpath to the town centre and criteria to ensure that design and layout reflect vernacular character. No more than three dwellings on the site. Agents and Developers No comments received Individuals No comments received Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Five dwellings would seem excessive and we Disagree. In line with the proposed housing mix would suggest no more than three. policy and the close proximity of the site to the town centre it is considered that a higher density of development is appropriate.

250

Policy SD- WW09: Land at Clements Close, Binsted

Reg 22 (1) (c) (iii) There were a total of 4 comments on this policy/chapter. These are summarised below. National Agencies Historic England welcome the requirement for a pre-application archaeological assessment. No changes sought. Borough, City, County and District Councils Hampshire County Council confirm that Binstead footpath no.28 must be protected. Parish and Town Councils No comments received Other Organisations The RSPB state this site is within the zone of influence to the Wealden Heaths Phase 2 SPA. Policy reference should be made for the need to mitigate recreational distance impacts. Allocation should be shown on a inset map at clearer scale. Agents and Developers No comments received Individuals No comments received Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The wording of the allocation policy has been amended to provide clarity and consistency with the rest of the Local Plan  The allocation policy is supplemented by detailed supporting text which sets out the context of the site and the evidence  A specific criterion has been added to the policy (1(a)) which sets that appropriate mitigation of development on the Wealden SPA should be informed by an appropriate assessment  Specific criteria related to Ecosystems Services are included (6a-d) which relate to non- motorised access, trees, pollination and permeable surfaces

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Binstead footpath no.28 must be protected The PROW is outside the site; development would be similar that adjacent to the footpath and as such it is not necessary to include a specific policy criterion.

251

Policy SD- SS02: Land at Kiln Lane, Buriton

Reg 22 (1) (c) (iii) There were a total of 3 comments on this policy/chapter. These are summarised below. National Agencies Historic England support the requirement for pre-application archaeological assessment. No changes sought. Borough, City, County and District Councils No comments received Parish and Town Councils Buriton Parish Council made two representations highlighting a number of issues with development at this site including serious flooding, long distance views, traffic and disturbance to wildlife. Policy requirements suggested include preference for smaller market homes, high quality design, retention of hedgerows and traffic calming measures. Other Organisations No comments received Agents and Developers No comments received Individuals No comments received Reg 22 (1) (c) (iv) The representations have been taken into account as follows. The Parish Council representation highlighted particular concerns with regard to flooding, impact on landscape and highways & access. When these issues were taken into account, it was considered that an alternative available site in Buriton (Land at Greenway Lane) has less constraints and potential impacts. As such, the proposed allocation site at Kiln Lane was removed from the Regulation 19 draft Local Plan and the site Land at Greenway Lane was included instead. Land at Greenway Lane it is considered has less landscape and highways impacts and potential to address surface water flooding. It also has capacity to provide up to 10 dwellings which is more than the Kiln Lane site. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason n/a n/a

252

Policy SD- WW11: Land at Brookland Way, Coldwaltham

Reg 22 (1) (c) (iii) There were a total of 12 comments on this policy/chapter. These are summarised below. National Agencies Environment Agency state the site is within SPZ3. Borough, City, County and District Councils West Sussex County Council state a Road Safety Audit will be required. Parish and Town Councils No comments received Other Organisations CPRE Sussex & South Downs Society object to the inclusion to this site due to significant impact on Waltham Brooks SSSI and the impact on the setting of the SPA and Arun Valley Ramsar. Sussex Wildlife Trust & Hampshire Wildlife Trust also comment that proximity to the SPA will trigger a Habitat Regulations Assessment (HRA). The Trust would not support an increase on the site. Wiggonholt Association commented on existing significant flooding at the site and impact on the historic road network. They also question whether alternative sites outside the floodplain have been considered. Southern Water support the allocation with changes to ensure adequate mitigation measures to protect groundwater and nearby wastewater infrastructure. Smiths Gore on behalf of the Barlavington Estate support the allocation with changes to clarify only small part of larger site would accommodate more housing and note nearby ecological designations. Agents and Developers No comments received Individuals Two individuals objected to this allocation due to harm to flooding issues, wildlife, impact on views and limited local amenities. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The wording of the allocation policy has been comprehensively revised and amended to provide clarity and consistency with the rest of the Local Plan  Criterion 2 sets out the requirement for proposals to be in broad conformity with a development brief to be prepared by the SDNPA  The proposed allocation includes an increase in the number of dwellings (up to 40) but stipulates a set maximum unlike the Regulation 18 draft Local Plan policy which stated “approximately 20”  Amendments to the policy includes specific reference to possible mitigation to be provided given the proximity of designated sites in the Arun Valley, landscape strategy, landscaped open space, highways, flood risk mitigation  The allocation policy is supplemented by detailed supporting text which sets out the context of the site and the evidence required at the application stage

253

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Existing significant flooding at the site and The site is outside the Environment Agency impact on the historic road network. They also fluvial flood zones. The likely vehicular access is question whether alternative sites outside the onto the A29 and as such will not impact on floodplain have been considered. historic road network.

254

Policy SD- WW01: Land East of Cowdray Road, Easebourne

Reg 22 (1) (c) (iii) There were a total of 4 comments on this policy/chapter. These are summarised below. National Agencies Historic England support the requirements for a Heritage Statement and reference to the Conservation Area and nearby Grade II listed buildings. Borough, City, County and District Councils Chichester District Council question whether this allocation will be predominantly affordable housing subject to viability? West Sussex County Council state a Road Safety Audit will be required. Parish and Town Councils No comments received Other Organisations The South Downs Society support this allocation. Agents and Developers No comments received Individuals No comments received

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The wording of the allocation policy has been amended to provide clarity and consistency with the rest of the Local Plan  Criterion (1a) addresses the need for development proposals to conserve & enhance adjacent heritage assets  The allocation policy is supplemented by detailed supporting text which sets out the context of the site and the evidence The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Affordable Housing As with all allocation sites, proposals will be subject to the ‘global’ affordable housing policy SD28 in the draft local plan. A Road Safety Audit will be required Policy SD19 (Transport and Accessibility) addresses the impact of development proposals on the safe operation of highways.

255

Policy SD- WW10: Land at Petersfield Road, Greatham

Reg 22 (1) (c) (iii) There were a total of 9 comments on this policy/chapter. These are summarised below. National Agencies The Environment Agency state the site in in SPZ3. Historic England support the requirement for a Heritage Statement and pre-application archaeological assessment. Borough, City, County and District Councils Hampshire County Council confirm that Greatham footpath no 10 must be protected. Parish and Town Councils Greatham Parish Council object to this allocation due to poor vehicular access; poor public transport and lack of community facilities including primary school and nursery spaces. The Settlement Policy Boundary should not be changed. Other Organisations The RSPB & Sussex Wildlife Trust note this site is within the zone of influence for recreational disturbance to the Wealden Heaths Phase 2 SPA. Both organisations support a strategic approach to mitigation through a revised policy SD13 rather than site by site mitigation. Southern Water support this allocation with changes to ensure additional local sewerage infrastructure. An easement of 6m would be required which will affect the site layout and design. Agents and Developers The landowner supports this allocation and confirms it is available. Individuals No comments received Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The wording of the allocation policy has been amended to provide clarity and consistency with the rest of the Local Plan including:- i. Criterion 2(b) addresses the need to conserve and enhance heritage assets; ii. Criterion 2(c) addresses the need to provide suitable mitigation towards the Wealden Heath SPA; iii. Criterion 2(e) addresses the need to protect groundwater resources; and iv. Criterion 2(f) addresses the possible need for highway improvements to facilitate safe access and egress  The allocation policy is supplemented by detailed supporting text which sets out the context of the site and the evidence  Specific criterion related to Ecosystems Services are included (3a-c) which relate to trees, pollination and permeable surfaces

256

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Poor vehicular access; poor public transport The site has an existing vehicular access onto and lack of community facilities including Petersfield Road which it is considered has primary school and nursery spaces. scope to be improved. The site is adjacent to an existing primary school and village hall. It is the responsibility of the Local Education Authority to provide primary school places. The draft policy (SD73) also includes scope for a new small shop.

Easement Utilities requirements are addressed through draft policy SD44.

257

Policy SD- WD01: Land at Itchen Abbas House, Itchen Abbas

Reg 22 (1) (c) (iii) There were a total of 8 comments on this policy/chapter. These are summarised below. National Agencies The Environment Agency comment that the policy should recognise the proximity to the River Itchen (50m away) to ensure protection of the river and seek enhancements where possible. Borough, City, County and District Councils Hampshire County Council support reference to completion of an off-road walking and cycling route along the Itchen Valley although there are no identified resources at HCC to support delivery of this. Parish and Town Councils Itchen Valley Parish Council object to the allocation and request that SDNPA work with the Parish Council to identify alternative sites. The Parish Council question the ownership of the site (there are two landowners) Other Organisations Upper Itchen Valley Society object to the allocation, as there is no footpath to the village and development would adversely impact the rural setting of a PRoW and the green gap between Itchen Abbas settlement boundary. Agents and Developers One landowner supported the allocation but sought a larger allocation to include land north of the B3047. Individuals A HCC Councillor commented on the allocation stating that any development should be subject to pedestrian routes to the village being improved. An extension to the village to the west of the village would seem more appropriate. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The wording of the allocation policy has been amended to provide clarity and consistency with the rest of the Local Plan including:-

i. Criterion 1(a) addresses the need for development to demonstrate there would be no likely significant effect on the River Itchen SSSI/SAC; ii. Criterion 1(b) and (c) sets out the need for suitable design and landscaping; iii. Criterion1(e) addresses the need for development to demonstrate there would be no harm to the amenity of the adjacent public right of way; and iv. Criterion 1(h) addresses the need for some off-site pedestrian access improvements

 The allocation policy is supplemented by detailed supporting text which sets out the context of the site and the evidence

258

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason n/a n/a

259

Policy SD- DS01: Land between Church Lane and the A273, Pyecombe

Reg 22 (1) (c) (iii) There were a total of 3 comments on this policy/chapter. These are summarised below. National Agencies The Environment Agency state the site is in SPZ2 Borough, City, County and District Councils No comments received Parish and Town Councils No comments received Other Organisations Friends of the Earth (Brighton & Hove) support this allocation with changes. The site should be developed more densely, 8 units seems a low figure compared to other allocations. Reference should also be made to the Brighton & Lewes Downs Biosphere Reserve which the site lies within. Agents and Developers DMH Stallard LLP commented that the allocation should be increased to 12 new dwellings. Individuals No comments received. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

The site has an existing consent for eight dwellings. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason n/a n/a

260

Policy SD- WW02: Land at Farnham Road, Sheet

Reg 22 (1) (c) (iii) There were a total of 2 comments on this policy/chapter. These are summarised below. National Agencies The Environment Agency recommend that the site area is reconsidered to remove the area within the flood zone. The site is also in SPZ2. Borough, City, County and District Councils Hampshire County Council state that nearby Ashford Hangers (SSSI / SINC) should be added as a constraint. Parish and Town Councils No comments received Other Organisations No comments received Agents and Developers No comments received Individuals No comments received

Reg 22 (1) (c) (iv) The representations have been taken into account as follows. The site Land at Farnham Road, Sheet has an existing planning consent (Ref: SDNP/15/05485/FUL) for the erection of 11 dwellings and associated access, parking and open space. As of March 2017, the consent was clearly advanced in terms of it being built out. As such, it was considered that there was no over-riding reason to retain the allocation as set out in the Regulation 18 draft Local Plan.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason n/a n/a

261

Policy SD- SS01: Land South of Loppers Ash, South Harting

Reg 22 (1) (c) (iii) There were a total of 34 comments on this policy/chapter. These are summarised below. National Agencies Historic England support the requirement for a pre-application archaeological assessment and reference to the archaeological constraints on the site. Borough, City, County and District Councils Parish and Town Councils Harting Parish Council support the allocation with changes. The number of dwellings should be reduced to 6 and reference should be made to addressing conflict with other users on New Lane and impact on views. Other Organisations No comments received Agents and Developers No comments received Individuals 24 individuals objected to this allocation. The majority gave reasons for their objection as follows:

 Adverse impact on landscape character, ecology and ecosystem services (including Dark Night Skies)  Loss of views, prominent site – development would be imposing on existing views  Impact of additional traffic - narrow lane is not suitable, conflict with other users, difficult junction with Midhurst Road, parking issues at South Acre, allocation not in line with SD18 Transport and accessibility  Will not provide low cost or affordable housing for local people  Does not relate well to existing settlement pattern, currently outside the Settlement Policy Boundary  Adverse impact on wildlife  Noise / light pollution from construction and long term impacts  Parish Council does not represent the views of the community  Flooding and drainage issues – particularly due to the height difference of the site  Overdevelopment of the site  Alternative more suitable sites in the parish should be considered before this site. Development should be other villages  Currently agricultural land

262

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The wording of the allocation policy has been amended to provide clarity and consistency with the rest of the Local Plan including:-

i. Criterion (1a-b) related to vehicular access and the need for on-site parking; and ii. Criterion (1d) setting out the need for the centre of the site to remain open to preserve views out of the site  The allocation policy is supplemented by detailed supporting text which sets out the context of the site and the evidence

 Specific criteria related to Ecosystems Services are included (2a-b) which relate to pollination and permeable surfaces

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Adverse impact on landscape character, These issues are addressed through draft Local ecology and ecosystem services (including Dark Plan policies SD2, SD4, SD8, SD9 and SD49. Night Skies)

Affordable housing Development will need to provide affordable housing in line with draft Local Plan policy SD28.

Alternative more suitable sites in the parish South Harting is the largest settlement in should be considered before this site. Harting Parish and as such subject to material Development should be other villages. considerations should be focus for planned development rather than other smaller settlements. Flooding and drainage issues The EA does not identify the site as being at risk of surface water or fluvial flood risk. Development proposals should provide suitable utilities in line draft Local Plan policy SD44.

263

Policy SD- SS01: Land at Meadow House, West Meon

Reg 22 (1) (c) (iii) There were a total of 5 comments on this policy/chapter. These are summarised below. National Agencies The Environment Agency state the site in in SPZ2 and there is no existing mains drainage available. Historic England support the requirement for a Heritage Statement Borough, City, County and District Councils Hampshire County Council comment that site will require a site specific flood assessment. Opportunity to formalise footpath link between West Meon footpath 13 and the Meon Valley Trail should also be added. Parish and Town Councils West Meon Parish Council comment that the site has access issues, access should be through Meadow House to make deliverable. Site in within West Meon Conservation Area and will require sensitive design. Other Organisations No comments received Agents and Developers No comments received Individuals No comments received

Reg 22 (1) (c) (iv) The representations have been taken into account as follows. The site would appear to have a covenant restricting development. In addition, there was some uncertainty over whether the site could provide at least five additional dwellings (the minimum size requirement for inclusion in the draft Local Plan) of a typology appropriate for the conservation area. Nonetheless, the site is within the West Meon settlement boundary as such proposals are acceptable in principle and could potentially be bought forward through the development management process. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason n/a n/a

264

Policy SD- SS06: Land at Long Priors, West Meon

Reg 22 (1) (c) (iii) There were a total of 6 comments on this policy/chapter. These are summarised below. National Agencies The Environment Agency state there is no mains drainage available at the site. Borough, City, County and District Councils Hampshire County Council confirm that the amenity of nearby West Meon footpath no.8 must be protected. They also recommend a site specific flood assessment is required. Parish and Town Councils West Meon Parish Council object to this allocation due to the increase in traffic along a narrow road. Other Organisations No comments received Agents and Developers One agent supported this allocation but states the site should be extended to include additional land submitted to the SHLAA. This would provide a further 5 dwellings including additional affordable housing. Individuals No comments received Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The wording of the allocation policy has been amended to provide clarity and consistency with the rest of the Local Plan including:-

i. Criterion 1e and If relate to vehicular access and the need for on-site parking; and ii. Criterion 1g relates to flooding  The allocation policy is supplemented by detailed supporting text which sets out the context of the site and the evidence. This includes inter alia a Flood Risk Assessment and Hydrogeological Survey; and  Specific criteria related to Ecosystems Services are included (2a-d) which relate to non- motorised access, trees, pollination and permeable surfaces.

265

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Mains drainage Development proposals need to accord with draft Local Plan policy SD44 (utilities infrastructure).

Highways Development proposals should be supported by a Highways Assessment and Public Rights of Way It is not considered that the development of the site would harm the PROW. Indeed the development provides potential to link with the PROW.

266

Policy SD- DS03: Land at How Court, Lancing

Reg 22 (1) (c) (iii) There were a total of 10 comments on this policy/chapter. These are summarised below. National Agencies The Environment Agency comment that the site is immediately adjacent to FZ3. Borough, City, County and District Councils Adur & Worthing Council make several comments on this site including:

 Is there landscape assessment evidence to suggest development at this site would not have an adverse impact (wider SHLAA site rejected for this reason)?  There should be affordable housing provision for residents of Adur District Council  Drainage and groundwater issues will need to be considered. West Sussex County Council state a Road Safety Audit would be required. Parish and Town Councils No comments received Other Organisations CPRE Sussex comment that the site is unsuitable for development due to flood risk and surface water flooding issues. The site may also be contaminated (adjacent Old Petrol Filling Station). They also question whether there is further evidence to be considered in the SA process and request to see this evidence. The South Downs Society object to this allocation due to development on agricultural land and encroachment into the open countryside. They note the site was discounted in the SHLAA due to visual impact. Lancing Manor SE Residents / Adur Floodwatch Group object to the allocation due to a number of reasons:

 Conflicts with other policies in the Local Plan  Potential contamination  Adverse impact on wildlife  Flooding / attenuation issues  Conflict with previous SDNPA response to development at Old Petrol Filling station i.e. preserving the character of the SDNP Agents and Developers Lancing College support this allocation but seek the inclusion of a larger site area which forms a critical part of the Estate Plan. Individuals No comments received

267

Reg 22 (1) (c) (iv) The representations have been taken into account as follows. The representations have set out concerns in relation to landscape, flooding, highways and ecology. Essentially, it was considered that development of the site would have adverse impacts on the local landscape and was poorly related to existing settlements. As such, the proposed allocation has been removed from the Regulation 19 draft Local Plan.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason n/a n/a

268

Policy SD- DS02: Land at Normansal Park Avenue, Seaford

Reg 22 (1) (c) (iii) There were a total of 4 comments on this policy/chapter. These are summarised below. National Agencies The Environment Agency state the site is in SPZ3 Borough, City, County and District Councils East Sussex County Council comment that the development should ensure permeability for pedestrians to access local public transport links. Parish and Town Councils Seaford Town Council support the allocation with changes to ensure provision for a children’s play area and green space. The development must be accessible to neighbouring streets. They also recommend land south of the allocation could also be allocated for housing (land outside the SDNP). The Town Council would support an additional allocation at Alfriston Road (SHLAA site LE094) if land for future cemetery extension is secured as part of the allocation. Other Organisations No comments received Agents and Developers No comments received Individuals No comments received Reg 22 (1) (c) (iv) The representations have been taken into account as follows. The site is no longer available for development and as such has been removed from the Regulation 19 draft Local Plan. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason n/a n/a

269

Sites not included in the Local Plan Preferred Options

Reg 22 (1) (c) (iii) There is a total of 1 comment on this policy/chapter. These are summarised below.

Borough, City, County and District Councils Adur & Worthing Councils – Expressed surprise that the Halewick Lane, Sompting site (former Waste transfer Site) had not been included and assessed in the SHLAA, as the NDP group were no- longer including the site within their plan area. It was also noted that Lancing College was not referred to in the Local Plan.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Former waste transfer site, Sompting, not The SHLAA provides evidence for the site included in the SHLAA. allocations but is not definitive. The Sompting NDP has considered this site however the NDP is not being taken forward currently, and no alloction has been made. There is nothing in the Local Plan development strategy that indicates that the site should be considered for an allocation. Lancing College is not referred to in the Local There is no reason why Lancing College should Plan. be specifically referenced.

270

Chapter 10: Development Management Policies

Reg 22 (1) (c) (iii) There were a total of 6 comments on the introduction (paragraph 10.1 and 10.2) to this chapter. These are summarised below. National Agencies There were no comments on this section made by national agencies. Borough, City, County and District Councils Chichester District Council made the following comments:

 The Historic Environment section appears fragmented some included with policies relating to Woodland and Hedgerows and a separate section for archaeology. They suggest a Historic Environment Section structured in a similar way to other sections with an Introduction, Supporting text, policy and evidence. This may allow for some rationalisation of the text/supporting text. The “Partnership Management Plan Outcomes” identified under Archaeology apply to the whole historic environment. Reference should be made to NPPF, NPPG and Historic England Good Practice Advice Notes in Planning (GPANs).  There should be a separate policy on Listed Buildings to include impact of development on the setting of listed buildings and curtilage buildings and structures. East Sussex County Council suggest a reference to minerals and waste development management policies would be appropriate in this section. Parish and Town Councils Rowlands Castle Parish Council note that there does not seem to be a Development Management policy relating to Water Quality as referred to in 'Water Resources' in paragraph 2.26. The plan makes only one reference to 'Groundwater Source Protection Zones' and that is for a single site (policy SD-SS06). Therefore, they comment that the Local Plan would appear to not attempt to generally influence proposed developments in such zones and note that EHDC/SDNP JCS Policy CP26 ('Water Resources/Water Quality') covers this topic, but it will be replaced in the SDNP when this Local Plan is adopted.

271

Other Organisations The South Downs Society made the following comments:

 The Society believes that the policies are generally comprehensive, well written and researched, and are backed by appropriate evidence, in line with NPPF and other relevant guidance. They consider that they should provide a good basis for the day to day assessment of planning applications and give applicants/ neighbours/stakeholders a clear idea of what will, and will not, be permitted.  Welcome the wording at para 10.2 on the importance of appropriate enforcement. While we recognise that the way in which this is carried out is not directly a matter of planning policy, it nevertheless constitutes one of the key tools in the planning toolbox and, without robust and visible enforcement, those – like this Society – with the best interests of the National Park at heart will have difficulty believing in the deliverability of the plan.  Suggest a further “catch all” development management policy covering the “design, form and setting of new development”, bringing together all the essential elements that need to be considered to ensure that new development of all types is successfully integrated into its surroundings. We understand that such a policy is found helpful elsewhere, being used in respect of minor and householder applications, as well as strategic proposals. Agents and Developers There have been no comments from agents and developers that are relevant to this section. Comments about Policy SD22, specific sites and the SHLAA have been considered against the relevant policies. Individuals There were no comments on this section made by individuals. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 In response to feedback at Preferred Options, the Development Management policies have been restructured, so that they follow immediately on from the relevant strategic policy or policies. This addressed the concern over fragmentation of policies.  There is now a separate Policy SD13 relating to Listed Buildings.  With regards water resources and water quality, there is now a Policy SD17: Protection of the Water Environment.

272

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Reference should be made to NPPF, NPPG and This comment has been superseded by Historic England Good Practice Advice Notes restructuring of the document. References to in Planning. relevant national policy and guidance are made throughout the Plan where necessary, however it is not necessary to proliferate the Plan with such references. There should be a reference to minerals and This comment has been superseded by waste development management policies in this restructuring of the document. Paragraphs 1.5 section. and 1.6 of the Local Plan Introduction (Section 1) refer clearly to the need to refer to relevant policies in the minerals and waste development plans. Suggest a “catch all” development management Policy SD5: Design (previously Policy SD6) policy covering the “design, form and setting of comprehensively sets out policy on design new development. matters and is applicable to all development.

273

Policy SD35 Provision and Protection of Open Space

Reg 22 (1) (c) (iii) There were a total of 23 comments on this policy. These are summarised below. National Agencies Only one National Agency, Sport England, responded and objects to the policy as currently worded. In the absence of a robust and up‑to‑date assessment of the needs for open space, sports and recreation facilities and opportunities for new provision under NPPF Par 73, how will the LA assess if a sports facility is ‘valued by the local community’ or actually needed for sport in the absence of this study? Part 2 of the policy should be informed by the NPPF Par 73 study and not dealt with isolated piecemeal responses to individual planning applications. The criteria in the policy must reflect those in Par 74 of NPPF but as currently worded it is less demanding (like for like is not the same as equal or better and there is no requirement on an applicant to demonstrate a surplus). Borough, City, County and District Councils Responses were received from Brighton & Hove City Council (B&HCC), Hampshire County Council (HCC) and East Sussex County Council (ESCC). BHCC represented that the National Park is not an island and relates to adjacent settlements. Its open space may meet the needs not only of the communities within the National Park but also those adjacent to the National Park. They requested that criterion 2 b) be amended by the replacement of the words: "which the SDNPA has identified a deficit" with: "which there is an identified deficit". HCC is concerned that the wording of the policy does not allow sufficient flexibility to secure future improvements to education facilities during the plan period. HCC has proposed an additional clause: 2c) the development will result in local provision of alternative education, sports, recreation or open space facilities, the need for which clearly outweighs the loss of the open space. The justification provided is that “Where central government funding is not available, the only way that education improvements can be funded is through developer contributions and through the disposal of surplus land within school sites.” The County Council is only able to promote the disposal of surplus school facilities for alternative development where it can be demonstrated under Section 77 of the School Standards and Framework Act (1998) that the land is surplus to the requirements of both the subject school and other Local Education Authority (LEA) schools within the local area, and that the proceeds from the sale of the surplus land is re-invested by the LEA into education, sport and/or recreational facilities. They have similarly proposed wording referring to Section 77 of the School Standards and Framework Act (1998) in the supporting text. ESCC has recommended a change to the wording of paragraph 10.5 that states: “open space provision may not be practicable in many instances”. In these instances, it must be stressed that open space provision on-site is required for SuDS schemes. Responses were received from two District Councils: Lewes and Chichester. The former queried the lack of a policy mechanism to deliver open space in the absence of a policy to require appropriate on-site provision or seek developer contributions. It therefore urges the SDNPA to adopt replacement open space standards in its Local Plan to ensure that open space provision effectively keeps pace with the needs arising from the residents of new housing developments. Chichester similarly stated: “The amount of open space for new development should be quantified.”

274

Parish and Town Councils Five parish councils responded, all in favour of the policy. Liss Parish Council recommended that paragraph 1a) be reworded as it is difficult to follow. East Dean & Friston Parish Council especially support the idea of encouraging non-motorised access to any new development, and improving connectivity with the wider rights of way network. Other Organisations Seven other organisations responded, all broadly supportive. Five Villages Cycling Forum made comments regarding insufficient differentiation between the needs of cyclists, walkers and equestrians primarily applicable to policies, SD19 and SD43. However, his comments do merit consideration in relation to the wording in paragraph 1d) which infers a focus on recreational traffic to the exclusion of commuting cyclists. Southern Water cannot support the current wording of policy SD35 as it could create a barrier to statutory utility providers from delivering their essential infrastructure required to serve existing and planned development. They have therefore proposed revised wording for paragraph 2: Planning permission will not be granted for development proposals that would result in the loss of open space unless: (i) like-for- like provision of a similar quantity, quality and accessibility is made in close proximity to the existing open space; or (ii) it meets a specific necessary utility infrastructure need and no alternative site is available. The South Downs Society considers that the supporting text needs to clarify whether the planning policy to protect “open space” embraces not only publicly accessible land such as parks and gardens, but also private facilities such as school playing fields and sports clubs. The latter are equally important to National Park purposes in terms of shaping the form, character, and appearance of settlements and their place in the wider landscape. NFU South East Region has requested rural workers dwellings are made specifically exempt from SD35 to prevent unnecessary and costly delays. Responses were also received from: South Downs Local Access Forum, CPRE Sussex and Friends of the Earth Brighton & Hove which all supported the policy as currently worded. Agents and Developers There were no responses received from this category. Individuals Responses were received from two individual, both of whom support the policy as currently worded.

275

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The policy, introduction and supporting text are all restructured to provide greater clarity, to ensure wording approach is consistent across the Local Plan, and so avoid unnecessary repetition of policy matters, for example 1d is deleted as this is considered to be sufficiently addressed through sustainable transport policies set out elsewhere in the Local Plan.  A study into the open space, sports and recreation standards has been undertaken and standard are set out in the supporting text of the policy.  Text from (2) "which the SDNPA has identified a deficit" changed to "which there is an identified deficit", now criteria 3.  ‘the development will result in local provision of alternative education, sports, recreation or open space facilities, the need for which clearly outweighs the loss of the open space.’ added to now become criteria 3(c).  Paragraph 10.5 is updated to become new paragraph 7.254 to address the recommendation from ESCC regarding SuDs provision, and now says ‘Open space may form part of the requirement to deliver sustainable drainage, if the space is usable and fit-for-purpose. Where insufficient space exists on site to meet local needs then off-site provision in the locality may be sought in line with strategic policy SD45’.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Southern Water propose new wording to Provision of utilities is addressed in the address needs of utility providers development management policy ‘Telecommunications and Utilities Infrastructure’.

276

Policy SD36: Local Green Spaces

Reg 22 (1) (c) (iii) There were a total of 20 comments on this policy. These are summarised below. National Agencies No national agencies commented on this policy. Borough, City, County and District Councils Only HCC responded in this category, echoing the comments made with respect to policy SD35 (see above). No Districts or Boroughs commented on this policy. Parish and Town Councils Nine Parishes / Town Councils responded, all supportive of the policy. A number of these referred to specific Local Green Space (LGS) nominations that parishes either had made separately through the LGS call or wished to make. Selborne Parish Council wish to see the word ‘unacceptable’ removed before ‘adverse impact’ in clause 2 of the policy and Arundel Town Council suggested removal of clause 2; [revised proposed policy wording removes clause 2 in its entirety]. East Dean & Friston Parish Council has queried the wording of paragraph 1, suggesting that it may be better to say that development proposals may be permitted if they ‘include the designation of a new local green space’? Other Organisations Southern Water echoing its comments made with respect to SD35 (see above) has proposed amended wording for clause 2 of SD36 as follows: 2. Development proposals that would have an unacceptable adverse impact on these Local Green Spaces will not be permitted other than in very special circumstances, for example, it is essential to meet specific necessary utility infrastructure needs and no alternative feasible site is available. CPRE Sussex and the South Downs Society both support the policy. The only objection to the policy has been submitted by the Chair of Governors, Selborne CE Primary School but this is solely in respect of its application to the proposed designation of the School Field so not an objection to SD36 per se. Agents and Developers There were no responses received from this category. Individuals There were three comments from individuals supporting the policy but making specific reference to LGS nominations that either had made separately through the LGS call or which they wished to make. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 All nominated sites have been assessed in the Local Green Spaces study. Nominations which fulfil the criteria as set out in the NPPF and PPG are set out in the policy.

277

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason A variety of changes are proposed to the The criteria is deleted as part of a wider policy wording of criteria 2 restructure to avoid unnecessary repetition and to ensure consistent wording between policies throughout the Local Plan.

278

Policy SD37: Trees, Woodland and Hedgerows

Reg 22 (1) © (iii) There were a total of 17 comments on this policy. These are summarised below. National Agencies Natural England make the following comments:

 Hedgerows are a priority habitat, listed under Habitats and Species of Principal Importance’ within the England Biodiversity List, this should be cited here.  The NERC Act 2006 places a general duty on all public authorities, including local planning authorities, to conserve and enhance biodiversity.  Hedgerows provide a vital function as wildlife corridors. They have an important role in genetic dispersal and climate change adaptation. They should be protected from severance.  Concerned that ancient woodland has been included with other woodland and habitats. Ancient woodland merits specific consideration.  Criteria 5 needs to be amended. Ancient woodland is an irreplaceable habitat which requires specific consideration in the planning process. Mitigation (avoidance and reduction of impact) must be considered before compensation.  Planning applications which deleteriously impact ancient woodland must demonstrate how harm can be avoided or reduced (mitigation) before compensation is considered. The role of the local planning authority is to make a judgement as to whether the needs and benefits of the development in that location (as opposed to elsewhere) clearly outweigh the loss.  Ancient woodland is irreplaceable so questions of compensation are highly complex. The policy does not reflect this key point and needs to be reviewed. Historic England ask that reference is made to the historic importance of hedgerows in the supporting text. Borough, City, County and District Councils East Sussex County Council – minor change to supporting text. Parish and Town Councils

 Bepton and Liss Parish Councils support the policy.  Selbourne Parish Council suggest that ancient hedgerows be given specific protection.  Arundel Town Council considers the policy overlaps with SD12 and there is a need for consistency. They recommend that criteria 2 be deleted as it is too restrictive and unnecessary.  Bramshott and Liphook Parish Council support the policy but suggest that consideration be given to that appropriateness of planting proposals along key routes which could impact on views within, to and from settlements.  Itchen Valley Parish Council would like to see more non-native species plants/tree’s removed in favour of native species, particularly in conservation areas. Applicants wanting to remove non-native species should be approved with a requirement to replace with native species if appropriate to the historic landscape.

279

Other Organisations Friends of the Earth Brighton & Hove and the South Downs Society support the policy. The Woodland Trust objects to the policy. They comment on the value of ancient woodland and its irreplaceability. They believe it must be given absolute protection. The Woodland Trust would also like to see an increase in tree cover especially in view of the threats faced by trees and woodland, such as tree disease and its ability to deliver a wide range of benefits. CPRE Sussex give broad support for the policy but make the following comments:

 Protection for ancient woodland and important hedgerows should be included within the Policy.  Concern that loss of trees through planning applications dealt with by delegated authorities will not recognise the cumulative loss.  Should plan for positive planting and land use for carbon sequestration/flooding/air pollution. Would like to see a broader plan for tree planting within the Park (not only linked to individual development proposals) with an preference for the use of native tree and hedge species;  Where their purpose is for screening, these should be of suitable size to achieve that purpose within a short period.  Mitigation is not appropriate where ancient woodland exists. These ecosystems take many years to establish and should not be included in any mitigation strategy.  Mitigation for woodland tends to ignore non-carbon values. The South Downs Land Managers Group comment that:

 In some instances it may be more appropriate to require existing trees, hedgerows and woodland to be managed, as part of the development work and/or subsequently, rather than seeking to protect them or plant new ones.  It should be recognised that not all trees are equal in their value to wildlife or landscape.  Planting should not be required prior to commencement of works, where those works would thereby be delayed adding cost and damage the newly planted trees. The timing of planting should be proposed by the applicant in their application/management plan so as to take account of detailed operational knowledge.  Suggest an additional requirement that a management plan, where appropriate, be drawn up and implemented.  Needs to be qualified by a condition not to impede appropriate tree management by imposing additional cost, complexity or delay. Agents and Developers No responses received.

280

Individuals

 Policy does not go far enough to protect ancient woodland and veteran trees. There should be no further loss of ancient woodland in the National Park.  The Local Plan should specify clear criteria to ensure the protection and protective buffering of ancient / veteran trees and ancient woodland, particularly outside SSSIs.  Two individual support the policy and approach.  There should be much stronger support and requirements for new planting as part of any development.  The density of development should be planned to allow for native broad leaved trees to be planted in positions that will allow them to prosper, and with enough space around them for there to be no possibility of their roots damaging the new houses. This might mean lower densities, but fully grown mature native trees in amongst dwellings is a feature of the existing landscape and all too often absent from modern development.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 ‘Hedgerows are a priority habitat, listed under Habitats and Species of Principal Importance’ within the England Biodiversity List. Hedgerows provide an important function as wildlife corridors. They have an important role in ecosystem services such as genetic dispersal and climate change adaptation. They should be protected from severance’ added to new paragraph 5.94.  Additional wording added to the supporting text to cross refer to the Biodiversity policy which addresses requirements for Ancient Woodland.  Reference to consideration of native tree species when planting new trees added to supporting text.

281

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Concerned that ancient woodland has been Ancient Woodland is also addressed through included with other woodland and habitats. the Strategic Biodiversity and Geodiversity Ancient woodland merits specific consideration. policy. Criteria 5 needs to be amended. Ancient Criteria 5 refers to non-protected woodland. woodland is an irreplaceable habitat which Ancient Woodland is protected and is requires specific consideration in the planning addressed through the Strategic Biodiversity process. Mitigation (avoidance and reduction of and Geodiversity. impact) must be considered before compensation. Recommend that criteria 2 be deleted as it is Protection of root areas and taking into too restrictive and unnecessary. account of future growth is important for the health and future of trees which may be affected by development. Suggest that consideration be given to that Matter is addressed through Landscape appropriateness of planting proposals along key Character and Safeguarding Views policy. routes which could impact on views within, to and from settlements. Would also like to see an increase in tree The importance of trees is recognised by the cover especially in view of the threats faced by SDNPA and this policy. It would not be trees and woodland, such as tree disease and appropriate to require all applicants to increase its ability to deliver a wide range of benefits trees on site, for example where significant tree cover is not commensurate with the local character of the area.

282

Policy SD38: Energy Performance and Historic Buildings

Reg 22 (1) (c) (iii) There were a total of 12 comments on this policy. These are summarised below. National Agencies Historic England welcome and supports the policy in principle but suggest that criteria a) is amended to "The conservation and enhancement of the heritage asset's character and appearance" and critera b) is amended to "The conservation and enhancement of the heritage asset's special architectural or historic significance". Borough, City, County and District Councils Chichester District Council made a number of comments:

 Policy needs to be supported by more guidance and technical information on evidence/detail requirements needed to support planning applications to ensure that potential harmful impacts have been considered, particularly in relation to heritage assets.  Use of the term ‘significance’ should be used to be consistent with Historic England guidance and the NPPF.  There should be a policy on listed buildings  Energy performance covers a wide range of application, including renewables, retrofitting insulation and how the buildings are used. Suggest caution about an overly general policy given the wide range of issues.  Suggest some technical information – either in the policy or supporting text that addresses problems associated with installing wall insulation and the effects on the breathability of traditional construction.  Suggest the policy should require adequate evidence/detail be provided in support of applications so that we can be sure that the potential harmful impacts have been considered, particularly in relation to heritage assets.  Reference could be made to recent BRE research (Solid wall heat losses and the potential for energy saving – BRE May 2014) that confirms the complexity of traditional buildings and gaps in understanding how they perform. There are particular uncertainties about the medium and long-term consequences of applying insulation to solid walls made of traditional materials—the change in the performance of the envelope could lead to changes in the whole building performance (balance of moisture, hydrothermal performance), in the indoor environment conditions and in the overall building condition (decay and damage). Would be cautious about suggesting such proposals will be encouraged. East Hampshire District Council welcomes the policy and supporting text. They are concerned that there are no development management policies relating to listed buildings, the setting of listed buildings and buildings local historic interest. They consider these policies are vital components when deciding applications relating to heritage assets along with guidance contained in the NPPF. Winchester City Council comment that given, the number and range of historic buildings and features within the National Park it is surprising that these policies (SD11, SD38, SD39, SD40 and SD41) are not more comprehensive and provide more guidance as to what is required of development proposals.

283

Parish and Town Councils Bepton Parish Council and Selborne Parish Council supports the policy. Liss Parish Council express strong support for the policy. Other Organisations Friends of the Earth Brighton & Hove support the policy. The South Downs Society supports the policy, but they suggest the addition of the word “historic” before “fabric” in criteria c. Development proposals may be a chance to remove or replace unsympathetic more recent additions/alterations to historic buildings. The South Downs Land Managers Group welcomes the positive approach to improving the energy performance of historic buildings. They consider it disappointing that no mention is made of the preparation of guidance for improving the energy efficiency of historic buildings. The Sompting Estate are generally supportive. They would welcome a proposal in the Local Plan that SDNPA will provide design standards for approaches to double glazing of historic buildings acceptable in the light of the problems of energy conservation and climate change. Agents and Developers There were no comments made by agents and developers on this policy. Individuals One individual states they fully support this statement and if the SDNPA can do anything to reduce the bureaucracy for these buildings, it would be extremely welcome. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Criteria a) is amended to "The preservation and enhancement of the heritage asset's character and appearance" and criteria b) is amended to "The preservation and enhancement of the heritage asset's special architectural or historic significance".  New policy to address requirements related to Listed Buildings added to the Local Plan (Policy SD13).  Supporting text cross refers to the Local Plan policy on Design and also Climate Change and Sustainable Use of Resources.  ‘historic’ is added to criteria c)

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Suggest the policy should require adequate The policy requires that development proposals evidence/detail be provided in support of should demonstrate that a series of matters are applications so that we can be sure that the addressed. potential harmful impacts have been considered, particularly in relation to heritage assets.

284

Policy SD39: Conservation Areas

Reg 22 (1) (c) (iii) There were a total of 17 comments on this policy. These are summarised below. National Agencies Historic England made the following comments:

 Para 10.36 - the New Forest National Park Authority has designated some extensive tracts of open countryside as Conservation Areas.  Welcomes and supports the policy in principle.  Criteria 1 should to say: "…that conserve or enhance the special architectural or historic interest, character or appearance to reflect the rationale for designating conservation areas  Criterion j) should include reference to views out of a conservation area.  Request additional criteria resisting the demolition of buildings or structures that contribute positively to the special architectural or historic interest and the demolition of buildings that contribute to the character and appearance of the conservation area unless the replacement would make an equal or greater contribution to that character and appearance.  Request a requirement for applicants to provide sufficient information to allow an informed assessment of the impact of the proposed development on the special architectural or historic interest of the conservation area (as required for archaeology). Borough, City, County and District Councils Chichester District Council suggest there should be reference to ‘preserve or enhance’ being a statutory test. They request commitment to resist demolition of buildings or structures that contribute positively to the character and appearance of the conservation area and suggest these are defined as part of the character appraisal process and/or identified through the planning process. They suggest the policy could include a reference to a requirement for heritage statements to support applications as mentioned for archaeology. East Hampshire District Council support the policy and supporting text. They are concerned that there are no development management policies relating to listed buildings, the setting of listed buildings and buildings local historic interest. They supports the general principle to tighten up the settlement policy boundaries and link them closer to the boundaries of the conservation areas. Winchester District Council comment that given, the number and range of historic buildings and features within the National Park it is surprising that these policies (SD11, SD38, SD39, SD40 and SD41) are not more comprehensive and provide more guidance as to what is required of development proposals. Parish and Town Councils Arundel Town Council suggest the removal of ‘only’ in criteria 1 and consider it unnecessary. Bepton Parish Council and Selborne Parish Council support the policy. East Dean & Friston Parish Council support the policy. They are pleased to see that it is recognised that development can impact on a Conservation Area if it is visible from within, looking out, as well as looking in, and that it can impact upon the whole character of the settlement. Liss Parish Council strongly support, but suggest that it should include a section on listed buildings and those of local historic interest, particularly as a hook for neighbourhood plans

285

Other Organisations CPRE Hampshire supports the policy and its application. They note that Petersfield’s conservation appraisal and area management plan is recognised and is ‘up-to-date’. However it still needs to be approved as soon as possible so that it can be used with the Neighbourhood Plan and this Plan. Friends of Lewes Society and Friends of the Earth Brighton & Hove support the policy. The South Downs Society support the policy, but suggest the addition of ‘skylines’ to (j) as the impact of development on them can be a key factor in settlements on hills and ridges, such as Lewes. The Petersfield Society support the policy, but are concerned that the conservation area appraisal and management plan for Petersfield has still not been approved by SDNPA and this is now been outstanding for 18 months. Agents and Developers There were no comments made by agents and developers on this policy. Individuals One individual supports the policy and questions whether the Conservation Area in Selbourne should be extended to include more open spaces. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Policy reworded to reduce repetition and to be consistent with policies throughout the Local Plan, for example ‘comply with other relevant policies’ is deleted – the Local Plan is read as a whole.  Reference to ‘conserve and enhance’ changed to ‘preserve and enhance’.  Criteria 1 includes ‘preserve or enhance the special architectural or historic interest, character or appearance of the conservation area’ and references skylines and views out of conservation areas.  New criteria (2) added regarding the demolition of buildings.  ‘Sufficient information to support an improved assessment should be provided…’ added to criteria 2 (criteria 1 in the Pre-submission Local Plan)

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason n/a n/a

286

Policy SD40: Enabling Development

Reg 22 (1) (c) (iii) There were a total of 14 comments on this policy. These are summarised below. National Agencies Historic England support the policy. They would welcome a reference to the use of legal agreements to secure the restoration of the asset prior to completion of the enabling development. They point out that Criteria 2 and para 10.41 should now refer to Historic England rather than English Heritage. Borough, City, County and District Councils Chichester District Council commented that the first sentence of para 10.43 is incomplete and that the policy should include a reference to the use of legal agreements to secure the restoration of the asset prior to completion of the enabling development. East Hampshire District Council support the policy and supporting text. Winchester District Council commented that given, the number and range of historic buildings and features within the National Park it is surprising that these policies (SD11, SD38, SD39, SD40 and SD41) are not more comprehensive and provide more guidance as to what is required of development proposals. Parish and Town Councils Arundel Town Council commented that if this Policy is really necessary, then there seems to be duplication between criteria 1 and 2. Bepton Parish Council support the policy. Rowlands Castle Parish Council question why is it necessary to include the phrase '...... presented as enabling development' This policy appears to contradict, or put severe restrictions on, Policies SD23 (Housing) and SD24 (Affordable Housing). Selborne Parish Council strongly support the policy. Other Organisations Friends of the Earth Brighton & Hove support the policy. Lancing College commented that the SDNPA is actively encouraging and in fact in some instances requires development to be set out within an Estate plan. As stressed within other representations an Estate Plan that is endorsed by the SDNPA will by definition have been agreed to in principle as being required and appropriate in accordance with the Authority's priorities and duties and the Local Plan, or may be agreed to on an exceptional enabling basis. They consider that policy SD40 must also reflect this and recommend suggest amendments to the wording. The South Downs Society support the policy. They suggest adding “demonstrably” before “represent” to emphasise that the onus is on the applicant to show that all other options have been exhausted and that a measure of enabling development is the only realistic option to secure the future of a heritage asset. The South Downs Land Managers Group support and welcome the policy.

287

Agents and Developers Wates Development Ltd commented that the policy does not accord with NPPF Para 140 and should be reworded to reflect this guidance. Individuals There were no comments from individuals on this policy. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

- Please note, this policy is merged with the Strategic Policy for the Historic Environment –  Policy wording is restructured for clarity and to avoid unnecessary duplication through its merging with the Strategic Policy for the Historic Environment.  ‘Use of legal agreements to secure the restoration of the asset prior to completion of the enabling development’ added.  ‘Demonstrated’ added to what is now criteria 6 (b) of the Strategic Historic Environment policy. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Requires development to be set out within an Whole Estate Plans are addressed in another Estate plan. As stressed within other policy in the Local Plan. representations an Estate Plan that is endorsed by the SDNPA will by definition have been agreed to in principle as being required and appropriate in accordance with the Authority's priorities and duties and the Local Plan, or may be agreed to on an exceptional enabling basis. They consider that policy SD40 must also reflect this and recommend suggest amendments to the wording. Wates Development Ltd commented that the Disagree. The policy sets out the criteria by policy does not accord with NPPF Para 140 and which the SDNPA will determine if enabling should be reworded to reflect this guidance. development is appropriate.

288

Policy SD41: Archaeology

Reg 22 (1) (c) (iii) There were a total of 12 comments on this policy. These are summarised below. National Agencies Historic England supports and welcomes the policy, but make the following comments:

 Would like to see the penultimate paragraph of the Policy to require the deposition of the record in a publicly accessible archive.  Do not understand why the Local Plan contains specific development management policies for conservation areas and archaeology, but not for listed buildings, registered historic parks and gardens (we appreciate that these are covered in Strategic Policy SD5, although there is an argument for including that section of that Policy in a separate Development Management policy) and possibly registered battlefields. Advise that development management policies may be required where are necessary to amplify a general, overarching, Strategic Policy for the historic environment within a Core Strategy – for instance, to deal with particularly distinctive or important historic environment features or significance.  Consider that a lack of listed building policy is a significant omission from the Plan. They also request a specific DM policy on Registered Historic Parks and Gardens.  Suggest it would be helpful, in para 10.44, to point out that non-designated archaeological remains of demonstrably equivalent significance to scheduled monuments should be considered against the policies in the NPPF for scheduled monuments.  They suggest it could be noted, in para 10.48, that preservation by record is the least preferred option but where it takes place, the record should be placed in a publicly accessible archive. Borough, City, County and District Councils Chichester District Council made a number of comments on the supporting text:

 Para 10.43 - Walls are not generally regarded as ‘finds’.  Para 10.44 - The wording may lead to confusion over the definition and status of non- designated heritage assets. Recommend deletion of the words ‘may be referred to as non- designated heritage assets and’ from the fourth sentence.  Para 10.45 – Suggest reiterating the wider significance of the archaeological resource, perhaps by the insertion of e.g. ‘and its contribution to the wider historic environment’ to the penultimate sentence.  Para 10.46 - Usually ‘desk-based’ rather than ‘desktop-based’.  Para 10.47 - Avoid the phrase ‘archaeologically sensitive areas’ which was previously used by WSCC for non-designated areas of significance. Perhaps remove the word ‘archaeologically’.  Para 10.48 - This section seems confused: the significance of relevant archaeological remains should be established in a desk-based assessment whereas the proposed methodology for their preservation should be outlined in the written scheme of investigation.  Para10.49 - This seems to contain two completely separate issues that should be in their own sections.

289

East Sussex County Council made a number of comments:

 Suggested that the following changes to these sections are made to clarify that the Written Scheme of Investigation (WSI) is the document setting out the scope of a programme of archaeological work. All heritage professionals and archaeologists are bound by professional requirements to produce a WSI (or project design) for any piece of work that they propose to undertake.  Suggested that reference is made to the local authority standards as this is a Local Plan and it will sit better with the reference to the national standards of the Chartered Institute.  Para 10.49 - Those projects that affect significant archaeological remains such as major infrastructure projects, projects within historic urban centres, particularly those which are the subject of an extensive urban survey and any other projects where significant archaeological interest has been established may require a programme of archaeological work, the details of which will be set out in a written scheme of investigation. This will include a programme which promotes a wider understanding and appreciation of the site’s archaeological heritage in a local and regional context.  Para 10.50 -The programme of archaeological work that the Authority may wish to secure could take the form of evaluation survey and mitigation recording such as an archaeological excavation, historic building record or a watching brief, along with the appropriate level of post-excavation assessment, analysis, reporting and archiving. The scope of the programme of archaeological work will be set out in the written scheme of investigation and this shall meet the requirements of the relevant standards of the Chartered Institute for Archaeologists (CIfA) as well as locally relevant standards produced by the local planning authority archaeological advisors and be agreed by the Authority. Winchester District Council commented that given, the number and range of historic buildings and features within the National Park it is surprising that these policies (SD11, SD38, SD39, SD40 and SD41) are not more comprehensive and provide more guidance as to what is required of development proposals. Parish and Town Councils Arundel Town Council suggest deletion of “only” in criteria 1 and consider this to be unnecessary emphasis. Bepton Parish Council supports the policy. Cheriton Parish Council make reference to the 29th March 1644 battle of Cheriton and consider that any development in Cheriton must have a full archaeological survey to collect artefacts still in situ. Selborne Parish Council supports the policy in principle, but request deletion of the word "unacceptable" in criteria 1, because it is not acceptable to allow harm to heritage assets. They are also dismayed to see that the Authority might permit an unavoidable harm. If it is known that harm would be caused, it cannot be unavoidable and request deletion of the word "unavoidable" Other Organisations Friends of Lewes Society, Friends of the Earth Brighton & Hove and South Downs Society support the policy. Agents and Developers There were no comments made by agents and developers on this policy.

290

Individuals There were no comments made by individuals on this policy.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Listed buildings policy added  General review of the supporting text addressing various wording comments raised by WSCC and ESCC above.  ‘It is widely recognised that there are sites which have an equal significance, but which are non-designated heritage assets. If the significance of such sites have been demonstrated, they will be treated in the same way as Scheduled Monuments’ added to the supporting text of this policy.  Text making reference to preservation by record as being the least preferred option but where it takes place, the record should be placed in a publicly accessible archive to paragraphs under section heading ‘In-situ archaeological heritage assets’ of the supporting text to this policy.  Word ‘only’ and ‘unacceptable’ removed from criteria 1.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Request a specific DM policy on Registered It is considered that Registered Historic Parks Historic Parks and Gardens and Gardens are suitably addressed through the Strategic Policy on Landscape Character. Remove criteria which may allow unavoidable Proposals which would result in unavoidable harm harm will only be permitted where there is justification of public benefits which outweigh that harm.

291

Policy SD42: Sustainable Drainage

Reg 22 (1) (c) (iii) There were a total of 17 comments on this policy. Overall comments were supportive with suggested improvements. Only one response advocated withdrawal of the policy and inclusion in a broader ‘water or flood management’ policy. Comments received are summarised below. National Agencies The Environment Agency (EA) was the only National Agency to respond; the EA supported the inclusion of the policy but recommended that the use of SuDS are advocated for all new development, not just in areas at risk of flooding. County Councils East Sussex County Council (ESCC) was the only County Council and Lead Local Flood Authority (LLFA) to respond. They proposed some minor improvements to the supporting text and also an additional paragraph pertaining to land drainage consents as planning permission does not necessarily mean that consent will be given to the culverting or diversion of an ordinary watercourse. ESCC commented extensively on the wording of the policy, specifically:

 Expressed concern that the criteria outlined in policy SD42 selectively quotes the national non-statutory technical guidance and therefore does not provide guidance for the ESCC local flood risk situation;  In the light of the above recommended that national guidance is not repeated in the Local Plan; and  Recommended that a section regarding brownfield sites is included in this policy. They have provided alternative wording for the preamble and para 1 of the policy. Borough, City, County and District Councils Comments were only received from 2 District Councils, Lewes and East Hampshire District Council (EHDC). Lewes District Council expressed support for the policy advising that promoting the use of SuDS to reduce the district’s vulnerability to the flooding is a key priority of the Council. EHDC Neighbourhood Plan and CIL coordinator considered that the section contained a lot of technical detail on SUDs and recommended withdrawal of the policy and inclusion in a broader ‘water or flood management’ policy. Parish and Town Councils Comments were received from 7 parish councils: Bepton; East Dean and Friston; Cheriton; Liss; South Harting; and Selborne. 6 were supportive of the policy (1 neutral response) but Selborne was extremely alarmed to see in paragraph 1 that the NPA may intend to permit development in areas that are known to be at risk of flooding and recommended deletion of this phrase. Other Organisations Responses were received from 6 other organisations: CPRE offices in Hampshire and Sussex; Sussex and Hampshire & Isle of Wight Wildlife Trust; Friends of the Earth, Brighton & Hove; the Gilbert White Museum; South Downs Society; and Portsmouth Water. All with the exception of CPRE supported the policy; CPRE consider the evidence for the success of SuDs is not proven and that trees and hedgerows play a larger part in slowing water flow and allowing it to permeate more slowly into the ground. CPRE also consider that SuDs is an urban solution and its appropriateness across the South Downs may be questionable.

292

The Wildlife Trusts stated that the policy would align better with the environmental ambitions of the plan if it included a requirement for SuDS to enhance biodiversity where possible. Portsmouth Water recommend the addition of text in this section recognising that infiltration drainage is unlikely to be appropriate in Source Protection Zone 1 and 2. Agents and Developers There were no responses received from Agents and Developers. Individuals There were no responses received from individuals. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The Policy and supporting text has been revised and simplified significantly by reducing the amount of detailed technical criteria which may soon be rendered obsolete by changes to national guidance.  The policy has been further simplified by moving previous criteria to the supporting text regarding the need to take account of appropriate evidence and characteristics on a site-by- site basis;  The policy now requires sustainable drainage systems for all major developments whether in flood risk areas or not. These are also advocated for other development proposals where required by the Lead Local Flood Authority (LLFA) and identified in the Local Plan SFRA.  Criteria 3 of the policy requires Suds to be designed to provide multuiple functions including benefitting biodiversity;  Para 7.289 provided guidance on infiltration as recommended by Portsmouth Water. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason CPRE considers the evidence for the success of Disagree with these comments. The multi- SuDs is not proven and that SuDs is an urban functional benefits of SuDS are widely solution. acknowledged. They can be designed to be naturalistic in character responding to the site context.

293

Policy SD43: Public Realm and Highway Design

Reg 22 (1) (c) (iii) There were a total of 21 comments on this policy. These are summarised below. National Agencies Historic England welcomed the policy, especially criterion 3, and proposed referring to their publication ‘Streets for All’ in the supporting text. Borough, City, County and District Councils Brighton & Hove City Council asked for Criterion 1 to be amended to read ‘maintain and where possible enhance highway safety’ West Sussex County Council suggested that Criterion 1 could be amended to read ‘follow the principles set out in Roads in the South Downs where appropriate’.

Chichester District Council proposed referring to Buildings for Life in terms of road hierarchy, mix of parking provision and avoiding long rows of end-on parking. Parish and Town Councils General support was expressed by four parishes along with interest in and support for Roads in the South Downs. Rowlands Castle Parish Council requested that signage should respect distinctive environments, and that more consultation on signage should be required. Twyford Parish Council expressed concern that the policy is too general to protect against increasing traffic volumes, and needs to be more precise, for example by identifying which roads fall into which category in ‘Roads in the South Downs’ Other Organisations General support from five groups Support for ‘Roads in the South Downs’ Concern over the different surfaces required by cyclists and horse-riders Two requests to add in text requiring the needs of large agricultural vehicles to be taken into account in highway design. One request for road signs to be more locally distinctive. Agents and Developers No respondents in this category commented on this policy. Individuals One respondent stated that there is public support for the retention of traditional wooden signposts and asked for the NPA to publish a design guide on this topic.

294

Reg 22 (1) (c) (iv) The representations have been taken into account as follows. Brighton & Hove City Council asked for Criterion 1 to be amended to read ‘maintain and where possible enhance highway safety’. The criterion has been amended to read ‘’protect and enhance highway safety’. This wording is consistent with that used throughout most of the plan. Several comments related to the provision of locally distinctive road signs. This is an element of the principles of ‘Roads in the South Downs’, as mandated in Criterion 1. In addition, a requirement has been inserted into paragraph 6.26 for contributions to ‘the adaptation of existing highways so that standardised road infrastructure can be minimised in a way consistent with highway safety’. Two requests were received to add in text requiring the needs of large agricultural vehicles to be taken into account in highway design. This requirement has been included in paragraph 6.33. Historic England proposed referring to their publication ‘Streets for All’ in the supporting text. This reference has been inserted in paragraph 6.35.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason West Sussex County Council suggested that This reduction in the weight attached to “Roads Criterion 1 could be amended to read ‘follow in the South Downs” is not considered the principles set out in Roads in the South appropriate. The suggestion is said to be Downs where appropriate’. motivated by concerns over highway safety, but the policy also requires development to ‘protect and enhance highway safety’, so safety will not be compromised. As the policy stands, in the unlikely case that a development could only be delivered safely by the use of highway design measures that contradict the principles in Roads in the South Downs, that could be a reason for refusal. If the suggested change was made, this would no longer be the case. Twyford Parish Council expressed concern that The purpose of the policy is not to protect the policy is too general to protect against against increasing traffic volumes- that issue increasing traffic volumes, and needs to be would be dealt with by policy SD19: Transport more precise, for example by identifying which and Accessibility. The guidelines in Roads in the roads fall into which category in ‘Roads in the South Downs make it clear which roads it South Downs’. covers- namely, all but the very largest.

Referring to Buildings for Life in terms of road Potential confusion arising from reference to hierarchy, mix of parking provision and avoiding too many guidance documents. long rows of end-on parking. Concern over the different surfaces required Surfacing is an element of design so this point by cyclists and horse-riders. will be covered by Criterion 3 of the new policy (was Criterion 2).

295

Policy SD44: Vehicle and Cycle Parking Provision

Reg 22 (1) (c) (iii) There were a total of 21 comments on this policy. These are summarised below. Borough, City, County and District Councils Brighton & Hove City Council and East Hampshire District Council both expressed an interest in any SDNPA parking standards and a desire for further discussion on the topic. Brighton & Hove City Council suggested retitling the policy ‘Parking Provision’, adding reference to parking for disabled people under bullet point 2, and providing more information on the findings of the Transport Study. Chichester District Council would like to see a proportion of electric car bays, or cabling to enable their future provision, on new public car parks. They raised concerns about underprovision of car parking on new developments in the market towns, and a wish for a policy supporting coach parking and more definition of ‘obtrusive’ car parking. Parish and Town Councils There were four expressions of general support Two parish councils noted a need for additional parking within their village, with one saying the policy accommodated this need and the other that it should be more encouraging. Liss Parish Council requested that the plan place more emphasis on parking for railway stations Other Organisations There were three expressions of general support More clarity on appropriate levels of parking provision was requested Requests were made for: A criterion to resist inappropriate conversion of gardens to parking space, as per the NPPF. A criterion requiring new car parks to be linked to attractive walking routes to other parts of the settlement they are in. More emphasis on disability, including mobility scooters More emphasis on the potential for cycle commuting and therefore cycle parking. A criterion dealing with rural parking at visitor hot spots Reference to horse transport vehicles, and a policy to protect visitor infrastructure e.g. car parks without height barriers. The National Trust objected to the policy, requesting an allowance for new, extended or re-located car parks to serve rural visitor attractions, subject to certain criteria. Agents and Developers Callstone Ltd requested that the policy be worded flexibly. Individuals There were two requests for discussion of horse box parking.

296

Reg 22 (1) (c) (iv) The representations have been taken into account as follows. Brighton & Hove City Council suggested retitling the policy ‘Parking Provision’. This change has been made. Requests for amendments relating to rural visitor attractions have been addressed by expanding the first criterion of the policy so it also applies to sites with a strong functional link to an established cultural heritage, wildlife or landscape visitor attraction. This also makes the policy more flexible, which was another request received. Some responses related to more emphasis on parking for people with disabilities. While the provision of dedicated disabled parking spaces is largely covered by county level guidance, already cross-referred to by the policy, additional reference to this point has been added into the new Paragraph 6.46. In addition, a requirement has been added into the policy for public car parks to provide charging facilities for mobility scooters, where relevant. More emphasis on cycle parking was requested. This has been addressed by changing references throughout the policy from ‘vehicle parking’ to ‘parking’, to make clear that all types of parking are covered. Levels and detailed standards for cycle parking will continue to be set at a county level. Chichester District Council proposed a requirement for electric car charging facilities on public car parks. This has been included. More information on the findings of the Transport Study was requested. This is presented in the Transport Background Paper. A criterion to resist inappropriate conversion of gardens to parking space was proposed. This has not been included in the policy, but a new paragraph 6.44 has been inserted into the supporting text to aid decisions on when such conversion would be appropriate. Reference to horse transport vehicles and their parking was suggested. In response a new criterion 4b has been inserted into the policy requiring provision for such parking on new public car parks with good accessibility to the bridleway network.

297

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Brighton & Hove City Council and East The SDNPA no longer intends to produce its Hampshire District Council both expressed an own parking standards. Rather, it will continue interest in any SDNPA parking standards and a to support the provision and updating of desire for further discussion on the topic. parking standards and guidance by Local They raised concerns about underprovision of Transport Authorities. Other issues related to car parking on new developments in the market these standards would be covered by this work. towns,

The policy is aimed at facilitating appropriate Request to be more encouraging of additional and necessary car parking in the most parking within their village. sustainable villages.

Liss Parish Council requested that the plan Facilities at railway stations are covered in place more emphasis on parking for railway policy SD19. While this policy would in principle stations allow for increased parking at railway stations, such provision is not a priority for the SDNPA. More definition of ‘obtrusive’ car parking was ‘Obtrusive’ means ‘Noticeable or prominent in requested. an unwelcome or intrusive way’ (Concise OED, 2008); the assessment of landscape impact of car parks would be in line with Policy SD4: Landscape Character.

298

Policy SD45: Replacement Dwellings and Extensions

Reg 22 (1) (c) (iii) There were a total of 36 comments on this policy. These are summarised below. National Agencies Only one comment was received from a National Agency – Historic England. They gave support to the overall principle of the policy, in particular support for criterion 2b) which aims to protect the established character and pattern of the surroundings. It was noted that criterion 1a may be too restrictive to require environmental benefits and questioned whether a proposal causing no additional environmental harm would be acceptable. Borough, City, County and District Councils Two district councils made representations on this policy, Chichester District Council (CDC) and East Hampshire District Council (EHDC).

 Again clause 1a) was highlighted and the question asked “What if there is no material harm” in the resiting of a replacement dwelling, would this be acceptable.  Questioning the ability of Clause 2d) to protect the stock of existing small dwellings (as defined in para. 10.87 ii) given that Permitted Development Rights would already allow some small dwellings to extend floorspace over the 100m2 threshold, resulting in the loss of a small dwelling.  It was recommended to differentiate between heritage assets and non-heritage assets, as in Policy SD49 Conversion of Redundant Agricultural Workers Dwellings.  Both questioned the definition of “materially larger” requesting clarification.  Suggested cross referencing SD6 Design and stating SDNPA support for low carbon development. Parish and Town Councils Ten Parish/Town Councils commented on this policy. Many gave broad support to the policy, some seeking clarification on the overall purpose and definitions of clauses or phrases used, including:

 Why only allowing a 30% increase?  What is the justification for a 1982 base date?  Definition of “materially larger” Others considered the policy inconsistent and unfairly restrictive to all villages outside the named market towns.

 Same allowance of percentage increase for extensions should be given for replacement dwellings  Does not refer to or limit cumulative extensions

299

Other Organisations Seven groups or organisations responded to this policy. They were generally supportive.

 CPRE Hampshire stated that the policy is too restrictive due to not allowing extension to floor area of a replacement dwelling. It was also noted that the policy did not mention garages and other outbuildings (2f).  CPRE Sussex was broadly supportive of the policy but commented that clause 2e) was too restrictive, particularly within other settlements with a Settlement Policy Boundary.  South Downs Land Managers Group thought that Clause 2e) again felt to be too restrictive. Either apply the same increase to all dwellings or at least all smaller dwellings, regardless of location in market towns.  The South Downs Society questioned why a 30% threshold has been applied and concern over challenge at appeal which would weaken the policy over time.  The South Downs Local Access Forum aid that the policy currently doesn’t address the effect of cumulative extensions  Friends of the Earth (Brighton & Hove) support the policy  Friends of Lewes raised concerns over annexes becoming independent dwellings. They suggest including ancilliary and remain in the same ownership to clause 2f) Agents and Developers Agents and landowners responded on behalf of six estates. All had very similar comments:

 The purpose of clause 1c) was said to be unclear, questioning whether it was to retain small dwelling stock and seeking clarification and justification.  The policy should recognise that some buildings occupy very large plots where increases in number of buildings would not harm the landscape character or amenities of nearby residents.  Extensions should not be arbitrarily limited in size given the lack of housing, cost of moving and affordability issues in the region. The appropriateness of a proposed extension should be based on its landscape impact, not standard size threshold.

300

Individuals Several individuals commented on this policy, with many commenting on the same clauses:

 1a &2e) – questioning the fairness of having different standards for the four named market towns and all other areas of the National Park. It should differentiate between development within and outside Settlement Policy Boundaries  Noting the contradiction within the two clauses of the policy which allows for increased floorspace through extensions but not when replacing a dwelling. This could encourage piecemeal extensions rather than encouraging comprehensive and coherent redevelopment.  Visual subservience does not automatically lead to good or sympathetic design and should be judge in each development proposal rather than applied as a blanket requirement.  Why does clause 1 only apply to dwellings that don’t make a positive contribution? There is potential for a replacement dwelling to be of equal quality/value or make a greater contribution than the existing dwelling.  Clause 1a) was considered too restrictive and the suggestion made that a proposal with no net harm or “environmental disbenefit” should be permitted.  One comment was made on the impractical nature of clause 1a) when many people live in their current home during the construction of a replacement dwelling  Several representors questioned definitions within the policy (materially larger, positive contribution) as well as the justification for trying to preserve the stock of smaller homes.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Policy SD45 (Replacement Dwellings and Extensions) of the Regulation 18 ‘Preferred Options’ draft Local Plan has been significantly revised. This includes splitting the policy into two policies in the Regulation 19 draft Local Plan: SD30 (Replacement Dwellings) and SD31 (Extensions to existing dwellings, and provision of annexes and outbuildings);  Policy SD30 sets out two criterion. Criterion 1a limits the increase of the gross internal area to a maximum of 30% and criterion 1b sets out design and amenity considerations;  Policy SD30 also sets out the replacement of one dwelling with up to three smaller dwellings subject to addressesing criterion relating to size, layout, design, parking and storage. Permitted development righst, where they exist, may also be controlled (Criterion 3);  Criterion 2d (it does not result in a loss of a small dwelling) of Policy SD45 is removed from the revised draft Local Plan policy SD30 as it considered inappropriate to use a development management policy to achieve a strategic planning objective (retention of smaller dwellings);  The term ‘materially larger’ has been removed from the policies;  The 30% figure in Policies SD30 and SD31 was retained from Policy SD45 as it was considered that this provided ample scope to extend replacement dwellings where proposed. Agree that replacement dwellings and extensions should be given the same scope to extend.  The reference to 1 July 1982 in the supporting text is removed;  The reference in Policy SD45 criertion 1c. to a different approach between the larger settlements (Petersfield, Midhurst, Petworth and Lewes) and all other settlements is removed in policies SD30 and SD31. Instead, the revised policies are both ‘global’ i.e. they apply everywhere in the National Park.  Policy SD31 addresses outbuildings and annexes;

301

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason It was recommended to differentiate between Disagree. It is considered that the relevant draft heritage assets and non-heritage assets Local Plan policies should be applied if the dwelling is also a heritage asset.

Suggested cross referencing SD6 Design and Generally the draft Local Plan avoids cross- stating SDNPA support for low carbon referencing. If this approach were to be development. adopted then it could result in a denser and less accessible plan. Broadly, all draft Local Plan policies apply where relevant and in the case of replacement dwellings policy SD6 would apply more often than not. Low carbon development is broadly supported in principle.

The policy currently doesn’t address the effect Both policies SD30 and SD31 set out size limits of cumulative extensions. and the restriction of future permitted development.

Concerns over annexes becoming independent Supporting text paragraph 7.96 sets out that dwellings. annexes must be in the same ownership. This can be secured through suitable conditions or planning obligation.

The policy should recognise that some buildings The policies do not address new buildings per occupy very large plots where increases in se. number of buildings would not harm the landscape character or amenities of nearby residents.

302

Policy SD46: Agriculture and Forestry

Reg 22 (1) (c) (iii) There were a total of 43 comments on this policy. These are summarised below. Parish and Town Councils General support was offered. One parish council requested that emphasis remain on the two Purposes of the National Park when considering agricultural applications There was a request to discourage the replacement of traditional wooden gates with steel ones On paragraph 10.107: there was a request to loosen, as three years is too short; or remove entirely. On paragraph 1f) there was a request to tighten, as three years is too short; another request to loosen, as three years is too long; and one suggestion that this needs to refer to the property, not the owner, to prevent change of ownership circumventing the condition. On the final criterion, we were requested to replace ‘unacceptable adverse impact’ with ‘harm’; or delete. One parish council requested that we require designs, materials and colours that blend into the countryside, especially green or dark colours for barns. Other Organisations Comments from estates, farm businesses and organisations representing them: There was a comment that Purpose 1 must take priority over all others. Four respondents supported recognition of permitted development (PD) rights in supporting text Criterion 1(b): there were two requests to replace ‘adverse’ with ‘unacceptable’ to allow for a measure of adverse impact on the locality, or to add ‘significant adverse’ Criterion 1(c): Two respondents wrote that we should clarify horticulture as part of agriculture Criterion 1(e): Two respondents requested that this refer to the contribution of existing landscaping Criterion 1(f) re. new buildings to replace ones recently disposed of: Comments received on this criterion included: One respondent thought that the aim is understandable. Five respondents suggested removal of this criterion, to allow for buildings going out of use during downturns. One respondent thought that the criterion should require conditions when the use of a building is changed, to remove PD rights for new buildings on the site. Two respondents suggested the addition of ‘if that need was reasonably foreseeable at the time of disposal. One respondent asked that the it should state ‘the avoidable disposal of a building’ Four respondents wrote that the policy should recognise that sometimes old buildings are not fit for purpose and need replacing.

303

Supporting text para. 10.107 on dismantling disused buildings: This paragraph received multiple objections on the grounds that it is too restrictive, would discourage investment, would prevent cyclical changes in farming, and that some agricultural buildings are heritage assets; Eight respondents asked for it to be removed; two that the time limit should be increased to ten years or more; two that we should either insert a clause that this will only be applied to exceptionally unattractive buildings, or substantially increase the number of years; and one that it should only apply to modern buildings. One respondent agreed with the principle but was concerned there was not enough provision for its enforcement. Criterion 2(b) on considering other opportunities before applying for new forestry tracks- One respondent commented that this should not say ‘all’ other possible opportunities, this could be read as including ceasing forestry operations. Concern was expressed over the subdivision of farms into small plots which develop various buildings with a weak agricultural justification eventually becoming in essence luxury residential plots. This respondent suggested that we need to tighten definitions with regard to agricultural need and the erection of buildings with the potential for conversion to residential, and only grant permission for agricultural development to genuine farming businesses on viably sized plots with long-term plans. State that permission will not be granted for change of use of recent buildings. Support was expressed for criterion 3 Other organisations: General support was expressed. Strong support was expressed for the removal of redundant buildings after three years; this should be included in the policy wording. One respondent requested that we include here the requirement for farm diversification to support the core agricultural use. On criterion 1(f): there was a comment that this should refer to the property, not the owner, to prevent change of ownership circumventing the condition. One respondent requested that we insert a criterion requiring the development to meet a financial test that it contributes to the viability of the business overall. There was a request that the Local Plan should refer to food security, the Special Quality of agriculture, and food miles, and to conserving and enhancing land in agricultural use. Support was received requiring buildings to be close to existing ones wherever possible. One respondent stated that colour and materials are critical and need to be agreed before construction. There was a comment that Criterion 2 should include agricultural tracks.

304

Individuals Cllr Ient of Lewes District Council requested the policy include measures to ameliorate the visual impact of new barns, with reference to materials, roof treatment and also traffic routing. The same respondent stated that the NPA should discourage farm structures on the Downs e.g. pig arcs at Redgate Pig Farm, Bramber, and strongly encourage landscaping of roofs where they do exist. There was a comment that paragraph 10.107 was too restrictive, demolition could be costly and would restrict changes in farming practice; and that the paragraph should be removed Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

Paragraph 10.107 of the supporting text, on conditions requiring the removal of redundant buildings, received many comments. This paragraph has been replaced by 7.195, which- in line with several proposals from consultees- would only place this requirement on buildings granted permission in exceptional circumstances, and would allow for a longer period of vacancy.

There were requests for Criterion 1e to reference the contribution of existing landscaping. The criterion (now 1d) and relevant supporting text have been amended to reflect both new and existing landscape elements.

Criterion 1f, restricting the proliferation of buildings where serviceable ones already exist, received a variety of comments, both positive and negative. The SDNPA believes this policy is sound but has followed some suggestions by inserting an allowance for exceptions in the supporting text. In line with one suggestion, the policy now refers to holdings rather than to their owners.

There was a request to amend Criterion 2b to reduce the demand for assessment of alternative options, with regard to new tracks. This criterion has been re-written so as to put the focus onto options using existing tracks.

The final criterion has been removed, in accordance with one suggestion (and also in line with the revised policy writing approach). Several respondents asked for mention of the importance of designs, materials and colours. This has been followed up in the supporting text (Paragraph 7.190). There was a comment that Criterion 2 should include agricultural tracks. The criterion has been changed accordingly.

305

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Discourage the replacement of traditional This is not a matter that can be affected by wooden gates with steel ones planning policy.

Requests for changes to Criterion 1b This criterion has been deleted entirely, since it replicates other policies in the Local Plan. Clarify horticulture as part of agriculture in Not necessary; this definition is well established Criterion 1c in planning law. Tighten definitions with regard to agricultural The policy already requires agricultural need and the erection of buildings with the buildings to be designed as such, rather than potential for conversion to residential, and only with residential conversion in mind. It is not grant permission for agricultural development considered that a blanket ban should be placed to genuine farming businesses on viably sized on genuine agricultural developments on small plots with long-term plans. units. Include here the requirement for farm This is better dealt with in the farm diversification to support the core agricultural diversification policy. use. Insert a criterion requiring the development to This would seem to be an onerous requirement meet a financial test that it contributes to the for little benefit, since a development which did viability of the business overall. not contribute to the viability of the business would be unlikely to go ahead. The Local Plan should refer to food security, The introduction to the section already refers the Special Quality of agriculture, and food to the Special Quality of agriculture. The other miles, and to conserving and enhancing land in matters mentioned here are better covered by agricultural use. Policy 2: Ecosystem Services

306

Policy SD47: Farm Diversification

Reg 22 (1) (c) (iii) There were a total of 36 comments on this policy. These are summarised below. Borough, City, County and District Councils Hampshire County Council give general support to the policy. Parish and Town Councils General support from two parish councils. Support for criterion 1 that there should be no harm to the Special Qualities. One parish meeting expressed concern about the procedure for considering farm and estate plans, requesting a criterion to say that, to be applicable, farm and estate plans must incorporate the results of community consultation and must be provided to the Planning Authority for review not less than three months prior to the submission of connected planning applications. One parish council requested that the policy contain clear criteria, be applied with practicality and without undue costs. One request for the policy to require designs, materials and colours that blend into the countryside Other Organisations Estates, farm businesses and those representing them Criterion 1: One respondent stated that ‘no harm to the special qualities’ is unachievable, instead harm should be minimised and balanced by the benefits of the proposal; another proposed the phrase ‘No unacceptable adverse impact’. Criterion 2 (what kind of buildings should be used for farm diversification) General support was offered. Five respondents supported the policy preference for characterful buildings, but objected to the age criterion. Two respondents proposed that the policy should allow for the conversion of modern buildings that make no positive contribution to the landscape where they can be screened or weatherboarded to reduce landscape impact, and one proposed allowing for isolated new buildings where they are well screened. Criterion 3 (demonstrating long-term benefit to the farming business): Seven respondents requested that the requirement for comprehensive plans be proportional to the scale of development proposed. One questioned the need for this requirement in principle.

307

Criterion 4 (diversified activities remaining ancillary to the farming operation): Multiple general objections were received to this criterion. Specifically: One respondent questioned the need the policy; One proposed that diversification should be allowed to include the rental of space to unconnected businesses; Two asked for the criterion to be removed entirely; One, while agreeing with much of the supporting text on the issue, proposed specifying that the policy relates to the scale of diversified activity not being out of proportion to the farm, as opposed to ownership structure; One objected that farmers should not be forced to maintain an unviable farming enterprise; Two objected to the fact that the policy could be interpreted as requiring diversified businesses to make less profit than the farm, which could entail making a loss themselves. Supporting text Five respondents requested positive reference to permitted development rights as a baseline. One respondent supported the section of supporting text on outdoor storage With regard to the list of possible diversified enterprises in paragraph 10.115: Three respondents request that the list not be restrictive, and the phrasing changed to reflect this One requested that the reference to ‘processing the outputs of sustainable livestock farming’ be changed to ‘the outputs of agriculture and forestry’. One asked for the wording on tourist accommodation to be tightened to prevent it subsequently being converted to housing. Other organisations General support from three organisations One respondent proposed adding a requirement to the supporting text that new buildings be compatible in character with the surrounding buildings. Individuals Criterion 2: One proposal that the policy should allow for the conversion of modern buildings that make no positive contribution to the landscape where changes can be made to them so that they do make a positive contribution to the landscape; e.g. through external insulation. Criterion 4: Five objections to the criterion requiring that diversified businesses be subsidiary to the main farm enterprise. One of these pointed out that it would be quite easy for a successful diversified business to exceed the turnover of the main farm enterprise. 10.115 (list of possible diversified enterprises): One request that the list in 10.115 not be restrictive, and the phrasing changed to reflect this.

308

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

Various changes were proposed to Criterion 2 regarding the type of buildings that could be converted for farm diversifaction use, and where new buildings would be appropriate. This criterion (now 1b) has been amended to reflect the fact that policy SD41 covers the conversion of farm buildings in much more detail, so replication is not necessary. The locational requirements for new buildings have been slightly loosened.

Requests were received for the diversification plan to be proportionate in detail to the scale of the project. This has been incorporated into Paragraph 7.198 of the supporting text.

Multiple responses were received on the original Criterion 4, the requirement for diversified activities to remain ancillary to the farming operation. Many of these seem to have been based on misunderstanding of the intention of this policy, so the correct interpretation has now been clarified in the supporting text.

Queries were received on the original list of potential diversified activities, in paragraph 10.115. The introduction to this list ahs been changed to make clear that the activities on it are examples of potentially suitable acitivities, rather than a definitive list. The referene to ‘outputs of sustainable livestock farming’ has been changed to ‘outputs of the unit…’ in response to some comments.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Concern about the procedure for considering This concern relates to policy SD25, rather than farm and estate plans the one under consideration Requests for changes to Criterion 1 This criterion has been deleted entirely, since it replicates other policies in the Local Plan. Positive reference to permitted development The introduction to the chapter already refers rights as a baseline to permitted development rights, and makes clear that the policies relate to developments that would not be covered by those rights.

309

Policy SD48: Agriculture and Forestry Workers’ Dwellings

Reg 22 (1) (c) (iii) There were a total of 31 comments on this policy. These are summarised below. Borough, City, County and District Councils Chichester District Council stated that the policy should refer to agricultural or forestry workers throughout. Parish and Town Councils One expression of general support was registered. One parish meeting requested the insertion of a clause to prevent agricultural or forestry workers’ dwellings (AFWD) being built supposedly to accompany a proposed farm development, then the farm development not materialising and the AFWD receiving permission for open market housing use. One parish council expressed concern at the frequent abuse of this type of policy, a concern that the policy as drafted is too weak and a desire to see the functional need test considerably tightened. In addition, a requirement was requested for enterprises seeking such a dwelling to contribute positively to the National Park purposes and be viable over time. One parish council asked for requirements for designs, materials and colours that blend into the countryside. Other Organisations Estates, farm businesses and those representing them Four expressions of general support were received. One respondent commented that the policy and supporting text is too loosely worded. Four requests were made for dwellings to be permitted to support farm diversification. One respondent asked for AFWD to be exempted from CIL. Criterion 1(b) on other available accommodation: One respondent requested that the availability of appropriate accommodation be considered in terms of appropriateness and affordability, as well as the other criteria. Criterion 1(c) preventing AFWD where other dwellings have been sold in the past ten years: Requests were received to take account of the justifiable disposal of dwellings due to changes in economic circumstances (3 respondents), to shorten the period to two or three years (3 respondents), and to only apply the test to dwellings which could have met the functional need (2 respondents) or were appropriate. One general objection to the criterion was received. Criterion 1(d) limiting the floorspace of AFW dwellings: Four respondents stated an in principle objection to a size limit. Two further general objections were received that it would make farms less viable and discriminate against young farmers.

310

Requests were received to allow for larger dwellings where there is a demonstrable need e.g. due to family size (2 respondents) Two respondents requested an allowance for the construction of a second AFWD per unit for retired agriculture or forestry workers to live alongside their children (2 respondents), or specific policy text to make it easier for established farms to build a second AFWD. A comment was made that specifying a time limit for temporary permissions, and preventing successive temporary permissions, could put new enterprises in jeopardy. One respondent requested the NPA to close the loophole by which farms are broken into small plots where AFWDs are applied for to support a plausibly high intensity use such as a chicken farm; the agricultural use is subsequently discontinued and the dwelling passes into open market use. It was suggested that this could be prevented by only allowing AFWDs on farms above 20-30ha, where the farm is certified as a genuine business by SDNP accountants, and the farm income provides at least 75% of the income of the dwelling’s occupant; by requiring the farm to submit annual accounts to the NPA for a period after permission showing it to be a genuine business; and strengthening enforcement. A comment was made that recently built agricultural dwellings should not be eligible for conversion. Other organisations General support expressed by one respondent. Concern was expressed as to the number of speculative planning applications of this nature that have occurred in the past, along with support for the policy. An additional criterion 1(c) was requested to state that ‘the business on the holding is or will be financially viable in an appropriate period.’ There was a request to substantially reword the policy to reflect the fact that modern technology often means agricultural or forestry workers no longer have to live on site, as opposed to within a short drive of the site; and to require the evidence provided to be ‘robust’. One request was made to limit the provision of AFWDs to farming and forestry businesses which contribute to the Special Qualities of the National Park, as opposed to, for example, an intensive rabbit farm. The size limit of 120m2 was questioned. An additional criterion 2(f) was requested to state that ‘At the end of any temporary permission it must be demonstrated that the financial viability is proven’ Individuals Criterion 1(d) limiting the floorspace of AFW dwellings: One general objection was made that the limit is too low, two proposals for higher limits were received, and one request to delete the criterion. Criterion 1(f): protection of AFWD by condition: One request to delete the criterion was received.

311

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Policy and supporting text significantly revised and amended to provide greater flexibility in approach whilst seeking to be appropriate for the National Park;  Policy SD32 Criterion 2a sets out requirements needed to demonstrate that that the enterprise is suitable for consideration i.e. established, extensive and viable.  Policy SD32 Criterion 2c. sets out that no other dwellings connected to the enterprise have been sold in the last five years. It is considered that five years, a reduction from 10 years in Preferred Options policy SD48, is a reasonable compromise;  Policy SD32 Criterion 3 sets out the restrictive circumstances in which occupancy conditions will be removed;  Policy SD32 Criterion 4 (Temporary Dwellings) essentially retains the supporting criterion (2) of Policy SD48.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Requirements for designs, materials and Design addressed through draft Local Plan colours that blend into the countryside. policy SD5

Requests were made for dwellings to be The policy is clear that new dwellings are to permitted to support farm diversification. support agriculture and/or forestry – not other activities which could come forward as part of a diverisifcation scheme.

AFWD to be exempted from CIL. This would be considered trhough the separate CIL process rather than the Local Plan process.

An in principle objection to a size limit Disgaree. It is considered appropriate to limit the size of agricultural and forestry workers dwellings to a reasonable size. The limit is 120 sq/m which could still provide a 3 or 4 bedroom home suitable for families.

Allowance for the construction of a second Disagree. It is not the intention of the policy to AFWD per unit for retired agriculture or provide retirement homes. forestry workers to live alongside their children.

Request was made to limit the provision of Disagree. Each proposal should be considered AFWDs to farming and forestry businesses on its own merits – rather than assuming that a which contribute to the Special Qualities of the ‘rabbit’ farm (or any other agricultural activity) National Park, as opposed to, for example, an was in principle incompatible with the special intensive rabbit farm. qualities of the national park.

An additional criterion 2(f) was requested to The suitability of a temporary consent, whether state that ‘At the end of any temporary new or a subseuquent one, would be permission it must be demonstrated that the established through criterion 2a. to 2e. financial viability is proven’

312

Policy SD49: Conversion of Redundant Agricultural Buildings

Reg 22 (1) (c) (iii) There were a total of 32 comments on this policy. These are summarised below. National Agencies Support was received from Historic England who made the following comments. Clause 2a) could be considered too restrictive with the additional requirement to enhance the setting, as well as the architectural and historic significance (note: use ‘significance’ rather than ‘interest’). Within the supporting text it should highlight the importance of the relationship of individual buildings to other buildings within a farmstead, and the group of buildings to their setting within the wider landscape. Within the Policy there should be a requirement to retain existing features of architectural or historic significance. Borough, City, County and District Councils Both Lewes (LDC) and Chichester District Councils (CDC) commented on the policy. LDC suggested that the policy should address the setting of non-heritage assets, as it does for heritage assets in clause 2a). CDC commented that not all rural buildings are agricultural. Parish and Town Councils Of the five Parish Councils who commented on the Policy, 3 supported the policy. The following comments were also made:

 In the supporting text (para 10.126) it refers to post war buildings but lacks clarity in relation to buildings constructed in the earlier part of the twentieth century.  An addition to clause 1f) The proposed use does not impact upon the amenities and /or the activities of neighbouring properties and uses by reason of noise, odour and traffic generation, nor impact on the special qualities of the National Park"  That the policy require design, materials and colours which blend into the countryside.

313

Other Organisations Support was received from CPRE Sussex, the Country, Land and Business Association (CLA), the South Downs Land Managers Group, the South Downs Society and Friends of the Earth (Brighton & Hove). The following comments were also made:

 The supporting text mentions specific uses, but this is not mentioned in the Policy text.  The supporting text states that conversion should not result in the need for another agricultural building, this needs to be stated within the policy itself.  The policy wording needs to acknowledge that many rural buildings may contain protected species (as at para 10.148) and ecological surveys will be required where there is a reasonable likelihood.  Clarification of the term “optimal viable use”  Clause 1d) felt to be unnecessarily restrictive.  There is potential for conflict between clauses2a and 1b, where, in order to conserve a heritage asset, substantial reconstruction may be required. Suggested additional clause or text, that reconstruction may be supported where they restore lost features or sustain otherwise unviable features.  It is considered unrealistic to require no impact upon neighbours, either during construction or operational phases. Clause 1f) could therefore prevent otherwise acceptable uses /proposals coming forward.  In line with other policies within the plan which recognise horse riding as a sustainable transport mode, a positive approach to equestrian development would be expected. Agents and Developers Comments were received from seven estates. They all had similar comments as follows:

 The conversion of redundant agricultural buildings to residential use should be positively encouraged within the policy in line with paragraph 55 of the NPPF.  The requirements should not be unnecessarily burdensome. In particular the marketing assessment and the implications of Building Regulations referenced in paragraph 10.149. It is not clear what the justification or purpose of these is.  There is potential for conflict between clauses2a and 1b, where, in order to conserve a heritage asset, substantial reconstruction may be required. Suggested additional clause or text, that reconstruction may be supported where they restore lost features or sustain otherwise unviable features.  Clarification and a clear definition of heritage assets is required.  There must be very clear guidance or requirements in relation to agricultural need and existing buildings that may be turned into residential use. Individuals Six individuals commented on this policy:

 Where a farm building is effectively both isolated and/or derelict, it might harm the character of the area to convert it or rebuild it.  Concern that the policy excludes conversion to residential uses by not specifying that this is an acceptable use in principle and in line with paragraph 55 of the NPPF.  The requirement to convert redundant farm buildings without substantial reconstruction is unrealistic, particularly a conversion to residential use.

314

Reg 22 (1) (c) (iv) The representations have been taken into account as follows. Historic England said that Clause 2a) could be considered too restrictive with the additional requirement to enhance the setting, as well as the architectural and historic significance (note: use ‘significance’ rather than ‘interest’). The word ‘significance’ has been substituted for ‘interest’, but the SDNPA disagrees with the recommendation not to use the formulation ‘conserve and enhance’, which is used throughout the Local Plan. Historic England also stated that the supporting text should highlight the importance of the relationship of individual buildings to other buildings within a farmstead, and the group of buildings to their setting within the wider landscape. Within the Policy there should be a requirement to retain existing features of architectural or historic significance. These recommendations have been carried out. The policy has been amended to address the setting of non-heritage asset buildings, as well as heritage assets, as recommended by LDC.

One comment was received questioning the definition of a traditional farm building. This definition has now been included in the Local Plan glossary.

The implications for suitable uses were questioned as this area of the policy was seen as vague. These implications are now set out in paragraphs 7.212- 7.214 of the supporting text, with criterion 1g providing detail on residential uses. One respondent noted that the supporting text states that conversion should not result in the need for another agricultural building, and suggested this needs to be stated within the policy itself. This has now been incorporated into the policy. Some respondents objected to the marketing assessment and the implications of Building Regulations referenced in paragraph 10.149, saying that it is not clear what the justification or purpose of these is. This requirement has been taken out and replaced with clear guidance on potential uses. The comment was made that, where a farm building is effectively both isolated and/or derelict, it might harm the character of the area to convert it or rebuild it. This has been reflected in Criterion (a) of the new policy.

315

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Proposed changes to Criterion 1f on amenity The whole criterion has been deleted as it duplicates other Local Plan policies. The policy wording needs to acknowledge that This issue would be dealt with through Policy many rural buildings may contain protected SD9: Biodiversity and Geodiversity species (as at para 10.148) and ecological surveys will be required where there is a reasonable likelihood.

Clarification of the term “optimal viable use” This term is defined under Policy SD12: Historic Environment. There was a suggestion for additional clause or The reconstruction of lost features would not text, that reconstruction may be supported be supported if the proposed development was where they restore lost features of heritage unsuitable in other terms. The sustenance of assets or sustain otherwise unviable features. existing features would already be covered by the policy. Clarification and a clear definition of heritage This is defined in the Local Plan glossary. assets is required.

316

Policy SD50: Equestrian Uses

Reg 22 (1) (c) (iii) There were a total of 18 comments on this policy. These are summarised below. Borough, City, County and District Councils East Sussex County Council raised the potential for manage construction to constitute a waste management operation, and proposed the inclusion of text to deal with such situations. Parish and Town Councils General support was offered. Requests were made for:

 More detail on deterring the subdivision of, and introduction of ‘clutter’ into, open fields  Tightening the wording of the final criterion  Deletion of the second criterion as unneccessary  A requirement for design, materials and colouring that blend into the countryside. Other Organisations Five organisations offered general support. One organisation requested more specific guidance and tighter definitions Another requested more emphasis on grazing density and the avoidance of overgrazed, churned fields Additional indicators were proposed that would show land is being used for keeping, not just grazing, horses. Other requests were made for criteria on the size of facilities relative to the local settlement, and on cumulative impact; for more recognition of the positive effect of equestrian uses, and of polo; and for indigenous species to be required in planting schemes Two estates and an agency questioned when equestrian development might not be compatible with other countryside users, as per Criterion 1(g). Individuals One respondent strongly supported a policy to curb the fragmentation of fields with inappropriate fences and jumps.

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The opening wording of criterion 1 is amended and crierion 2 is deleted for consistency across all policies in the Local Plan.  A new criterion is added requiring a conservation based land management approach. This is further clarified in the supporting text, for example, using a locally nativie seeding mix, using a grazing rotation programme and restoration of hedgerows as a framework for paddock subdivision.  Additonal wording is incorporated into the supporting text referencing the importance of careful design and layout in mitigating and avoiding landscape impacts.

317

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Suggestion of criteria on the size of facilities Addressed through the landscape policy and relative to the local settlement. design policy. East Sussex County Council raised the potential This is not considered a matter that should be for menage construction to constitute a waste dealt with through the local plan. management operation, and proposed the inclusion of text to deal with such situations. Additional indicators were proposed that This is considered too detailed a matter to be would show land is being used for keeping, not included in the monitoring framework. just grazing, horses.

318

Policy SD51: Shops Outside Centres Corresponding to Pre-Submission Policy SD38

Reg 22 (1) (c) (iii) There were a total of 14 comments on this policy. These are summarised below. National Agencies No comments received Borough, City, County and District Councils No comments received Parish and Town Councils Selbourne Parish Council are concerned about the over-development of some garden centres. They consider that proposals for new extensions should be supported by a robust Business Plan to demonstrate long term viability. They comments that there is no vision in the Policy for what happens if and when farm shops and garden centres cease to operate. They also make some more minor wording suggestions.

Arundel Town Council consider that setting restrictions over what can and can’t be sold in farm shops is unnecessary, oppressive and not the business of a Planning Authority. Other Organisations CPRE Hampshire suggest a small number of minor wording changes. CPRE Sussex and Friends of the Earth Brighton & Hove broadly support but CPRE Sussex consider some aspects too restrictive. The South Downs Society consider the percentage split of goods to be sold by farm shops is a useful guide but may inflexible and unenforceable. The South Downs Land Managers Group welcome the policy and the inclusion of FARMA recommendations. They comment that the supporting text should recognise the seasonality of produce, so that the split may vary over the year and that a larger radius from which products can be drawn may be beneficial. The radius will currently disadvantage shops near the coast. They suggest to amendments to the policy to address these issues. The Petersfield Society query what uses might be considered inappropriate in a garden centre. They also note that the policy assumes that the only retail is convenience, farm shop or garden centre but examples of other types of shop that have proliferated in recent years include fashion retailers etc. The question how this policy will control the expansion of such a centres.

319

Agents and Developers

 Amberleigh House Ltd suggest the policy be amended to include provision for cycle hire/repair shops, facilities for horse riders or walkers as this would support drive for more sustainable transport.  Callstone Ltd support the policy but suggest that the proposed threshold (150 sq. m) for impact assessment for a convenience store is very low, the default national threshold is 2,500 sq m. It is considered overly onerous and greater justification is required to support a for lower threshold.  Notcutts Ltd support the policy in relation to garden centres and note that the primary function of garden centres should be garden related but the introduction of supplementary activities / product lines has grown through a need to even out the seasonal fluctuations within the sector. They consider that garden centres play an important role in the local economy, and are important employers within the National Park. They operate from large sites as they are 'land hungry uses' and are expensive to operate. Supplementary products and activities are essential to the continued viability of a centre, without these the businesses will often struggle to remain viable with inevitable loss to the local economy. The public expect a good range of product and activities when visiting. They conclude that a too restrictive policy will make it difficult for garden centres to compete with their counterparts outside the Park boundaries and suggest some changes to the policy to reflect their views.  The Sompting Estate make the same comments as the South Downs Land Managers group.  The Bignor estate consider that retail units should be marketed for at least 36 months and that enforcement powers should be strengthened. Individuals No comments received. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Policy wording amended to be more positive and clear.  Supporting text added to recognise the benefits to garden centres of allowing for some diversification but also the need for such developments to be part of a long term strategy for the business.  Supporting text in relation to farm shops includes reference to seasonality.  Local food is considered to be that which has come from no further than 30 miles away. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Amend policy to include provision for cycle Not necessary as supported by other policies in hire/repair shops, facilities for horse riders or the Local Plan. walkers as this would support drive for more sustainable transport. Callstone Ltd support the policy but suggest Threshold set in accordance with evidence that the proposed threshold (150 sq. m) for within retail study. impact assessment for a convenience store is very low, the default national threshold is 2,500 sq m. It is considered overly onerous and greater justification is required to support a for lower threshold.

320

Policy SD52: Shop Fronts Corresponding to Pre-Submission Policy SD52

Reg 22 (1) (c) (iii) There were a total of 8 comments on this policy. These are summarised below. National Agencies Historic England would like to see a requirement for the retention of any existing features of architectural or historic significance in the existing shopfront or facade. They consider that this policy might sit more logically with those for the historic environment. Borough, City, County and District Councils Chichester District Council consider that reference should be made to their existing shop front guidance. They consider that the policy may sit better with the historic environment policy and grouped with advertising and signage.

Parish and Town Councils Selbourne Parish Council support the policy. Other Organisations

 Friends of Lewes Society support the policy but are concerned that it does not continue the provisions of extant policy ST29 of the Lewes District Council Local Plan with respect to illuminated signage in the Lewes Conservation Area. They propose some limited changes to the wording to reflect this position.  Friends of the Earth Brighton & Hove support the policy.  South Downs Society support the policy but consider it could be supported by design guidance. They note that although listed buildings will be protected the policy should express a preference for retention of traditional shopfronts wherever practicable.  The Petersfield Society comments that the policy should be cross referenced with EHDC Shopfronts Design Guide 2003.

Agents and Developers

No comments received. Individuals No comments received. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Criteria has been added relating to the retention of historic features. In addition reference is also made to conservation areas and listed buildings.  The policy is now grouped with those on adverts which reflects normal practice.  The policy now also seeks shop front designs that are based upon a traditional approach but the specific reference to blinds and canopies has been placed within the supporting text.  A need for eny lighting to be considered as part of a design is added to the policy.

321

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason The policy might sit more logically with those Not all shop fronts are within conservation for the historic environment. areas or on listed buildings. This policy applied to all shopfronts, no matter where the location. Reference should be made to existing shop There is a range of advice existing across the front guidance. National Park and it is not being cross referenced policy by policy, in addition not all have been adopted by the SDNPA. The existing guidance is a useful reference and does not conflict with this policy. In a number of locations Neighbourhood Plans are now providing more detail.

322

Policy SD53: New and Existing Community Infrastructure Corresponding to Pre-Submission Policy SDxxxxxxx

Reg 22 (1) (c) (iii) There were a total of 21 comments on this policy. These are summarised below. Borough, City, County and District Councils Brighton & Hove City Council enquire how the expansion of facilities abutting the boundary would be considered, for example Sussex University. Chichester District Council requested further guidance on the change of use of community infrastructure to other uses. For example, more detailed requirements on marketing, demonstration of lack of viability or need. Hampshire County Council indicated that they may need to dispose of community buildings or land to fund the improvement of local services. They propose additional text to cover this eventuality, similar to that used by NFDC and WCC. They stated that points under criterion 3 can be mutually exclusive, so the requirement should be to meet ‘any’ of them rather than ‘all’ of them.

Parish and Town Councils One respondent offered general support. One respondent sought a list of infrastructure. One respondent stated that the East Hants JCS policy SD28 offers more protection than this policy does. More reference to schools is sought. Liss Parish Council request that Liss should be deleted from the list of settlements in Criteria 1, since it has significantly fewer facilities than most of the others. On Criterion 2, there is a request that larger-scale community infrastructure be required to show community support, as well as community engagement. On the other hand, there is a comment that it is too restrictive to require a demonstration of need or community engagement for facilities on appropriate sites within settlement boundaries. A proposal was made that Criterion 4 should be a sub-criterion of Criterion 3. Concern expressed over the unnecessary loss of community facilities, and a policy to prevent such loss through change of use. One parish council consider Criterion 3 to be unnecessarily restrictive. Other Organisations Five organisations offered general support to the policy. One prominent educational establishment in the Adur area proposed that the policy should support community facilities that have estates by referring to Estate Plans and the ability of developments on those estates to help meet the operational requirements of such institutions.

323

It was proposed that the policy should provide, with clear guidance, the flexibility to allow community facilities such as primary schools, village halls and sports facilities to be provided outside settlement boundaries. The potential of woodland creation as a possible community infrastructure project was highlighted. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Policy and supporting text significantly revised and amended to provide suitable flexibility in approach whilst seeking to be appropriate for the National Park; i. Criterion 1a. sets out the need for applicants to demonstrate a local need for the proposal; ii. Criterion 1b. sets out that the scale of the proposal should be proportionate to the local area; iii. Criterion 1c. sets out the need for community engagement; iv. Criterion 1d. sets out the need for accessible and inclusive locations for new facilities; and v. Criterion 1e. sets out that consideration of providing the facility via re-using existing buildings including shared use has been considered before new build;  The supporting text clarifies which types of infrastructure the policy applies too including schools;  The revised policy sets out details of the marketing requirements;

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason How the expansion of facilities abutting the The draft policy applies to all of the SDNP so if boundary would be considered. a proposal was abutting the boundary it would be treated the same as anywhere else.

Too restrictive to require a demonstration of Disagree. It is clearly good practice to engage need or community engagement for facilities on with local communities before providing new appropriate sites within settlement boundaries. community facilities and good planning to ensure that unnecessary facilities are not provided.

The policy should support community facilities There is no particular need to emphasise that have estates by referring to Estate Plans community facilities provided within larger and the ability of developments on those estates. The policy applies to all proposals of estates to help meet the operational this ilk. requirements of such institutions.

324

Policy SD54: Supporting Infrastructure for New Development Corresponding to Pre-Submission Policy SDxxxxxxxxxxx

Reg 22 (1) (c) (iii) There were a total of 21 comments on this policy. These are summarised below. National Agencies Thames Water generally support the policy. They do not envisage any concerns over the sewerage implications of the allocation at Binsted (the only allocation in their area). They propose text requiring developers to demonstrate there is adequate sewerage capacity to serve their developments, and pay for improvements if not. Southern Water have found that some of the proposed allocations require additional local infrastructure, involving making a connection to the local sewerage or water distribution networks at the nearest points of adequate capacity. This may require the provision of off-site infrastructure if there is no appropriate point nearby. They propose deleting the word ‘on-site’ from criterion 2. Borough, City, County and District Councils East Sussex County Council request that the policy refer to ‘education provision’ rather that ‘school places’ and propose to share their Education Commissioning Plan with the NPA. Hampshire County Council support the consideration of broadband and telecoms through two separate polices, and request a reference to village design statements to be added to Criterion 7 of the policy. West Sussex County Council Recommend that an assessment of the cumulative transport impact of the SDLP housing allocations on junctions and hotspots be carried out, and provide details. After the first sentence of Criterion 6 they propose adding: ‘With particular regard to the wellbeing of current and future residents’ They propose the consideration of the wider facilities (beyond housing) needed by the older population, of whom the SDNP has a higher than average proportion. Hampshire County Council indicated that they may need to dispose of community buildings or land to fund the improvement of local services. They propose additional text to cover this eventuality, similar to that used by NFDC and WCC. They stated that points under criterion 3 can be mutually exclusive, so the requirement should be to meet ‘any’ of them rather than ‘all’ of them.

Parish and Town Councils Three respondents offered general support. Reference was sought to extending the provisions of mains gas to settlements that currently do not have it, and to requiring new developments to extend broadband to nearby properties as well as to the development site itself. One respondent proposed adding a note that, in Neighbourhood Plan areas, the relevant Parish Council should be involved in determining appropriate infrastructure. One respondent requested that on site renewables should not be permitted where there is potential for them to harm the landscape.

325

Other Organisations Four organisations offered general support.

One organisation asked for the policy to be redrafted to ensure viability is taken into account in the negotiation of development based contributions.

One respondent stated that, whilst broadband is very important, the provision of at least minimum viable levels of broadband throughout the Park is for many more urgent than the provision of superfast broadband. One respondent supported green infrastructure projects, in particular an off-road path from Hamsey to the Jubilee path from Ditchling. Agents and Developers One respondent offered general support but requested that the required infrastructure should be commensurate with the scale and nature of the development proposed, and not make it unviable. They proposed revised, more flexible text, removing reference to legal agreements and phasing. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

326

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Some of the proposed allocations require This issue will be addressed through draft Local additional local infrastructure, involving making Plan policy SD44 (Telecommunications & a connection to the local sewerage or water Utilities). distribution networks at the nearest points of adequate capacity.

West Sussex County Council Recommend that This is evidence that underpins the draft Local an assessment of the cumulative transport Plan development strategy, rather than policy impact of the SDLP housing allocations on SD42 (Infrastructure). The evidence has been junctions and hotspots be carried out completed and is available to view on the South Downs website.

Requiring new developments to extend Draft Local Plan policy SD44 requires broadband to nearby properties as well as to broadband in relation to new housing but the development site itself. clearly it could not be expected to address existing shortfall in provision elsewhere.

In Neighbourhood Plan areas, the relevant Clearly Neighbourhood Plans provide an Parish Council should be involved in opportunity for local communities to set out determining appropriate infrastructure. what they perceive as local infrastructure issues.

On site renewables should not be permitted Renewable energy proposals would be subject where there is potential for them to harm the to draft Local Plan policy SD51 (Renewable landscape. Energy).

Policy to be redrafted to ensure viability is The supporting text to Policy SD42 (Para. taken into account in the negotiation of 7.222) sets out that new development should development based contributions. be adequately supported by existing infrastructure, or makes sufficient provision for any new infrastructure that is required to make the development acceptable in planning terms.

Supported green infrastructure projects Draft Local Plan policy SD42 (Infrastructure) and SD45 (Green Infrastructure) addresses the need for green infrastructure where appropriate.

327

Policy SD55: Advertisements and Signage Corresponding to Pre-Submission Policy SD53: Adverts

Reg 22 (1) (c) (iii) There were a total of 10 comments on this policy. These are summarised below. National Agencies Historic England support criterion 1(a), but propose that it should also refer to the historic significance of host buildings. Parish and Town Councils General support was expressed, along with concern over proliferation of signage and advertising along main roads Requests were made to tighten the wording in the second criterion, and to insert a requirement for A-boards to be removed outside opening hours More detail and definition in the policy were requested, to aid enforcement Other Organisations Six organisations expressed general support. Concern was expressed by two organisations over the proliferation of signage and advertising. References were requested to enforcement, and more on cumulative impact. There was a request to define and map Areas of Special Advert Control, potentially extending them to cover various features of interest. One respondent considered the policy to be weaker than that in the old Lewes District Local Plan, and requested changes to remedy this. One respondent proposed that all advertising signage in rural areas of the Park should require specific permission from the NPA. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Reference to the historic significance of host buildings is included in the policy.  The need to consider the cumulative impact is included alongside the need to keep adverts to a minimum.  A reference to illuminated adverts has been added to reflect the Shop Fronts policy.  Reference to the imposition of conditions has been deleted from the policy and included in supporting text as this is not required within the policy.  Reference to A boards has been added to the supporting text along with the wish to see them removed once a business has closed for the day.  The title of the policy has been changed to Adverts as this is more commonly understood terminology.

328

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason More detail and definition in the policy were This is not possible in a policy covering the requested. entire National Park, detail can and often is added by Neighbourhood Plan groups. References were requested to enforcement. Reference to enforcement has not been added as this could equally apply to all policies within the Local Plan. Define and map Areas of Special Advert The extension of the ASAC has been Control (ASAC), potentially extending them to considered but resources are not currently cover various features of interest. available.

All advertising signage in rural areas of the Park The legislation sets out what constitutes should require specific permission from the deemed consent and what requires consent. It NPA. would not be proportionate or reasonable for all advertisements to require an application.

329

Policy SD56: Renewable Energy

Reg 22 (1) (c) (iii) There were a total of 21 comments on this policy. These are summarised below. National Agencies Historic England welcomes and supports Development Management Policy SD56, although we would prefer the replacement of "cultural heritage" with "historic environment" in criterion 1a). Borough, City, County and District Councils In this category Hampshire County Council (HCC) was the only respondent; HCC fully support this section, and look forward to innovative work with energy providers to develop a forum for improvements and good practice in the National Park. Parish and Town Councils There were five responses in this category. Barlavington Parish Council was concerned by the exclusion of any guidelines on the SDNPA’s view on renewable energy and whether this is going to be supported or not. It would expect the same clarity to be applied to renewable energy as is applied to analysing / identifying where housing development is to be located. Selborne Parish Council supports the policy in principle but has serious concerns about the proposed encouragement of anaerobic digesters fuelled by crops such as maize / sweetcorn which are not eco-friendly. It proposes amending paragraph 1 c) to read: "..existing public access is not impeded and the enjoyment of the natural beauty of the landscape is not diminished." Liss Parish Council considers that the policy should include reference to protecting views. Arundel Parish Council considers the policy to be unnecessarily restrictive in all circumstances. Bepton Parish Council supports the policy as currently worded. Other Organisations This category attracted the greatest number of responses; five from Estates / property managers and seven from NGOs. Broadly speaking, the Estates welcome the support provided by the policy for renewable energy schemes in the National Park. They point out that estates and farms benefit from the critical mass of property to make renewable and Low Zero Carbon energy schemes viable (e.g. district heating schemes). They also have the necessary resources (e.g. forests and land) to make provision for such schemes. CPRE Hampshire supports renewable energy, but not where it would compromise the Special Qualities of the SDNP. Large wind turbines, in particular can have a serious adverse impact on views, relative tranquillity, and dark skies as well as landscape character, which can also be adversely affected by large solar farms. It argues that Policy SD56(a) should be strengthened to read; "a) the siting, scale, design and appearance will not have an adverse impact upon the Special Qualities of the National Park, including landscape character, views, relative tranquillity, dark skies, cultural heritage and wildlife" CPRE Sussex would like to see greater emphasis on the incorporation of renewable technologies within existing and planned developments, where this does not compromise the special qualities of the SDNP and also greater encouragement of community renewable schemes, a comment also echoed by the South Downs Society which in addition recommended that the wording at point 1a) could be simplified by referring to the special qualities of the National Park.

330

The South Downs Land Managers Group endorsed the flexible and non-prescriptive approach taken in this policy, adding that in order to sustain a more comprehensive biomass industry that additional infrastructure may be required. The Woodland Trust provided a detailed response in which the principal points are:

 Support for the development of small-scale, local biomass projects such as wood-fuel heat and power, which minimise the costs and carbon emissions associated with transport;  Mandatory environmental management of schemes via the UK Woodland Assurance Standard and Forest Stewardship Council certification;  Developing markets for wood fuel and from which income streams generated would help owners deliver environmental and social benefits from their woods to society. Agents and Developers Callstone Ltd. has endorsed the policy approach for individual developments adding that, as well as considering the impact this technology will have on viability, it is also important to consider the visual and other associated impacts on the National Park (e.g. a large number of domestic wind turbines would be considered to be inappropriate). Individuals One response was received from an individual who argued that the policy is woefully weak. A national park should be aiming to enforce renewable energy (particularly non-visually intrusive renewable energy) to promote sustainability and environmentally beneficial living across the National Park. He recommended two ways to address this: 1. Use of the statutory powers for Planning Authorities under The Planning and Energy Act 2008 under which improved energy efficiency /renewable energy provision can be required when considering planning applications, notwithstanding the much publicised U-turn on zero carbon homes. This MUST be included in order to ensure the long-term [environmental] sustainability of development in the South Downs. 2. The significant scope to promote District Heating Networks within the local plan. Citing the North Street Quarter feasibility study as an example.

331

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The policy has been substantially revised and re-structured to; provide greater depth of coverage of the issues associated with renewable energy proposals; to include a specific criterion for small-scale proposals that outside the SDNP are often Permitted Development and; to better reflect the recommendations of the AECOM Renewable and Low carbon Energy Study (May 2013);  The policy has been strengthened to say ‘permitted’ rather than ‘encouraged’, subject to certain provisos, to support the long-term sustainability of the National Park;  The appropriateness of the different renewable energy technologies within the National Park are clearly set out under separate headings in the supporting text;  There is no specific reference to anaerobic digesters, utilising maize and sweetcorn, in response to Selbourne Parish Council’s concerns;  In terms of impacts of renewable energy schemes on landscape, this issue is covered by Strategic Policy SD4: Landscape Character. The introduction to the Local Plan highlights that all policies are viewed together and the Core Strategic Policies set out the overarching principles of development in the National Park. The supporting text also refers to the sensitivity of the landscape to renewable energy schemes and that in considering their appropriateness applicants should refer to the South Downs Integrated Landscape Character assessment (SIDILCA) and to the South Downs Viewshed Characterisation Study. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Promoting district heating networks. The AECOM SDNP Renewable and Low Carbon Energy Study (May 2013) identifies that only Lewes and Petersfield are of a sufficient size for this type of renewable energy and this is set out in the supporting text.

332

Policy SD57: Telecommunications, Services and Utilities

Reg 22 (1) (c) (iii) There were a total of 14 comments on this policy. These are summarised below. National Agencies Southern Water disagreed with the way the Water Cycle Study had been summarised, and proposed an alternative text. Borough, City, County and District Councils Hampshire County Council expressed support for the aims and objectives of the policy, and the presence of separate Local Plan policies for broadband and telecommunications Parish and Town Councils One respondent supported encouragement for undergrounding; another said this should be a requirement, not simply encouraged. Requests were made for criteria requiring infrastructure to be removed when no longer required; and requiring designs, colours and materials that blend into the countryside. One respondent supported the encouragement for service improvements that do not affect the landscape and amenity of the area. One wanting the policy to be flexible Agents and Developers Three respondents in this category expressed general support. One respondent suggested that we should note the importance of mobile telecoms to modern farming. The Mobile Operators’ Association consider elements of the policy to be too restrictive; they request removal of the requirement for telecoms infrastructure to comply with other Local Plan policies, and of the requirement for location close to existing buildings. CPRE Hampshire, while strongly supporting the policy, proposed more specific reference to particular Special Qualities in SD57(a) and to making rural substations less obtrusive e.g. through colouring. Individuals One individual commenter supported the policy and urged progress on the removal/undergrounding of prominent telecoms infrastructure. Another noted the importance of broadband to tourism and requested the NPA to open dialogue with all current and potential broadband providers for the last 5%, and get them to demonstrate good practice.

333

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Policy and supporting text significantly revised and amended to provide greater flexibility in approach whilst seeking to be appropriate for the National Park;  Reference to Water Cycle Study removed from the supporting text;  Design of proposals address through supporting criterion 1b, 1c, 1d and 1e. and other relevant Local Plan policies (for example SD5);  Removal of the requirement for telecommunications proposals in location close to existing buildings. Instead the revised policy sets out a more flexible approach.  Revised policy criterion 1b. sets out the need to have an appropriate design that would not have an adverse impact on the special qualities of the National Park.  Draft Local Plan policy criterion 2 requires all new residential dwellings to be served by a superfast broadband connection and as such treat this utility as per water supply and electricity.

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Undergrounding should be a requirement, not It is considered that the policy should not simply encouraged. include a ‘one size fits all’ approach that insists upon undergrounding. Undergrounding may be the best approach in many instances, but its is considered that criterion 1b. and 1c. set out the context of ‘appropriate design’ and ‘available technologies’.

Removal of infrastructure once use no longer This cannot be insisted upon if a planning required. consent is granted.

Note the importance of mobile telecoms to No need to set this out in a Local Plan as modern farming. clearly mobile telecommunications have importance to most of society, not specifically just farmers.

334

Policy SD58: Air Quality Corresponding to Pre-Submission Policy SD54: Pollution and Air Quality

Reg 22 (1) (c) (iii) There were a total of 10 comments on this policy. These are summarised below. National Agencies Southern Water commented that odour is also a pollution issue and can have a significant impact on neighbouring users. It noted that neighbouring uses need to be appropriate to avoid conflict. The suggestion was made to include a requirement for adequate odour and noise dispersal for proposals adjacent to treatment works, and pumping stations. Borough, City, County and District Councils Lewes and Chichester District Councils and West Sussex County Council commented on this policy. The comments were broadly supportive with suggestions to clarify terms used (significant deterioration needs further explanation) and to include reference to the effect of transport on air quality. Parish and Town Councils Petworth Neighbourhood Plan Steering Group raised the question of a need for Air Quality Action Plans for other areas experiencing high levels of traffic congestion and (localised) air pollution. The potentially damaging effects of vibration was also noted, particularly the effect on historic buildings. Support was received from Bepton and Selbourne Parish Council Other Organisations Support was received from Friend of the Earth (Brighton & Hove), the South Downs Society who also recommended that this should also apply during construction of new development. The Woodland Trust objected to the policy saying that the policy should encourage the use of trees and tree planting as a way of improving air quality. Agents and Developers No comments received. Individuals No comments received.

335

Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 The policy is now entitled Pollution and Air Quality rather than just Air Quality to encompass a broader range of issues. In addition a new criteria, criteria 1, has been added to the policy to reflect this broader remit including odour (in response to the representation from Southern Water). The supporting text also contains further details in relation to odour and dust.  The criteria relating to development promoting opportunities for walking, cycling, public transport etc has been removed as it duplicates others within the Local Plan. However a reference to this matter is placed within the supporting text along with a comment on the need to reduce traffic levels particularly in areas of poor air quality.  Criteria 4 has been re-worded to make it clear that there is a need to follow best practice in any development from demolition through to completion.  The policy has been re-ordered and reduced in length for ease of reading and has been worded in a positive rather than negative style.  Details of what should be included in an air quality assessment and reference to the desire to work in partnership with other authorities have been placed in the supporting text as they are supporting details rather than planning policy. The link to the Dark Night Skies policy has been added. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason The need for Air Quality Action Plans for other The requirement to monitor, assess and take areas experiencing high levels of air pollution. action to improve local air quality is the responsibility of the local authority. Planning is just one element of a series of measures that can be used to address issues. This policy was prepared in response to particular issues in Lewes but should other local authorities declare any further AQMAs through the plan period this policy would equally apply.

Clarify the term ‘significant’. The term remains in the first criteria of the policy, to remove it would result in all developments having to demonstrate they do not have a negative affect at whatever level of severity. This would be undeliverable. The term significant will be judged on a case by case basis and will vary dependent on the pollutant involved and the location. The need to encourage tree planting. The desire to see further tree planting is accepted but there are many ways of reducing pollution, including at source before it is emmitted and some are more appropriate than others depending on the individual case. The Local Plan contains a policy on Trees, Woodland and Hedgrows.

336

Policy SD59: Contaminated Land Corresponding to Pre-Submission Policy SD55: Contaminated Land

Reg 22 (1) (c) (iii) There were a total of 6 comments on this policy. These are summarised below. National Agencies Support was received from the Environment Agency who also noted the potential for improvements through the remediation of contaminated land, which can lead to significant improvements in water quality, in line with the Water Framework Directive. Borough, City, County and District Councils Chichester District Council suggested further detail on the process and requirements of contaminated land investigations could be helpful to applicants. Parish and Town Councils Support was received from Bepton Parish Council and Selbourne Parish Council, although they did question the phrase ‘unacceptable risks to human health’ in clause 1, suggesting the removal of the word unacceptable. Other Organisations Support was received from Friends of the Earth (Brighton & Hove) and the South Downs Society. Agents and Developers No comments received. Individuals One individual supported the policy highlighting particular support for the robust avoidance of unacceptable risk to health and the natural environment. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

 Information on what might be included in a contaminated land assessment has been added to the supporting text.  Cross reference to the Local Plan policy on Aquifers has been removed as it is uneccessary. The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason The removal of the word ‘unacceptable’ from The term unacceptable has been retained as to the policy. remove it would result in all developments covered by this policy having to demonstrate they do pose an increased risk to human health no matter what the level of severity. This would result in an undeliverable policy. The term unacceptable will be judged on a case by case basis and will vary dependent on the contamination involved and the location.

337

338

Chapter 11: Implementation and Monitoring

Reg 22 (1) (c) (iii) There were a total of 6 comments on this chapter. These are summarised below. Borough, City, County and District Councils East Sussex County Council asked for an indicator on coastal habitats to be included under Outcome 3. West Sussex County Council requested the chapter to give more information about the frequency of monitoring, where the AMR can be read, and how the structure of the monitoring framework relates to the PMP. Other Organisations The South Downs Land Managers Group would find it useful to see a breakdown of the outcomes of applications for agricultural development. The National Trust would support the production of a guidance note on farm and estate plans, and would be happy to work with the SDNPA on this issue. Individuals One respondent expressed support for the criteria and framework. Another asked for the requirement for farm and estate plans to be dropped, due to the difficulty of planning for the future. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

A request was received to include an indicator on coastal habitats. The revised framework includes indicators on the area, condition and connectivity of target priority habitats; and on developments granted permission within the coastal zones. The latter would be looked at for their impact on the natural environment, among other matters.

A new indicator has been included on developments granted planning permission for agricultural development, although it would be excessive to also monitor such proposals whichwere refused permission.

A guidance note on what are now termed ‘Whole Estate Plans’ has been produced and can be viewed on the SDNPA website.

339

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason West Sussex County Council requested the Each indicator would be reported on every chapter to give more information about the year, although for many indicators new data frequency of monitoring, where the AMR can will be available less frequently- for example, be read, and how the structure of the every two years or every five years. For many monitoring framework relates to the PMP. indicators the exact frequency with which new data will become available, is uncertain and resource-dependent, therefore commitments to the regularity of monitoring are not included in the Local Plan. The new ‘Data Source’ column highlights indicators which are shared with PMP monitoring. The requirement for farm and estate plans to This policy (within Policy SD25) allows for be dropped, due to the difficulty of planning for development that would not be acceptable in the future. any other circumstance, so it would not be appropriate to allow such development without an estate plan.

340

Inset Maps

Reg 22 (1) (c) (iii) There were a total of 75 comments on this section. These are summarised below. Borough, City, County and District Councils East Hampshire District Council noted that part of the settlement boundary of Upper Farringdon lies in their area, and requested discussion on this topic. Parish and Town Councils Droxford Parish Council and Midhurst Town Council requested the extension of their settlement boundaries in specific locations. Itchen Valley Parish Council supported the tightening of the southern boundary of Itchen Abbas and requested discussion on potential amendments to the eastern boundary. Northchapel Parish Council were pleased that Luffs Meadow is not included as a proposed allocation, while stating that they found it hard to see where a site for six dwellings would come from within the new boundary for their village. Stroud Parish Council objected to the reduction of their village’s boundary, citing concerns about the delivery of affordable housing, market housing and a new village hall. They requested discussion with SDNPA. Other Organisations The Upper Itchen Valley Society support the revisions to the boundary of Itchen Abbas. The National Trust support the revisions to the boundary of Selborne, facing the Hangers, due to the potential for significant detrimental landscape effect from development there. Agents and Developers Comments were received that the settlement boundary should include draft housing allocations Specific extensions to the boundary were requested to accommodate sites submitted to the SHLAA Extensions were proposed to the existing or proposed boundary based on the statement that a boundary drawn through a garden is not ‘natural’ or clear and recognisable, and in one case that the land in question is hidden from wider view. Objections were made to the reduction of the boundary in several specific locations since it would restrict the possibility of future development. An objection was made to the removal of a private tennis court from the boundary, since if maintained it would have no wildlife value. Objections were received to the reduction of the boundary at specific buildings and/or land since they are stated to form an integral part of the settlement. Several respondents provided detailed comments or analysis of their site to justify this. A stock response was sent in by several agents and landowners, stating that the impact of settlement boundary reductions on windfall housing delivery rates should be investigated before they are adopted, and that the exclusion of the ends of long gardens from the boundary is arbitrary since they will still be subject to permitted development rights.

341

The boundary should include residential development adjacent to the boundary, as well as intervening land. Individuals Cllr Jackie Porter of Hampshire County Council supported the allocation of the Watercress Way and proposed expanding the boundary of Itchen Abbas to east and west, to allow for the development of affordable properties. Several respondents requested the extension of settlement boundaries to bring in specific plots of land. Support from many individuals- 25 in total- including residents of Selborne and visitors, for the proposed amendments to the boundary of Selborne. In particular this relates to the area between Selborne village and the Hanger and especially to sites where there has been interest in development. Reasons given include the retention of the character of the village and its linear form, protection of views into and out of the village, the heritage value of the land in question and of the village as a whole. Several requests for the car park and land behind the Queens Pub to be excluded from the boundary of Selborne. Selbourne settlement policy boundary is too tight and will not allow any growth. Four respondents objected to the proposed settlement boundary changes for Selborne and wished them to stay as they are. Reasons given include allowing for the village to grow through infill and change of use, and to provide for the needs of local people; the land inside and outside the current boundary having a different character; and in particular an objection to splitting the settlement boundary at Gracious Street. Reg 22 (1) (c) (iv) The representations have been taken into account as follows. Comments were received that the settlement boundary should include draft housing allocations. The exclusioin of draft housing allocations from the boundary at Preferred Options stage was solely in order to stress the provisional, draft nature of those allocations. The current draft of the Local Plan includes all such allocations within the boundary.

The settlement boundary for Upper Farringdon has been corrected in line with East Hampshire DC’s recommendations.

The requirement for six dwellings to be allocated in Northchapel has been removed, since no suitable site was found through the housing allocation process.

A housing allocation site has now been identified in Stroud and the boundary for that village is now being extended to include that allocation. Objections were received to the reduction of the boundary at specific buildings and/or land since they are stated to form an integral part of the settlement. In all these cases, the proposal has been reassessed, and in some cases our proposal has changed. The results of the reassessment are set out in the Settlement Boundary Review Update 2017. Several requests were received for the car park and land behind the Queens Pub to be excluded from the boundary of Selborne. This site has been reassessed and the car park removed from the proposed boundary, but the beer garden area remains inside.

342

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Many representations were made asking for Extension of the boundary purely for the sake greenfield/garden sites next to the settlement of allowing for specific new housing boundary to be included in the boundary, on development is managed through the housing the basis that they would be suitable for allocation process, which comprises a much housing development. more rigorous assessment of the merits of each potential site for housing, as appropriate to the National Park setting. Extensions were proposed to the existing or Disagree- the drawing of boundaries a certain proposed boundary based on the statement distance from the back wall of each house is that a boundary drawn through a garden is not clear, logical and measurable, and similar ‘natural’ or clear and recognisable, and in one methods for drawing boundaries are employed case that the land in question is hidden from in other Local Plans. There are particular wider view. reasons in this National Park why development in large gardens at the edge of settlements should be restricted, apart from where specifically allocated. The boundaries will be available for public view and download from the SDNPA website. The impact of settlement boundary reductions The great majority of settlement boundary on windfall housing delivery rates should be reductions have been at the expense of investigated before they are adopted. residential garden land. Developments on residential garden land are specifically excluded from the trend figures when calculating future expectations of windfall housing development, as required by the NPPF. The loss of such land from the settlement boundary will therefore not make any difference to our windfall expectation. In addition, the windfall figure has a general discount applied on the basis that past trends partly reflect the period before the National Park was set up, and windfall delivery can be expected to reduce with new National Park policies. The exclusion of the ends of long gardens from Disagree that this is arbitrary- while permitted the boundary is arbitrary since they will still be development rights will still apply, the subject to permitted development rights. exclusion of such land from the settlement boundary will prevent its development with new housing or employment uses (apart from exceptions defined in the Local Plan). The boundary should include residential If there is intervening land between residential development adjacent to the boundary, as well development and the boundary, then that as intervening land. development is not adjacent to the boundary. The settlement boundary methodology does allow for detached areas of housing to be included in the boundary in specific circumstances, but intervening land would not be included in that case.

343

344

Appendices and Glossary

Reg 22 (1) (c) (iii) There were a total of 16 comments on this section. These are summarised below. Borough, City, County and District Councils Four councils commented on Appendix 1 (current development plan policies operating in the National Park), proposing various factual corrections. East Hampshire District Council requested a table to show what each existing policy is being replaced by. East Sussex County Council requested clarification that the list does not cover minerals and waste plans. Parish and Town Councils Three parish councils commented on Appendix 5 (Village Design Statements, Parish Plans and Local Landscape Assessments), requesting the addition or amendment of references to their documents. Rowlands Castle Parish Council requested that our Appendix 1 be aligned with Appendix 1 of the East Hants JCS, and that the word ‘settlement’ be defined in the glossary. Other Organisations The Upper Itchen Valley Society requested the addition of their local parish plan to Appendix 5. There were requests for various words and for acronyms in general to be added to the glossary. Agents and Developers Regret was expressed that the Tranquility Study and SHMA were not available to view when the consultation opened. Individuals There was support for the Special Qualities in Appendix 2. With regard to Appendix 3 (Neighbourhood Development Plans), one individual asked how we are planning to facilitate the extension of the ecosystems approach across the Park boundary, since ecosystems themselves cross the boundary. A minor correction was requested to Appendix 5. Reg 22 (1) (c) (iv) The representations have been taken into account as follows.

Factual corrections have been carried out where appropriate.

Appendix 1 (now Appendix 2) has been converted to a table describing which existing policy is replaced by which Local Plan policy, as requested by East Hampshire DC.

Planning for ecosystems service provision across the National Park boundary is being carried out through the Green Infrastructure Strategy, supported by Local Plan policy SD45: Green Infrastructure.

The word ‘Settlement’ has been added to the glossary in line with one request.

345

The following representations have been considered by the NPA, but changes have not been made to the Local Plan as follows.

Issue Reason Changes requested to Appendix 5 Appendix 5 has been deleted. Other words and phrases to be added to the It is not considered worthwhile defining the Glossary words and phrases requested, since either they are in common usage, or they are not essential to understanding the Local Plan policies

346

Appendix 4

Summaries of main issues raised by representations at Pre-submission stage pursuant to regulation 20

345

346

South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Key Messages There were a total of 23 representations on the Key Messages. A summary of the main issues raised is set out below.

National Agencies No comments received Borough, City, County and District Councils No comments received Parish and Town Councils

 It is a difficult document to read and should be sub-divided into local authority areas (Cheriton PC)  The Local Plan should address the impact of development outside the National Park (Cheriton PC and Steyning PC)  Highlighted various concerns in Tichborne Village (Tichborne PC) Other organisations

 The Local Plan is well sup[ported by evidence and provides a sound basis for cooperation with neighbouring authorities (University College London) Individuals

 Support for the key messages and excellent policies (various)  No mention is made of Bramshott and Liphook and future potential for growth (various)  No mention is made of Nyewood and emerging opportunities in the parish  No plastic grass or artificial turf should be allowed  Allocations are based on what has been submitted to the NPA rather than landscape led.  The conversion of redundant agricultural buildings should not be restricted to occupation by local workers  Concern over access to Loppers Ash allocated under Policy SD90  Place names should be added to the conceptual spatial diagram  The key messages should stress that developing in a National Park is a privilege and so the standards for design should be higher.  There has been insufficient consultation on the Local Plan.  The document is not landscape-led as 78% of allocated sites are assessed in the Sustainability Appraisal as having an uncertain or negative landscape effect  Allocations outside existing settlement boundaries should provide 100% affordable housing.  Various objections to housing allocations in South Harting due to access and landscape impact.  Objection to national parks being subject to the presumption in favour of sustainable development.  The Local Plan should include a policy on major events such as music festivals and vehicle rallies  The interests of Selborne have been well reflected and encapsulated within the Plan (various)

349 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Introduction There were a total of 75 representations on this section. A summary of the main issues raised is set out below.

National agencies Historic England: Welcome and support references to cultural heritage in this section. Confirm HE have been positively engaged in the preparation of the SDLP. Natural England: Welcomes the Vision and Objectives of the Local Plan. Also support the inclusion of ecosystem services at the heart of the Local Plan. Highways England: No concerns with the potential impacts of planned development on the Strategic Road Network.

Borough, City, County and District Councils

 General support for the South Downs Local Plan (Eastleigh BC, Hampshire CC, Horsham DC, Lewes DC, West Sussex CC)  Greater clarification could be given in the Plan on the control of noise in the National Park, including standards to be achieved and when a noise report will be required. A clearer position on development for outdoor entertainment should also be included (Chichester DC).  Note and welcome recognition of importance of the adopted Hampshire Minerals and Waste Plan (2013)  Confirmation of Duty to Cooperate regarding housing need arising in Mid Sussex area of the National Park (Midsussex DC)

Parish and Town Councils

 General support for the Local Plan (Lancing PC, Stedham with Iping PC, Steyning PC, Twyford PC, Woodmancote PC)  Support for the landscape-led approach of the Local Plan (Corhampton & Meonstoke PC, Hawkley PC, Owslebury PC, Elsted and Treyford PC)  Welcome the high level engagement with Parish Councils in the process so far (Corhampton & Meonstoke PC)  The Local Plan remains lengthy and difficult to access. A glossary and compact final version would be helpful to the generl public (Liss PC)  Concerns raised that the right balance for the future of the whole Nationa Park will be achieved or provide the highest protection for niche areas such as Madehurst (Madehurst PC)  Distinctiveness of the SDLP could be improved (Parish of Colemore & Priors Dean)  Greater emphasis could be made of the landscape-led approach in this section (Parish of Colemore & Priors Dean)  Key messages, third para. should refer to ‘meetings with parish representative’ (Parish of Colemore & Priors Dean)  Para.1.41 is inconsistent with the glossary definition of parish plans

350 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Concerns raised with accessibility of online version of the Local Plan and accompanying maps (Pulborough PC)  Fig 1.1 should provide greater clarification regarding the Sandford Principle (Rogate PC)  Para 1.36-38 concern that insufficient weight is given to individual NDPs (Rogate PC)  As the SDLP will replace saved policies of the Lewes Local Plan – additional protection should be given to Bishopston Village and the Tidemills area (Seaford TC)  Introductory text should be corrected regarding designation of the National Park and establishment of the SDNPA (Selborne PC)

Other organisations

 General support for the Local Plan (Cowdray Estate, Folkington Estate, Houndean Residents Association, Murray Planning Assciates, SOS Bohunt Manor Community Action Group, South Downs Society, South Downs Volunteer Ranger Service, Sussex Wildlife Trust, Midhurst Society)  Support for the landscape-led approach of the Local Plan (CPRE Sussex, Friends of Lewes Society, RSPB, South Downs Society, Chichester Society)  Support for the ecosystem services led approach (Sussex Wildlife Trust)  Support and congratulate the SDNPA on preparing a consolidated plan for th whole of the SDNP. Acknowledge should be made in the plan of the potential implications of Brexit, allowing sufficient flexibility to landowners and farmers and support the rural economy (Angmering Estate, Brighton & Hove CC Downland Estate, Leconfield Estate, West Dean Estate).  The Plan should address the disputed public rights of navigation on the River Rother to develop recreational opportunities within the SDNP (British Canoeing).  The Plan has internal conflicts which it is hoped the Inspector will modify to provide clarity and certainty for future development (CALA Homes)  The landscape-led approach should be applied in balance with the need to deliver sustainable development (Cowdray Estate)  Clarification sought regarding SDNPA position on meeting objectively assessed housing need and duty to cooperate. Clear MoUs with relevant HMAs should be provided (House Builders Federation)  Concern raised that lengthy criteria are set for many policies and these may be either irrelevant or an unnessecary burden on minor applications. Also concern over the level of supporting information required for relatively simple planning applications (Sompting Estate, South Downs Land Managers Group)  Question the use of terminology ‘conserve and enhance’ (Sompting Estate)  Concern raised over the consultation process and comments being limited to matters of legal compliance and soundness (Sussex Wildlife Trust)  The SDLP fails the tests of soundness in respect to its duty to cooperation (Thakeham Homes)

351 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues Individuals

 Support for the Plan (multiple individuals)  In light of the allocation SD63, paragraph 1.24 regarding Sustainability Appraisal is inaccurate and unjustified (Cheriton PC Cllr Line)  The Plan does not give consideration to potential development sites on its boundaries with adjoining adjacent Local Authority areas and existing settlements within those  Greater flexibility within the Local Plan would allow communities to meet their needs and the objectives of the SDNP  A Duty to Cooperate issue needs to be addressed regarding Alfriston, as the emerging Wealden Local Plan also refers to housing figures in Alfriston  Concerns raised about parish council and community engagement in preparation of the Local Plan (Lewes District Councillor Victor Ient & various individuals)  Insufficient policies addressing the SDNP statutory purposes (Lewes District Councillor Victor Ient)  Duty to Cooperate issue raised regarding whether parishes partially outside the National Park been adequately consulted regarding planned development within the National Park  Question raised as to whether the Minsitry of Defence have been consulted by the SDNPA on their future land use intentions  Frequent requirement to ‘conserve and enhance’ within policy is unrealistic and will hinder housing targets from being met  Multiple references to biomass as an alternative to fossil fuels are not supported by analysis of local supply availability or the impact on transport infrastructure  Local Plan needs to be more succinct and accessible to be effective. Tighter policy wording is needed to provide protection fitting to a nationally protected area  Concern raised about accessibility of online consultation system  NPPF requires a key diagram and proposals map, neither are included  Para. 1.10 should also refer to the use of land which is not included in the Local Plan  Fig.1.1 should provide greater explanation with reference to sustainable development  Paragraphs 1.11-12 should refer to the NPPF  Insufficient weight is given to the conservation of wildlife and cultural heritage throughout the Local Plan  Too much emphasis is given to ecosystem services  The ‘Spatial Strategy’ does not provide a strategy for the plan and is not carried forward into the Core Policies  The evidence-base is insufficient (except relating to landscape)  No explanation is given of how Local Plan policies will replace existing policies and the difference between these  Concerns raised on consultation process for settlement boundary changes

352 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Chapter 2: Vision & Objectives There were a total of 27 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Historic England supported the reference to a conserved and greatly enhance heritage in the Vision and the second Local Plan objective to conserve and enhance the cultural heritage of the National Park. Borough, City, County and District Councils

 Chichester District Council commented that the objectives were broadly defined by the national park purposes. Parish and Town Councils

 The Local Plan should conserve, enhance and protect the natural beauty, wildlife, cultural and archaeological heritage of the SDNP and promote understanding of its special qualities, to the benefit of both residents and the wider general public (Bramshott and Liphook PC)  Supports the Vision but concerned that it is unattainable and unrealistic (Cheriton Parish Council)  Amend the objectives to define sustainable development and acknowledge the external pressures from development (Cheriton PC)  Object to the phrase ‘broadly compatible’ in regard to objective 9 on local businesses (Parish of Colemore and Priors Dean)  Insufficient reference made to enforcement (Rogate PC)  Strong support for the introduction (Selborne PC)  The vision should reference new technology (Stedham with Iping PC) Other organisations

 Agrees with the vision and objectives particularly in regard to ecosystem services (British Canoeing and Lewes District Green Party)  Welcomes the draft Local Plan in its entirety (Fittleworth and District Association)  The chapter should include resilience as well as sustainability in order to address climate change and other issues (Lewes District Green Party)  There should be increased interface between the National Park and its surrounding areas, for example, the Manhood Peninsula (Manhood Peninsula Partnership)  Supports the vision and objectives particularly the third objective on habitats (RSPB)  Endorses the vision and objectives (South Downs Society)  Supports the vision and objectives, but disappointed that there is no objective about net gains in biodiversity (Sussex Wildlife Trust)  Strongly supports the aims and objectives of the Local Plan (University College London)  Supports the vision and objectives which are well conceived and reflect the consultation process and the purposes and duty of the National Park (Sompting Estate) Individuals

 The vision should reference new technology  There is no objective relating to additional residential development

353 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 The NPA should consider allocating sites for housing on the edge of the National Park, for example, at Peace Haven  Supports the first two objectives, but thinks that they should be used conservatively and negatively  Supports the first four objectives and thinks the Local Plan should seek to restore and recreate as well as conserve and enhance the landscape  The vision and objectives should reference major events such as music festivals and vehicle rallies  The vision and objectives are unrealistic and are not focused on the requirements of plan making  No mention of restricting hunting and shooting

354 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy Chapter 3 – Spatial Portrait and Spatial Strategy There were a total of 34 representations on this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Welcomes and supports the spatial strategy as being the most appropriate of the options in terms of protecting the historic environment. Also welcome the identification of the cultural heritage and historic features in the broad areas. Borough, City, County and District Councils

 Request that greater recognition is given in the text to Stanmer Park as a gateway to the National Park. Reference to the promotion and enhancement of walking and cycling links to and from the City would also be welcomed. (Brighton and Hove City Council)  Support the landscape led approach which relects National Park purposes. (Chichester District Council)  The proposed development strategy is considered to be consistent with national policy. Disappointed that the level of provision being made in the Local Plan represents an annual shortfall of 197 homes per annum against the OAN. (Mid Sussex District Council)

Parish and Town Councils

 Advise that the Local Plan should contain a set of Core policies that apply across the National Park and separate sections dealing with the issues that affect each area by County, such as pressure for major transport infrastructure. The strategy for medium level of growth dispersed across the National Park, safeguarding the importance of the habitats and species of the Itchen and protecting the SAC is inconsistent with Allocation Policy SD63 (Cheriton Parish Council)  Support the dispersed medium spatial strategy, however consider that this approach does not adequately take account of the need to protect the identity and intrinsic character of smaller villages and towns, especially where these are located close to larger neighbouring settlements. This is particularly the case with the settlements of Easebourne and Midhurst, where there is particular risk of coalescence between the two places. (Easebourne Parish Council)  The SNDPA has not worked hard enough to meet its own housing needs or Gypsy and Traveller needs and all SHLAA sites should be re-assessed so as not to transfer the problem to EHDC. (Four Marks Parish Council)  Para 3.38 has a number of errors as Ashford Hangers is a NNR (it is not in itself an SAC, only part of the East Hampshire Hangers SAC); Duncton to Bignor Escarpment SAC (not ‘and’); Lewes Downs (Mount Caburn) NNR and Lewes Downs SAC. Para 3.45 should refer to the ancient woodland areas of the Scarp Slope. The Wealden Edge Hangers, part of the East Hampshire SAC is arguably one of the ecologically most interesting and diverse series of Chalk woodlands in Britain. (Colemore & Priors Dean Parish Council)  Support the approach to OAN. (Selbourne Parish Council)  No mention is made in para 3.31 of the negative impact of aircraft noise from Farnham airport and from a possible second runway at Gatwick (Stedham with Iping Parish Council)  Gateways sections paras 3.43 and 3.56 and the Hubs sections paras 3.44 and 5.57 should reference Steyning as being an attractive historic market town. (Steyning Parish Council)

355 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Request that para 3.14 is amended to say that Twyford Village occupies a key position on the western boundary and has good facilities both for visitors and for a wider population. (Twyford Parish Council) Other organisations

 There should be more emphasis on building houses in the National Park to: relieve pressure from neighbouring authorities and adjacent settlements; and to recognise the important contribution that increasing the supply of housing can make to affordability, the rural economy and to support thriving places. A further call for SHLAA sites should be carried out and sites re-tested against more realistic criteria. (Various organisations)  Sites such as land at Lower Hoddern Farm to the north east of Peacehaven can provide a long-term growth location that can contribute towards the National Park housing requirement whilst contributing toward the sustainability of Peacehaven. (EPV (East sussex)Ltd)  Welcome the reference in the text to the Brighton & Lewes Downs Biosphere Reserve designated by UNESCO, but this should also be referenced in one of the policies (Brighton & Lewes Downs Biosphere Partnership)  Support mention of the challenges around flooding and opportunities for recreation on the Rivers Arun, Adur, Cuckmere and Ouse river corridors. (British Canoeing)  The dispersed medium option development strategy is considered by SDNPA to do most to promote the vitality of a wide range of settlements in the National Park and support the rural economy, whilst protecting and enhancing the special qualities of the National Park. However, option 4 would contribute more to maintaining existing rural services in smaller settlements. Greater recognition should be given to the role and character of the settlements. The approach to managing growth as set out in paragraph 3.115 is unrefined and therefore unable to conserve and enhance the qualities of individual towns and villages. The spatial strategy is not justified against objective 7 of the Pre-Submission Local Plan. (Greatham Voice)  The Spatial Portrait should include mention of the river corridors of the Itchen and Meon River Valleys. (Hampshire CPRE)  Lewes as a key settlement and hub should be mentioned in para 3.57 (Houndean Residents Association)  The Vision, Objectives and Spatial Portrait Strategy are well conceived, reflect the extensive consultation process through which they were developed, and reflect the Purposes and Duty of the Park. (Sompting Estate)  The potential 6000 new houses at Bishopstoke close to the National Park western boundary at Colden Common should be mentioned on the Spatial map. (South Downs Land Managers Group)  Para 3.88, the River Adur Corridor should include additional wording to explain that the Downs Link is available for use by walkers, cyclists and equestrians and not just cyclists. (The British Horse Society)

Individuals

 Object to the Local Plan as this Chapter does not provide the coherent evidence base and strategy that is needed to conform to the requirements of NPPF paras156 and 157. The Spatial Portrait does not identify or objectively assess the planning needs of the area (required by NPPF 14). The National Park is not a single entity for local planning purposes as

356 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

it is diverse and dominated by neighbouring large urban areas which exert specific pressures on the National Park and require a policy response. (Various individuals)  Consider that parts of Liphook, particularly the Bohunt Manor Estate should not be within the National Park boundary.  There are policy errors and ommissions. Figure 3.2 The South Downs National Park contains a number of errors as the A31 is labelled A3, watercress line is shown as a working line, there is an inaccurate western boundary around Winchester and the course of the River Itchen is incorrect. Fig 3.3 is a selection of unco-ordinated and unlinked facts. There is a general lack of understanding of the complexity of planning policy issues and of the requirement for clear and precise policies to be directed at resolving real strategic and local issues, rather than a reliance on generic statements. The pressures that the downland and the Itchen valley face are both related to the fact that they are part of a wider vibrant economic region. The identification of Cheriton for development and the allocation of major development at Hinton Marsh is counter productive interms of effects on hydrology and designated nature conservation sites.  Support paras 3.18 and 3.19. The impacts of the watercress industry in terms of heavy lorries and pollution of watercourses needs to be addressed. (Cllr Jackie Porter, Hampshire County Council)  Para 3.31 fails to mention the negative impact of aircraft noise from Farnham airport and possible impacts if the second runway at Gatwick goes ahead.

357 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Chapter 4: Core Policies Introduction There were a total of 8 representations on this policy. A summary of the main issues raised is set out below.

National agencies Natural England welcomed the inclusion of sustainable development and ecosystem services as core policies within the plan. Borough, City, County and District Councils No comments were made by any Borough, City, County and District Councils Parish and Town Councils

 The core policies do not set out clearly what is unacceptable development in the National Park and what will be encouraged (Cheriton Parish Council) Other organisations

 Impracticable to apply core policies across the whole National Park. Instead it is suggested that policies should relate to identified character areas and their respective landscapes. Individuals

 The definition of sustainable development should include embedded carbon, life cycle and financial sustainability.  Support core policies particularly ecosystem services.  The Core Policies are inadequate and insufficient to provide the basis for a Local Plan in accordance with NPPF.

358 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD1: Sustainable Development There were a total of 44 representations on this policy. A summary of the main issues raised is set out below.

National agencies

 Historic England suggests that in order to comply with paragraph 133-4 of the NPPF that criterion 4(b) of SD1 should refer to ‘public’ benefits. Historic England welcomes the approach of giving great weight to conserving and enhancing the natural beauty, wildlife and cultural heritage of the National Park in the determination of planning applications. Borough, City, County and District Councils

 The approach in the Local Plan is consistent with the priorities in the City Council set out in the City Plan. However, greater reference should be made to the Brighton & Lewes Downs Biosphere Reserve (Brighton & Hove City Council)  Paragraph 4.7 on cumulative development should also reference development outside the National Park (Brighton & Hove City Council) Parish and Town Councils

 Particularly welcome the detailed wording of policy SD1 (Buriton PC)  Strongly supports Policy SD1 (Fernhurst PC)  Policies SD1 to SD18 are supported , but makes the Local Plan relatively week in relation to town and village centres (Liss PC)  Strongly support the principle of considering cumulative development, concerned that criterion 4 of Policy SD1 is too permissive and suggests re-ordering the guiding principles of the Local Plan set out in paragraph 4.4 (Parish of Colemore and Priors Dean)  Policy SD1 requires a clear strategy for implementation to be effective and there should be explicit mention of traffic impacts on the roads and lanes of the National park, tranquillity and dark skies (Upham PC)  Criterion 4 of Policy SD1 is unsound, because the use of the words 'unless exceptionally' weakens the statutory purposes, there is no statutory provision for it and the wording would invite developers to exploit that weakness (Selborne PC) Other organisations

 Supports Policy SD1 and paragraph 4.5, but thinks that the management of commercial shooting and the sensitive balancing of conflicting priorities requires a specific policy in the Local Plan (Iford Parish Meeting)  Supports Policy SD1, but thinks more detail is required on what constitute material considerations (Madehurst Parish Meeting)  Reference should be made to community food growing projects as an element of green infrastructure and of sustainable development otherwise it may be overlooked (Brighton & Hove Food Partnership)  Reference should be made to the Brighton & Lewes Downs Biosphere Reserve (Brighton & Hove Biosphere Partnership)  Supports Policy SD1 particularly criterion 2 (British Canoeing)

359 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Object to the fourth criterion of policy SD1 which would allow development that does not conserve the landscape, natural beauty, wildlife and cultural heritage of the National Park (CPRE Hampshire and CPRE Sussex)  Supports Policy SD1 and suggests paragraph 4.11 is extended to encourage development outside the National Park (DMH Stallard LLP)  Support policy SD1 but thinks it could be amended to apply to more than planning applications (Eastbourne Downland Group)  Too little consideration has been given to the overall development needs of the National Park and a medium growth strategy will not deliver an adequate provision of growth. Suggests that the development of Hoddern Farm will help to meet the housing needs of the National Park and Peacehaven (EPV)  The Local Plan places far too much emphasis on the preservation of the natural environment to the detriment of economic and social issues particularly with respect to housing. It also ignores the functional relationship between the National Park’s population and settlements adjacent to the Park’s boundary such as Liphook (Green Village Investments)  The social and economic aspects of sustainable development should be weighed in the balance with environmental matters. Also suggests the deletion of the word ‘exceptionally’ from criterion 4 of Policy SD1 (Cowdray Estate)  Largely supports the policy thinks that further detail should be given on what impacts are being referred to how the assessment of cumulative impacts will be assessed. Also favours a more positive wording of criterion 4 of the policy (Leconfield Estate)  The concept of ‘resilience’ should be added to the definition of sustainable development (Lewes District Green Party)  Paragraph 4.11 should be extended to reflect the national policy requirement to encourage sustainable development, which includes established employment areas outside the National Park (Hopegar Properties)  Suggests that the socio-economic duty of the Naitnal Park Authority should be included in the guiding principles of the Local Plan (South Downs Land Managers)  Support Policy SD1 (South Downs Society)  The definition of sustainable development should include embedded carbon, life cycle and financial sustainability.  Strongly supports Policy SD1 (Sussex Wildlife Trust)  The definition of social and economic wellbeing should include health. The guiding principles set out in paragraph 4.4 should also refer to greenwaste collection and composting facilities (Midhurst Society) Individuals

 Support for policy SD1, which is entirely appropriate, justified, effective, consistent with NPPF and procedurally and legally correct.  Inconsistency between the use of ‘will’ in policy SD1 and ‘may’ in paragraph 4.8 and the recommendation that both should say ‘will.’  Suggest an alternative definition of cumulative impacts.  Thinks that the Local Plan should define sustainable development and address the issue of plastic waste (Lewes District Councillor)  The policy will be used to create inertia by preventing harm but not promoting good development.  Support for Policy SD1 providing that it is using the Brundtland definition of sustainable economic development and not ‘sustaining economic development.’

360 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Taking a landscape-led approach and seeking the delivery of multiple ecosystem services are only material considerations that do not fully reflect either the wider purpose of the planning system. The plan therefore will provide less environmental protection than the policies it replaces and will result in more development than implied by the Vision. There is no implementation or monitoring framework for this policy, which is unacceptable.  Welcomes the commitment to sustainability.  Supports the wording of paragraphs 4.4, 4.7 and 4.10.

361 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD2: Ecosystem Services There were a total of 35 representations on this policy. A summary of the main issues raised is set out below.

National agencies

 The Environment Agency supports the overriding principles of this policy and in particular specific reference to criteria a, b,c,d,e and i.  The Forestry Commission comments that more clarity is required on defining supporting services, provisioning services are marketable products produced from the landscape, regulating services often have a transboundary impact and cultural services relate to health and wellbeing benefits. Recommends that the Local Plan should demonstrate how natural capital benefits derived from both the rural and urban context will be achieved through the planning process.  Historic England welcomes the recognition of cultural heritage as part of ecosystem services in Figure 4.2, but are disappointed that there is no specific reference to cultural heritage in Policy SD2.  Natural England pointed out that the Local Plan does not contain policy protection of the best and most versatile agricultural land and soils. Borough, City, County and District Councils

 The requirement for a statement on ecosystem services to accompany all planning applications is unreasonable particularly for householder application and so the policy is not justified (EHDC)  Policy SD2 appears very onerous in its requirements as it applies to all development including small and is difficult for applicants and decision makers to interpret (Winchester City Council) Parish and Town Councils

 Supports Policy SD2 (Fernhurst PC, Madehurst Parish Meeting and Selborne PC)  Policy SD2 is supported but its enforceability is questioned (Liss PC)  Objects to the policy requirement for all planning applications to be accompanied by an Ecosystem Services Statement (Stedham with Iping PC and Woolbeding with Redford PC) Other organisations

 The benefits of rural housing should be reflected in Policy SD2 (Angmering Estate)  Supports Policy SD2 (British Canoeing)  the focus on ecosystems designed to maintain natural capital and value the  The role of ecosystems services in providing important societal and environmental benefits is generally neglected in Local Plans, and so this is an important step forward (CPRE) Hampshire and CPRE Sussex)  Supports the principle of Policy SD2 (CLA)  Strongly supports the prominence given to the consideration of ecosystem services, but are concerned by potential conflicts between the various ecosystem services (Eastbourne Downland Group)

362 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Considers that there is too much emphasis on ecosystems and landscape which hinders residential development in appropriate locations at the time of a housing crisis. Recommends that more emphasis needs to be given to meeting OAN or at least getting closer to it and to ensuring that growth within the National Park Area is not stifled by landscape designations (EPV)  The Local Plan fails to consider the unique opportunity at Bohunt Park, Liphook to deliver multiple ecosystem services (Green Village Investments)  The benefits of rural housing should be reflected in Policy SD2 (Leconfield Estate)  Welcomes that all development proposals must be supported by a statement that sets out how the development proposal will impact on ecosystem services. Air quality should be added as an ecosystem service (Lewes District Green Party)  Supports Policy SD2 (South Downs Society)  Strongly supports Policy SD2 and the production of a technical advice note (Sussex Wildlife Trust)  Policy SD2 should also refer to the wind and sun as ecosystem services (The Midhurst Society)  The Local Plan should also include the re-sues of disused railway lines (The Watercress Way)  Strongly support Policy SD2 and suggests the addition of a new criterion on adaptation to climate change (University College London)  The benefits of rural housing should be reflected in Policy SD2 (The Edward James Foundation) Individuals

 The requirement for a statement on ecosystem services to accompany all planning applications will add cost and bureaucracy, as well as slowing down the planning system.  The policy is laudable in its ambition but it is questionable how it can be enforced (EHDC Councillor)  Support Policy SD2 but think that it should be cross referenced throughout the other policies  Policy SD2 is a list of objectives rather than a policy and so does not provide a clear framework for decision-making. There are no targets or implementation frameworks relating to the policy. It is unrealistic that the policy should apply to all applications.  Supports Policy SD2 as it builds on the legacy of the late Colin Tingle, who worked on the Lewes Neighbourhood Plan.  The policy is imprecise and somewhat repetitive. It belongs in the Partnership Management Plan rather than the Local Plan.

363 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD3: Major Development There were a total of 41 representations on this policy. A summary of the main issues raised is set out below.

National agencies

 Historic England omits the conservation and enhancement of the historic environment, which is an integral part of sustainable development.  Portsmouth Water noted that the re-use and recycling of water in paragraph 4.28 can be a high carbon option. Borough, City, County and District Councils

 Supports Policy SD3 and consider it important that the unique circumstances of the National Park and its wider relationship with surrounding areas is acknowledged (Brighton & Hove City Council)  Parish and Town Councils

 Welcomes and supports the robust wording of the policy (Buriton PC)  Strong support (Fernhurst PC)  Employment should be added to the principles of sustainable development in paragraph 4.28 (Midhurst Town Council)  The ‘potential harm test’ should be applicable to all planning applications in the National Park and not just major development (Rogate PC)  The word ‘serious’ should be omitted from the policy as no potentially adverse impact should be allowed in a national park (Selborne PC)  The definition of sustainable development in paragraph 4.28 should include embedded carbon, life cycle and financial sustainability (Stedham with Iping PC) Other organisations

 Strong support providing that the potential impacts of proposals are actually strictly assessed in relation to each individual setting as indicated in the Maurici opinion (Madehurst Parish Meeting)  Policy SD3 and its supporting text differs from the NPPF in a number of ways without adequate explanation. SD3 (1) should define ‘serious impact.’ Paragraph 4.25, first bullet fails to recognise ‘national considerations. Paragraph 4.25, second bullet point distinguishes between impact on the local economy and the general benefits of construction. Paragraph 4.25, third bullet introduces an assumption in regard to local need (Adam Hendry)  Reference should be the Brighton and Lewes Downs Biosphere Reserve (Brighton & Lewes Downs Biosphere Partnership)  Welcomes the clear local interpretation of national policy on major development and how it should be applied to the special qualities of specific national parks. What is considered small scale with little impact in one area of one National Park, could be considered to have major impacts on the special qualities in another part of the same park or in another national park. Having a locally defined policy provides greater clarity for developers and helps reinforce support and understanding among NPA Members (Campaign for National Parks)  Support for SD3, which provides useful clarity (Eastbourne Downland Group)

364 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 The GDPO definition of major development should be used in the Local Plan (EPV East Sussex)  The definition of major development used in the Policy is not based on national planning policy, does not draw in directly comparable case law and relates incorrectly to plan making rather than development management. Parts of SD2 either repeat national policy or is ultra vires. The policy should be deleted. (Green Village Investments)  Criteria 1 and 2 simply repeat national policy. The policy fails to explain how the NPA will determine what constitutes major development. The requirements set out in criterion 3 are too high and will impact adversely on viability. (Hall & Woodhouse Ltd and Prince’s Mead School Trust)  Assessments of major development should examine incremental development (Houndean Residents Association)  Clarification required on sites allocated in NDPs or granted planning permission before the Local Plan is adopted (JLL)  Supports the policy particularly the need for exceptional circumstances, the consideration of cumulative development and the sustainability requirements in criterion 3 (Lewes District Green Party)  Policy SD3 should not be applied to sites that are already allocated for development such as Old Malling Farm. The sustainability principles set out in the third criterion of policy SD3 are not consistent with the three tenets of sustainable development set out in the NPPF (Luken Beck)  Major development may be necessary to ameliorate the accumulation of iterative environmental damage (Manhood Peninsula Partnership)  The policy should give clear guidance for determining whether a development proposal is major (Rydon Homes Ltd)  Welcome the wording of SD3 on the definition of major development which reflects the Maurici opinion, the views of this organisation and the work carried out recently on behalf of CNP, CPRE and the National Trust into the workings of the “major development test” across the national parks. It is a fair reflection of the necessity of judging the potential impact of developments in their own setting rather than on a “by numbers” basis (South Downs Society)  The definition of major development is too subjective, overtly negative and should differentiate between urban areas and the countryside. (Springs Smoked Salmon)  Strongly supports SD3, but suggests that the word ‘serious’ is deleted as it has no planning context (Sussex Wildlife Trust)  All development will increase the amount of traffic on the roads that are also used by vulnerable users such as equestrians. Suggests amending the final bullet point of paragraph 4.25 to mention public rights of way (British Horse Society)  New developments should make a positive contribution to the generation of clean energy. Generating surplus of clean energy would be a more positive and ambitious target than zero carbon. (Midhurst Society)  Criterion 1 of SD3 should refer to ‘local’ context so that the scope for context is not interpreted too widely and beyond what is reasonable (National Trust)  Strongly support the strict conditions for the approval of major development (Wiggonholt Association) Individuals

 The policy and supporting text is overly legalistic.

365 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Queries who makes the decision on what is in the public interest. No mention of fracking or mineral exploration.  There should also be a policy on major events.  The sustainability criteria should apply to all development and not just major development.  The test for major development in SD3 is much weaker than in the NPPF, and this will allow too much major development to occur.  Strongly support the inclusion of ‘health’ and wellbeing within the policy (University College London professor)

366 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Section 5a – Introduction to Landscape There were a total of 7 representations on this policy. A summary of the main issues raised is set out below.

Specific consultation bodies – national agencies and utility providers No comments received. Specific consultation bodies – other local authorities No comments received. Parish and Town Councils

 There is considered to be an omission of a separate policy on large scale events such as music festivals in accordance with paragraph 27 of the DEFTA National Parks Circular 2010 (Cheriton PC) Other organisations and individuals

 Support for the subject matters such as views, tranquillity, and dark night skies) as upfront strategic policies alongside other more typical policies (South Downs Society, Individual).  Support for the removal of the unnecessary qualification of ‘adverse impacts’ as ‘unacceptable’ as found in the Preferred Options Local Plan (South Downs Society).  Objects to the Local Plan document as there is insufficient emphasis on enhancing, and not just conserving, the special qualities of the National Park, with particular regard to habitats, farm practices and economy, and design standards (Individual)  Considers the Local Plan omits emphasis on the importance of protecting land for agricultural use, in addition to its visual qualities (South Downs Society).

367 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD4: Landscape Character There were a total of 40 representations on this policy. A summary of the main issues raised is set out below.

Specific consultation bodies – national agencies and utility providers Historic England: Welcomes and supports clauses 2 and 5 of Policy SD4 as part of the positive strategy for the conservation and enjoyment, and a clear strategy for enhancing, the historic environment, although it is considered that these clauses would sit better within a specific historic landscapes policy within the section of the Plan on the Historic Environment. Welcomes the reference to local distinctiveness in paragraphs 5.8 and 5.11. Welcomes the reference to character assessments and Village Design Statements in paragraph 5.9. Welcomes and supports the subsection on Designed Landscapes (para 5.13-5.16) although paragraph 5.15 could say “Proposals which may affect the significance of designed landscapes…….” and we consider that these paragraphs would sit better within the section of the Plan on the Historic Environment. Welcomes the reference to historic landscape features in paragraph 5.18 Southern Water: Objects to the current wording of criteria 3 in Policy SD4. This is because it could create barriers to statutory utility providers, such as Southern Water, delivering essential infrastructure required to serve existing and planned development allocated in the Local Plan. Southern Water understand that SD4 should be read in conjunction with Policy SD44: Telecommunications and Utilities Infrastructure. However the current wording of criteria 3 of Policy SD4 could conflict with this, and the exceptions allowed through National Policy should be made explicit to avoid any such conflict. Requested that additional wording be added to criteria (c) to state that where exceptional circumstances exist, development must be demonstrated to be in the public interest.

Specific consultation bodies – other local authorities

 Policy is supported and considered sound (Winchester District Council)

Parish and Town Councils

 General strong support for the policy (Colemore & Priors Dean PC, Fernhurt PC, Madehurst Parish meeting, Rowlands Castle PC, Selborne Parish PC, Slindon PC)  Specific support for criteria (c) (Madehurst PC)  Support for the Landscape Character assessment as set out in Figure 5.2 (Ringmer PC)  Comment that this policy to be treated as a core policy (Colemore & Priors Dean PC).  Objection to the removal of reference to the need for development proposals to be informed by community-led or local landscape character assessments from policy wording of SD4 (Buriton PC)  Objection as it considered that the policy omits that the capacity of the landscape to accommodate development should take account of historic landscape character and the settlement pattern (Easebourne PC).  Regrets the Local Plan does not specifically identify local gaps. Queries if criteria (c) is strong enough (Liss PC).

368 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Request that hedges should be specifically mentioned in this section (Upham PC).

Other organisations and individuals

 General support for SD4 and its principles (Angmering Estate, Brighton and Hove Council’s Downland Estate, Leconfield Estate, South Downs Society, Sussex and Hampshire Wildlife Trusts, The Chichester Society, The National Trust, The Wigganholt Association, Member Lewes District Council, various individuals).  Supports reference to experiential and amenity quality of the landscape in Policy SD4, in addition to landscape character, is an important amplification (Individual).  Support for criteria 3 and the value of open and undeveloped land (Eastbourne Downland Group).  Support for criteria 4 and reference to green and blue corridors (Individual)  Commented that justifiable and necessary agricultural and rural business development should not be disadvantaged by this policy (CLA).  Commented that the policy is focused on development management issues and should be amended to also look more broadly at landscape character (Eastbourne Downland Group).  Objection to the policy due to omission of stress that development proposals which cause harm to a designed landscape will be refused (Folkington Estate).  Objection to the policy on the grounds it should be strengthened to deal with development other than buildings, such as the building of fences, removal of hedges and the construction of private trackways (Member, Lewes District Council)  Omission of criteria in the policy and elsewhere in the Local Plan on the impact of major changes to agriculture on predominantly open land including farm buildings (Member, Lewes District Council).  The supporting text at paragraph 5.10 is considered to omit explanation of what circumstances a landscape appraisal would be required (Angmering Estate, Brighton and Hove Council’s Downland Estate, Leconfield Estate, West Dean – The Edward James Foundation).  Objection to criteria (c) as protection of gaps may lead to artificial separations (Individual).  Objection to criteria (c) on grounds it does not provide sufficient protection for strategic gaps. Requests additional wording to the policy to state that there is a clear presumption that preservation of landscape character will take precedence over other policies (Individual).  Objection to the policy on the grounds that wording is not clear. The policy requirement to safeguard the experiential and amenity qualities of the landscape is too vague. It is not clear that landscape is given a priority (Individual).  No definition of blue corridors, or blue infrastructure or policies for it (Individual)  Request for minor amendment to criteria 4 to add reference to blue corridors in the second sentence (Sussex and Hampshire Wildlife Trusts).

369 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD5: Design There were a total of 29 representations on this policy. A summary of the main issues raised is set out below.

Specific consultation bodies – national agencies and utility providers Historic England:

 Welcomes and supports Policy SD5, particularly clauses c) and f), and supporting paragraph 5.19, although reference could perhaps be made to Conservation Area Character Appraisals as a reference source for appropriate and sympathetic architectural design.  Welcomes the list of considerations in paragraph 5.20 to inform a contextual analysis, but we would like to see a specific reference to historic landscape features as a consideration.  Welcomes and supports paragraph 5.24

Specific consultation bodies – other local authorities

 Support for the policy and consider it sound. Minor wording change is suggested: reference to ‘visual amenity’ for consistency with the Landscape and Visual Amenity Checklist (Winchester City Council). Parish and Town Councils

 Support for the policy (Fernhurst PC, Madehurst Parish Meeting, Midhurst TC, Petersfield TC, Rowlands Castle PC, Selborne PC, Slindon PC)  Objection on grounds of omission in the policy of matters relating to privacy and amenity of existing neighbours and future occupiers explained in paragraph 5.33 (Buriton PC)  Objection on grounds of loss reference to Village Design Statements in the policy as was previously included in the Preferred Options (Buriton PC).  Request for the last part of line 4 in paragraph 5.33 to be deleted ‘unless outweighed by innovative design solutions that mitigate these impacts.' as it is unnecessary, confusing and could potentially allow conflict to arise’ (Selborne PC)  Additional wording requested for the prevention of electric gates and gated communities (Stedham with Iping PC).  Objection on grounds of lack of guidelines on maximum density (Stedham with Iping PC)  Request for explicit note the need to avoid car dominated frontages and over dense development as part of criteria (d) (Upham PC)  Request for a draft of the streetscene should be provided for all proposals in para 5.22 (Upham PC)

Other organisations and individuals

 General support for policy SD5 (various organisations and individuals).  Support for reference to keep key landscape features such as trees and hedges (Lewes District Green Party)

370 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Support for reference to maximising sustainable technologies. Request wording change to state that solar panels could be approved even if judged to have landscape or impact on views (Lewes District Green Party).  Commented that it would be helpful if the policy could look more broadly at design, not just planning applications (Eastbourne Downland Group).  Request for amendment to design principles to allow that buildings should be appropriate for their intended use (DMH Stallard LLP).  Should include reference to Sport England’s Active Design Principles (Sport England)  Care is needed on emphasis arising from the change from ‘will be refused; to ‘will only be permitted’. Suggested tighter wording is needed for a nationally protected area (Individual)  Does not disagree with the principles of the Policy but the policy cannot exist with all the other requirements of the Plan, says there should be some ‘give’ elsewhere in the plan (CALA Homes)

371 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD6: Safeguarding Views There were a total of 29 representations on this policy. A summary of the main issues raised is set out below.

Specific consultation bodies – national agencies and utility providers Historic England: Welcomes and supports Policy SD6, particularly clause 2 d and paragraph 5.37.

Specific consultation bodies – other local authorities

 Support for Strategic Policy SD6. We would welcome the opportunity to work with your authority in relation to safeguarding key views to the Park (such as Chanctonbury Ring) from key locations within Horsham District (Horsham District).  This policy is supported and considered to be sound (Winchester City Council).

Parish and Town Councils

 General support for Policy SD6 (Buriton PC, Fernhurst PC, Madehurst Parish Meeting, Midhurst TC, Selborne PC, Slindon PC).  Comment that this is a generic policy and doesn’t specific actual views or viewpoints (Rogate PC).  Request that reference is made to views and viewpoints defined in NDPs must be protected (Rogate PC)

Other organisations and individuals

 General support for Policy SD6 (various individuals)  Objection to the policy on ground of omission of reference of views including from accessible water (British Canoeing).  Objection to the policy on the grounds that allocation sites and other potential sites may be in proximity of public rights of way. Request that the policy be amended to allow allocated sites which sit in proximity of a PRoW to come forward and it may not be possible to conserve and enhance that view (CALA Homes).  Commented that justifiable and necessary agricultural and rural business development should not be disadvantaged by this policy (CLA).  Objection to the policy on grounds it must state that it applies to temporary developments as well as permanent developments and there must be no exceptions in order to comply with SDNP Purpose number 1 (Individual).  The importance of neighbouring LPA's policies and the distance from the SDNP should be recognised in the consideration of developments in the vicinity of the Park (DMH Stallard LLP).  Objection to the policy on grounds wording should be included to state that landscape outside the National Park which lies within key views from the Park, or provides views of key landmarks within the Park will also be protected (Folkington Estate).

372 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Request that ‘only’ be added to criteria 2 and 3 to read ‘Development proposals will only…’. (Hampshire and Sussex Wildlife Trusts).

373 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD7: Relative Tranquillity There were a total of 33 representations on this policy. A summary of the main issues raised is set out below.

Specific consultation bodies – national agencies and utility providers No comments received.

Specific consultation bodies – other local authorities

 This policy is supported and considered to be sound (Winchester City Council)

Parish and Town Councils

 General support for SD7 (Buriton Parish Council, Fernhurst PC, Iford PC, Madehurst PC, Colemore & Priors Dean PC, Rowlands Castle PC, Selborne PC, Slindon PC, Stedham with Iping)  Comment that paragraph 5.44 should add reference to the means of ascertaining the tranquillity status of a particular site (Colemore and Priors Dean PC).  The Parish Council was concerned that its special interest in this provision should lead to the provision being significantly toughened (Rogate PC)  Comment to include measures to protect against Farnborough airport expansion.  Objection to point two on grounds it should refer to traffic impacts and call for a traffic impact assessment (Upham PC).

Other organisations and individuals

 General support for SD7 (Friends of Lewes Society, HotelDesigns, On behalf of Hopegar Properties, South Downs Society, The Chichester Society, The City of Winchester Trust, The Wiggonholt Association, individuals)  Comment that Figure 5.4 showing tranquillity scores in the National Park is small and does not magnify so cannot be checked (Houndean Residents Association).  Object to the policy on grounds that it is unclear as to who will make decisions relating to tranquillity, who will provide advice as part of the DM process, and that the planning concept is imprecise/unquantified. Also queries how robust evidence base is (Angmering Estate, Leconfield Estate, West Dean – The Edward James Foundation).  Object as it is not clear how the policy should be applied (individual)  Objection due to lack of clarity on the word ‘relative’ of the term ‘relative tranquillity’ and implications for farm operations (South Downs Land Managers Group).  Objects because the reference to the aural environment is insufficient and there should be a separate policy that should include noise standards (Individual)  Object on grounds that policy should be strengthened to control land uses and activities with potential to reduce tranquillity by residents and visitors such as drone flying and outdoor festivals (CPRE, South Downs Society).

374 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Objection on grounds that the Local Plan should include a core policy for large scale events (Individual).  Object to the policy on grounds that a new criteria is required which sets noise curfew and zone (Individual).  Objection to the policy on grounds that an addition should be made to criteria (b) which says where these impacts are not commensurate with approved uses or neighbouring Local Plan allocations (DMH Stallard LLP).  Objection on grounds that it should include a requirement for planning applications to provide a tranquillity study including decibel measurements and predicted decibel measurements (Lewes DC councillor).  Objection on grounds the policy should have an additional paragraph about the negative impacts of certain types of business on tranquillity and that tranquillity of residents and visitors should be paramount, not the business benefits (Individual).

375 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD8: Dark Night Skies There were a total of 39(TBC) representations on this policy. A summary of the main issues raised is set out below.

Specific consultation bodies – national agencies and utility providers No comments received. Specific consultation bodies – other local authorities

 General support for the policy (Brighton & Hove City Council).  Comment that criteria 2 should add the word ‘negatively’ to read ‘sky quality in the surrounding area is not negatively affected’ (Brighton & Hove City Council).  Comment that this policy is very complex and will be difficult for applicants and decision makers to interpret. The Sky Quality Measurement Map referred to in the policy must be available and detailed enough to determine which Zone any given application site falls into (Winchester City Council). Parish and Town Councils

 General support for the policy (Buriton PC, Cheriton PC, Fernhurst PC, Hawkley PC, Iford PC, Liss PC, Madehurst PC, Midhurst TC, Colemore & Priors Dean PC, Rowlands Castle PC, Selborne PC, Slindon PC)  Support for paragraph 5.61 (Colemore & Priors Dean PC).  Comment that internal lightspill from large glass windows should also be addressed through the policy (Buriton PC).  Comment that the category ‘E3/4 Urban’ does not reflect the sky quality of Buriton and other villages in the National Park (Buriton PC).  A clear Policy containing unambiguous criteria that allow for both measurement and monitoring of the Policy at all stages of development and into the future (Cheriton Parish Council)  Comment that lighting installed within a swimming pool can be visible from above and should be included within the policy (Fernhurst PC).  Objects, querying, in addition with the Dark Sky policy, how did 3H Motors at West Meon obtain permission for high spotlights? (Kilmeston PC).  Comment on paragraph 5.58 to add reference to means of identifying a specific sites Sky Quality Measurement (Colemore & Priors Dean PC).

Other organisations

 General support for this policy (Hampshire & Sussex Wildlife Trusts, South Downs Society, DMH Stallard LLP, Friends of Lewes Society, The Chichester Society, The City of Winchester Trust, Wiggonholt Association, Lewes District Green Party, On behalf of Hopegar Properties Ltd)  Specific support for paragraph 5.59 noted (Hampshire & Sussex Wildlife Trusts).

376 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Object on grounds that policy wording should be amended to recognise that lighting assessments should be proportionate (Angmering Estate, Leconsfield Estate, West Dean- The Edward James Foundation).  Support the goal of the policy for developments not to cause unnecessary light pollution, but objection on grounds that many potential light sources are out of the control of the planning system and dark night skies is not a recognised planning consideration (Angmering Estate, Leconsfield Estate, West Dean – The Edward James Foundation).  Object on grounds the policy is too rigid in particular that criterion 3 is applied irrespective of compliance with the hierarchy set out in criterion 2 and proposals for sports pitch lighting would breach the maximum Lux level set out in column 4 of the Policy (Highfield and Brookham Schools).

Individuals

 General support for this policy (Councillor for Lewes District Council, Councillor for East Hampshire District Council, and 2 other individuals)  Comments that the policy must be complied with and not ignored when decisions are being made on development proposals which are both permanent and temporary e.g. music festivals (Individual)  Comment that the policy needs robust application at and across the border of the National Park to be effective (Individual)  Comment concern regarding enforcement (Individual)

377 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Chapter 5b Development - Introduction There were a total of 2 representations on this policy. A summary of the main issues raised is set out below.

National agencies No comments received.

Borough, City, County and District Councils No comments received.

Parish and Town Councils Support introduction. (Selborne PC)

Other organisations No comments received.

Individuals Welcome aspects of section, however it is potentially missing ambition to create more – i.e. all developments to aim for a net gain in biodiversity. (Lewes District Council, Cllr Joanna Carter – Green Party)

378 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD9: Biodiversity and Geodiversity There were a total of 41 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Environment Agency: support this policy and the specific reference to the need to have regard for ecological networks. Furthermore the need for development proposals to seek to both protect and enhance biodiversity is supported. Natural England: Overall comment – The landscape-scale approach to biodiversity in this section and the aim to reconnect habitat across the National Park is strongly supported. Introduction text –

 Concern regarding loss of some introductory text from the Preferred Options Local Plan which has resulted in some confusion and there are some areas which require clarification and alternations.  Concern regarding removal of table present in the Preferred Options Local Plan setting out the designated sites in the National Park Criteria 1 –

 Welcomes criteria 1 of the policy and the obligations outlined in parts a-d, including the requirement to secure long-term management of habitats  requests that criteria 1 is linked to the GI Framework where possible  requests reference is also made to the NPPF mitigation hierarchy here. Criteria 2 –

 advise the terms International Sites and National sites could be amended to Internationally protected sites and Nationally protected Sites  object to 2b on grounds that phrase ‘at this site’ is omitted  object to 2e on grounds different designations are not clearly differentiated, further clarification on terms used, that Protected Species are afforded national and international statutory protection and this is not clarified here, reference should be made to the Biospehere, brownfield land should be included and priority habitats and species should be differentiated from protected species.  support reference to BOAs in 2e. Supporting text –

 Priority and protected species require further clarification. Borough, City, County and District Councils

 Support with minor changes: request stronger reference to the South Downs Way Ahead Nature Improvement Area (NIA) and the Brighton and Lewes Downs Biosphere Reserve in the policy. New criteria to 1 is suggested (Brighton & Hove City Council).

379 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Comments that it is not realistic to expect all developments to achieve a net gain in biodiversity – the NPPF requires this only ‘where possible’ (Winchester City Council)  Comment that connectivity of woodland should be promoted and fragmentation resisted (Winchester City Council)

Parish and Town Councils

 General support for this policy (Buriton PC, Fernhurst PC, Lewes TC, Madehurst Parish Meeting, Rowlands Castle PC)  Request that local nature conservation designation areas in Upham Parish are explicitly mentioned in this policy (Upham PC)  Request for clear definition under what circumstances the needs and benefits of development clearly outweigh the loss of ancient woodland as set out in criteria 2d (Madehurst PC).  Clarification required between term ‘clearly outweigh’ in criteria 1d and ‘demonstrably outweigh’ in SD1 (Colemore & Priors Dean PC).  Comment to insert the word 'against' after the word 'mitigated' in criteria 2bii, 2cii and 2e (Selborne PC).  In paragraph 5.86 wording should be changed from “All wild birds are protected” to “Most wild birds are protected” (Selborne PC)  Does not address how high pollution in streams and rivers should be tackled (St John Without PC)  Rural road margins should be recognised as having potential biodiversity value (St John Without PC)  Presence of elm trees should be recognised and promoted for biodiversity (St John Without PC)

Other organisations

 General support for this policy (RSBP SE England, South Downs Society, On behalf of University College London, Hopegar Properties Ltd).  Support for the policy but request the policy looks more broadly at biodiversity and not just planning applications (Eastbourne Downland Group).  Specific support noted for criteria 2d (Forestry Commission, Lewes District Green Party).  Specific support noted for criteria 1c (British Canoeing)  Specific support noted for criteria 1b (RSPB SE England, The Watercress Way)  Request for additional criteria after 1d which references the Brighton Lewes Downs Biosphere Reserve and the South Downs Way Ahead Nature Improvement Area (Brighton & Lewes Downs Biosphere Partnership).  Request that criteria 2e follow biodiversity net gain principle (Lewes District Green Party).  Objection due to no reference to the Biodiversity 2020 strategy, Section 41 of the NERC Act 2006, priority habitats and priority species (Eco21st).  Objection to the policy on grounds it does not aim to minimise impacts on biodiversity in general or demonstrate that the mitigation hierarchy will apply, or reflect the need for up- to-date information and suggestion of wording changes to criteira 1 (Hampshire and Sussex Wildlife Trusts)

380 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Comment that the strong emphasis on protected sites and species is welcome but that these are not the exclusive means of conserving biodiversity – the overall surrounding landscape is important (The Watercress Way).  Objection to criteria 1 of the policy on grounds it is worded to apply to all development proposals regardless of impact and request that ‘where appropriate’ is inserted into the first line of the criteria 1 (NFU South East Region, South Downs Land Managers Group).  Add definition of Biodiversity Opportunity Areas to the glossary (South Downs Land Managers Group).  Commented that wording with regard to international, including European, wildlife designation will need updating in the event of UK exit from the EU (South Downs Society). Individuals

 General support for this policy  Care is needed on emphasis arising from the difference in wording for internationally protected sites which say ‘development proposals will be permitted…’ compared with local sites  Objection on grounds that criteria for European sites and para 5.75 should be firmer and wider to protect surrounding areas that contribute to their value  Object on grounds there should be a separate policy on biodiversity enhancement  Object on grounds that BAP sites and other local designations should be protected by the policy and identified on the Policies Map

381 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD10: International Sites There were a total of 18 representations on this policy. A summary of the main issues raised is set out below.

National agencies Natural England: Supportive of the policy and comment with the following proposed changes:

 Reference should be made to the emerging NE Bat Protocol, applicable to The Mens SAC, Ebernoe Common SAC and Singleton and Cocking Tunnels SAC.  Links to the GI Framework  Arun Valley SPA heading should also include its SAC and Ramsar designations.  NE will work with SDNPA and provide advice on this policy and seek to ensure that it remains up to date and reflects the current position. NE will provide formal positon following the January Wealden Heaths Phase II SPA officer working group meeting. Borough, City, County and District Councils

 Support for the increase from 7km to 7km in respect of The Mens SAC (Horsham District Council).  East Hampshire District Council welcomes opportunities for joint close monitoring of capacity in proximity of the Wealden Heaths Phase II SPA. It should be noted that this capacity is between EHDC and SDNPA. Therefore reference to Waverley Borough Council at Paragraph 5.95 should be removed (East Hampshire District Council)  Recommend that the sixth column for Strategic Policy SD10: International sites should be amended as follows ‘net new dwellings allocated or permitted within 400 metres of the Wealden Heaths Phase II SPA. other than allocations.  Noted that policy is similar to that approach taken by Waverley Borough Council. WBC will continue to work with SDNPA and EHDC on this cross boundary issues (Waverley Borough Council).

Parish and Town Councils

 Supportive of the policy (Madehurst Parish Council).

Other organisations

 Supports policy and comments that wording will need to be updated to ensure identical or equivalent protections post exist from the European Union (South Downs Society).  Objection to criteria 4 on grounds of concern that the approach set out is inconsistent with the approach taken for SPAs elsewhere in southern England. A consistent and strategic approach to mitigation is required (Hampshire and Sussex Wildlife Trusts).  Proposed revised wording: ‘may be permitted where ‘in combination’ effects of recreation on the Solent Coastal Special Protection Areas are satisfactorily mitigated avoided through the provision of an appropriate financial contribution to the delivery of strategic mitigation’ (Hampshire and Sussex Wildlife Trusts).

382 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Generally supportive of the policy but objection to criteria 4 on the grounds it lacks sufficient protections. Advise wording should say: All net new residential dwellings within 400m of the SPA should be avoided. A strategic approach to mitigating recreational disturbance from net new housing between 400m and 5km from the SPA should be put in place, comprising a twin track approach of SANGs and access management on the SPA (RSPB).  Objection on grounds that that the Arun Valley SAC has been omitted from consideration in SD10 (Coldwaltham Meadow Conservation Group)  Omission of Lewes Downs SAC from this policy (Lewes District Green Party)  Request that the apparently conflicting approach between Policy SD10 and supporting text to Policy SD20 is clarified with regard to development of Singleton and Cocking Tunnels SAC for recreation (National Trust).

Individuals

 Supportive of the policy  Objection on grounds policy should be expanded to cover all international designations as SD9 is insufficient.  Supporting text paragraphs 5.88 to 5.95 should be expanded to cover all international sites setting out the steps required for maintenance, conservation and enhancement.  Objection on grounds that that the Arun Valley SAC has been omitted from consideration in SD10.

Change

 Recommend that the sixth column for Strategic Policy SD10: International sites should be amended as follows ‘net new dwellings allocated or permitted within 400 metres of the Wealden Heaths Phase II SPA. other than allocations.

383 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD11: Trees, Woodland and Hedgerows There were a total of 23 representations on this policy. A summary of the main issues raised is set out below.

National agencies

Historic England: Welcomes Policy SD11, particularly the references to Ancient Woodland and veteran trees in clause 4, as part of the positive strategy for the conservation and enjoyment, and a clear strategy for enhancing, the historic environment as required by paragraphs 126 and 157 of the National Planning Policy Framework. Natural England: … Borough, City, County and District Councils

 In criteria 2, ‘protected trees’ should be replaced with ‘trees protected by a Tree Preservation Order or within a Conservation Area’ (East Hampshire District Council)  Further detail should be provided in the supporting text to clarify what SDNPA consider to be exceptional circumstances (East Hampshire District Council).  clarify how the 15m ‘buffer zone’ will be measured – from the edge of the canopy, the tree trunk, the woodland edge (Winchester District Council)  Hedges which are ‘important’ under the Hedgerow Regulations should be subject to criterion 3 (Winchester District Council)

Parish and Town Councils

 Policy is generally supported (Buriton PC, Fernhurst PC, Madehurst Parish Meeting, Ringmer PC, Rowlands Castle PC)  The buffer zone in criteria 4 should be increased to 20m (Bury PC)  Buffer zones should be increased (Madehurst Parish Meeting)  Spelling error noted by Selborne PC

Other organisations

 Policy is supported (South Downs Society)  The Trusts strongly support the inclusion of a policy to protect trees, woodland and hedgerows. This is consistent with the National Park’s purposes and NPPF paragraphs 109 and 117 (Hampshire and Sussex Wildlife Trusts).  The overall approach is welcomed and comments that the value of tree planting is in achieving enhanced networks and links (The Watercress Way Society)  Support for new planting schemes and TPOs are noted (Lewes District Green Party).  Proposals for buffer zones near woodland or veteran trees are welcomed (Lewes District Green Party)  Concern that the policy will result in significant additional survey fees (CLA)  Policy should recognise that clearance of scrub and woodland may in some cases be desirable (Eastbourne Downland Group)

384 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 The policy would be enhanced if it made an explicit aim for net gain rather than no net loss (Lewes District Green Party)  Buffer zone should be increased above the minimum of 15m (The Midhurst Society)  Comments on how a proposed site will comply with the policy (on behalf of Hopegar Properties Ltd)

Individuals

 Supportive of the policy  Comments that there is no reason to differentiate between protected and unprotected and the criteria should apply to all trees in the National Park as trees are a fundamental feature of the National Park in the Western Weald.  There should be a group TPO over the Western Weald.  Supports wording of ‘conserving and enhancing’

385 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Historic Environment Chapter - Introduction There were a total of 4 representations on this section. A summary of the main issues raised is set out below.

National Agencies No comments received. Borough, City, County and District Councils No comments received. Parish and Town Councils

 Designated Battlefield sites should be added to the Proposal Map and Settlement Maps, and not simply marked by a symbol (Cheriton PC)  Support reasoning in introduction to Policy SD12. Para. 5.105 should include reference to historic sunken lanes of East Hampshire and West Sussex (Selbourne PC). Other organisations

 This section should also highlight how ecosystem services derived from natural capital assets can enhance the historic built environment e.g. timber used in construction or enhance the vernacular of buildings (Forestry Commission)  There should be greater reference to the preservation of historic parks and gardens in this section (Forestry Comission) Individuals

 Refers to the local importance of New Lane in South Harting for its historic and wildlife value

386 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD12 Historic Environment There were a total of 29 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Historic England: welcome and largely support positive strategy for conservation, enhancement and enjoyment of historic environment. Local Plan should be more proactive in responding to assets at risk. Caution against inclusion of criteria on enabling development. Greater reference should be made to the ‘significance’ of heritage assets. Borough, City, County and District Councils

 Question the use of conserve rather than preserve, and rather than or. Heritage Statement should only be required where there is an impact on a heritage asset (East Hampshire DC & Winchester DC)  Reference should be made to statutory requirements of Planning (Listed Buildings and Conservation Areas) Act 1990. (East Hampshire DC) Parish and Town Councils

 Support for Policy SD12 (Multiple parish councils)  Lessons from King Edward V11 development should be incorporated into this policy (Midhurst TC).  Concern raised that Policy SD12 will prevent organic change of historic buildings to meet needs of today (Elsted & Treyford PC) Other organisations

 Support for Policy SD12 (Friends of Lewes Society, South Downs Society  Concern that Policy SD12 places additional burden over and above Historic England Guidance contained within Enabling Development and the Conservation of Significant Places (Brighton & Hove Council’s Downland Estate)  Proposed allocation SD64 is not coherent with SD12 – the flower-rich hay meadow should be recognised as a cultural heritage asset (Coldwatham Meadow Conservation Group)  Policy SD12 should require proposals to positively contribute to local character and distinctiveness and respond to the historic landscape character and settlement pattern (Easebourne PC)  Policy and supporting text should acknowledge damage to historic environment beyond development e.g. intensive farming (Eastbourne Downland Group)  Definition of viability is needed now rather than in due course (South Downs Land managers Group)  The policy should be strictly applied and enforced (Wiggonholt Association) Individuals

 Support for Policy SD12 (various)  Heritage assets should also include buildings on a local list  Planning obligations / conditions should be used to restore vernacular buildings retained within a development  Policy will prevent change and does not promote good design.

387 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Proposed site allocation at Loppers Ash, Harting will not fulfil the criteria of this policy and should be removed from the Plan.

388 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD13 Listed Buildings There were a total of 20 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Historic England – welcome & supports SD13 in principle, however word ‘unnecessary’ should be removed from first criteria in line with NPPF guidance. Borough, City, County and District Councils

 Question the use of terminology ‘preserve and enhance’ in this policy. (Winchester CC, East Hampshire DC)  Inclusion of Policy SD13 meets and responds to previous concerns raised at preferred options consultation (Chichester DC)

Parish and Town Councils

 Support for Policy SD13 (Buriton PC, Fernhurst PC, Madehurst Parish Meeting)  Addressing listed structures at risk will require strict enforcement (Fernhurst PC)  Experience of King Edward VII development should be avoided in future (Midhurst TC)  Concern raised that Policy SD13 will prevent organic change of historic buildings to meet needs of today (Elsted & Treyford PC)  Word ‘substantial’ should be removed from before ‘harm’ in criteria 2 (Selbourne PC) Other organisations

 Policy SD13 provides insufficient protection for Listed Buildings. The word ‘substantial’ (harm) should be deleted from the policy if the policy is to be retained (CPRE Hampshire)  Support for Policy SD13 (Friends of Lewes Society)  Policy SD13 is not in line with NPPF guidance which recognises some limited exceptional circumstances outweigh substantial harm or loss to a listed building or its setting (The National Trust, Prince’s Mead School Trust).  The tests to assess enabling development should be clearly set out (South Downs Society)  Policy SD13 should be strictly applied and enforced (Wiggonholt Association)  Replace wording ‘will only be permitted’ with ‘will be permitted’ to be consistent with the presumption in favour of sustainable development (Wiston Estate) Individuals

 Support for Policy SD13.

389 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD14: Climate Change Mitigation and Adaptation of Historic Buildings There were a total of 13 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Historic England – no objection although question whether the policy adds anything more to SD13 Borough, City, County and District Councils

 Question the use of terminology ‘preserve and enhance’ within this policy (Winchester City Council) Parish and Town Councils

 Welcome policy (Buriton PC, Fernhurst PC, Madehurst Parish Meeting, Selborne PC)  Concern raised that Policy SD14 will prevent organic change of historic buildings to meet needs of today (Elsted & Treyford PC)

Other organisations

 Support for Policy SD14 (Lewes District Green Party, South Downs Society) Individuals

 Fully support Policy SD14  Climate change mitigation should not be limited to historic buildings (Mr Victor Ient, Lewes District Councillor)’  Local Plans can set requirements higher than building regulations and the policy could be strengthened accordingly.

390 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD15: Conservation Areas There were a total of 16 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Historic England: would prefer the use of ‘conserve’ rather than ‘preserve’, not considered to be an issue of soundness. Borough, City, County and District Councils

 No comments received. Parish and Town Councils

 Welcome and support this policy (Buriton PC, Fernhurst PC, Madehurst Parish Meeting, Selborne PC)  SD15 criteria 1(a) is supported, however there is no up-to-date Appraisal or Management Plan for Easebourne (Easebourne PC).  Policy terminology should be to conserve and enhance in line with National Park purpose (Harting PC)  Does the SDNPA intend to prepare a Conservation Area Appraisal for Upham? (Upham PC)

Other organisations

 Welcome and support this policy (Fittleworth and District Association, Friends or Lewes Society)  A resourced programme of Conservation Area Appraisals and Management plans is urgently needed (South Downs Society)  Requirement to conserve and enhance the setting of a Conservation Area is not consistent with national policy. (Cowdray Estate)  Replace wording ‘will only be permitted’ with ‘will be permitted’ to be consistent with the presumption in favour of sustainable development (Wiston Estate) Individuals

 Support Policy SD15  Requirement to conserve and enhance the setting of a Conservation Area is not consistent with national policy.  Policy does not recognise that positively designed change can enhance a Conservation Area or its setting.  Policy terminology should be to conserve and enhance in line with National Park purpose

391 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD16: Archaeology There were a total of 14 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Historic England – welcome and support this policy. Borough, City, County and District Councils

 Policy covers key issues however final sentence should be revised to “In these cases, preservation by record secured through an agreed programme of archaeological work and Written Schemes of Archaeological Investigation will be required.” Some minor amendments to the supporting text is also required. (East Sussex County Council) Parish and Town Councils

 Welcome and support this policy (Fernhurst PC, Madehurst Parish Meeting, Rowlands Castle PC)  Word ‘unavoidable’ should be removed from before ‘harm’ in paragraph 3 (Selborne PC).  Reference should be made to the Areas of Archaeological Potential (defined in Hampshire CC Historic Rural Settlements 2004). (Twyford PC) Other organisations

 Consultation with Historic England should be mandatory for all applications affecting historic battlefields (Houndean Residents Association, Lewes)  Support for Policy SD16 (South Downs Society) Individuals

 Policy may not achieve National Park goals as only requires development to ‘do not harm’ rather than ‘conserve and enhance’.  Designated Battlefield sites should be added to the Proposals Map and Settlement Maps, with boundaries not simply marked by a symbol.

392 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

5d - Introduction to Water There were a total of 2 representations on this section. A summary of the main issues raised is set out below.

National Agencies No comments received. Borough, City, County and District Councils No comments received. Parish and Town Councils

 Para 5.143 should contain explicit reference to important water flows. Consider that the origins of some water lavants/bournes is not clear in the mapping. Map 5.5 should be amended to show the Idsworth & Chalton lavant through Finchdean, Rowlands Castle, Havant and Emsworth. (Rowlands Castle Parish Council) Other organisations

 No comments received Individuals

 Consider that the right balance has been struck with this section between the competing needs of supporting the population, communities and agriculture

393 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD17: Protection of the Water Environment There were a total of 35 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Environment Agency: Supports this policy and specifically the wording in the supporting text para 5.158 relating to foul drainage connections. Historic England: Welcomes and supports this policy. Natural England: In general, strongly support this policy. However, advise that as the region suffers from high water stress, which will be exacerbated by climate change, there is a need to work to reduce pressures on the freshwater environment. Water companies cover large areas and transfer water considerable distances, therefore a large scale strategic approach would be more effective in protecting water resources and managing demand rather than looking at developments on a case by case basis. Discharge, abstraction and dewatering from chalk rivers and winterbournes that are under pressure needs to be considered in relation to their potentially significant impacts on designated sites. Portsmouth Water: Welcome and support this policy. However, consider that agricultural reservoirs do not aid demand for water and are not resilient to drought. Recommend that paragraphs 5.154 and 5.157 are updated to include text recognising the presence of solution features (karst) in the chalk as potential preferential pathways for contaminates/pollutants to groundwater and underlying aquifers. Southern Water: Object to paragraph 5.159 if the intention of this is not to support water supply reservoirs in general. The objection is made on the grounds that that the Local Plan is not positively prepared as is does not reflect the need for new or improved water supply infrastructure; it is not effective as it does not support the delivery of necessary infrastructure; and is not consistent with national policy. Para17 of the NPPF and para 005 of the PPG are cited in support of their objection. Suggest a change to this paragraph to specifically state that it is agricultural reservoirs that are not supported within the National Park due to their impact on the landscape. Borough, City, County and District Councils

 Welcome and support this policy (Brighton and Hove City Council)  Amendments are requested to the text and policy to cover private water supplies which provide potable water to a large number of domestic and commercial users. These supplies can be considered to have Source Protections Zones around them (for small supplies this will be a generic 50m buffer zone). This information is held by local authorities and it is suggested that this policy contains an additional criteria stating that Local Authorities with be consulted about applications that are in the vicinity of Private Supply SPZ’s (Chichester District Council) Parish and Town Councils

 This policy is supported and welcomed. (Buriton, Fernhurst, Madehurst Parish Council, Rowlands Castle and Selbourne Parish Councils)  Request amendments to the policy to make is clear that the conservation objectives for designated water courses are overriding considerations. The significance of the river corridor for the conservation and enhancement of the environmental quality of the

394 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues watercourse, particularly a chalk stream should be mentioned in para 5.148 and the river corridor of major water courses should be identified on the policy map. Para 5.153 regarding development not being located within 8 metres of a water course is inconsistent with Allocation Policy SD 63: Land south of the A272 at Hinton Marsh, Cheriton. (Cheriton Parish Council)  Consider this policy sound. (Lewes Town Council)  Water companies must be consulted on planning applications, in addition to the Environment Agency. The Source Protection Zoning needs to be investigated more thoroughly in light of the issues surrounding the UKOG Markwells Wood oil drilling planning application. (Rowlands Castle Parish Council)  Object to both this policy and Policy SD49 relating to Flood Risk as they do not address existing flood risk situations such from the Hazeley Bourne in Twyford. (Twyford Parish Council)  Water abstraction should be reduced perhaps by using desalination plants and also pollution to watercourses (St John without Parish) Other organisations

 Consider there needs to be more of a balance between the environmental benefits and maintaining river conditions for the passage of canoes, as river developments such as re- wilding schemes can physically change the riverscape and hydromorphology. (British Canoeing)  Greater reference should be made to protecting the capacity of the landscape to absorb and store water in areas prone to flooding. The planting of riparian and floodplain woodland can help to reduce diffuse pollution, protect river morphology, moderate stream temperature and aid flood risk management as well as meeting Biodiversity Action Plan targets for the restoration and expansion of wet woodland. (Forestry Commission)  Support this policy and consider the catchment based management approach to be excellent. There are concerns regarding the lack of focus on protecting the quantity of water in aquifers, given the expected increased use of water caused by new development in the South East. (CPRE Hampshire)  Consider that the policy does not recognise the threat to water supply from agriculture, especially fertilisers and pesticides. The supporting text or policy should also include reference to the importance of dew ponds as a characteristic feature of the downland landscape. (Eastbourne Downland Group)  Amendments are requested so that it is made a requirement that any development must demonstrate the adequacy of existing infrastructure such as sewage treatment. Object to the minimum buffer size of 8 metres between developments and water corridors mentioned in para 5.153 as this is considered totally inadequate, especially with climate change. (The Midhurst Society)  Welcome and support criteria 4 relating to the construction of agricultural reservoirs, however consider that there may be uncertainty over how proposals demonstrate compatibility with National Park Purposes. Suggest a SPD is prepared to guide assessment and design such as that produced by Kent and Suffolk County Councils. (NFU South East Region)  Request that criteria 1 of the policy should include protection of private water supplies. Suggest that this could easily be remedied by the addition of ‘and private’ before water supply. (South Downs Land Managers Group)  Support this policy. (South Downs Society)

395 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Strongly support this policy. However, some wording changes are suggested to ensure that public access is not mandatory where it may harm the special qualities of the National Park; that river corridors are included in the features that should be protected from pollution risks; and the pollution impacts of private sewerage systems are prevented by ensuring that foul drainage connects to mains systems or where this is not possible via a drainage field rather than directly to watercourses. (Sussex/Hampshire Wildlife Trusts)  Wording should better reflect NPPF and National Park Management Plan and be amended to say “will be permitted where they conserve…..” to be consistent with the presumption in favour of sustainable development. (Wiston Estate) Individuals

 Support this policy and supporting text.  Amendments are requested so that the policy covers water quantity as well as quality and as such there should be a tougher stance on any water demanding proposals (e.g. water resource, heavy, agri/horticulture by not permitting new reservoirs etc.)  The policy should be amended to make is clear that the conservation objectives for designated water courses are overriding considerations. New developments can affect the hydrology of surrounding land and biodiversity.  Site allocation SD89 Land at Pulens Lane, Sheet does not comply with this policy as it will result in significant damage to the river that is part of a Site of Importance for Nature Conservation.  Question why the parish is not included in the Hampshire County Council Groundwater Management Plan.  Policy should include an additional criterion that ensures that development proposals have given careful consideration to potential effects on water and how the approach represents the most appropriate solution.

396 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD18: The Open Coast There were a total of 15 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Marine Management Organisation: Supports this policy, but considers that additional information relating to marine licensing, and the emerging South Inshore and Offshore Marine Plans, should be included within the supporting text. Southern Water: Welcomes the amendments that have been made to the policy in order to encompass the operational needs of activities in support of the Heritage Coast. However, considers the operational needs of utility infrastructure need to be made more explicit in this policy and therefore object to this policy on the grounds that; it is not positively prepared as it does not reflect a potential need for new or improved water supply infrastructure, it is not effective as it does not support delivery of necessary infrastructure, and it is not consistent with national policy. The NPPF para 17 and Para 005 of the PPG are cited in support of this objection. Recommend changes are made to include additional wording to criteria 1a) ii ‘which should also encompass the operational needs of statutory utility providers.’ Borough, City, County and District Councils

 Support this policy but suggest amendments to include reference to the Brighton and Lewes Downs Biosphere Reserve (also known as the Living Coast) given that the undeveloped coastline areas of the SDNP, outside the Heritage Coast, fall within the Biosphere Reserve designation. Some suggested wording is provided for criteria 1.b) to include reference to the objectives of the Brighton and Lewes Downs Biosphere Reserve. Also request that that the designated area of the Reserve is included on Map 5.6. (Brighton and Hove City Council) Parish and Town Councils

 Support this policy. (Fernhurst PC, Madehurst Parish Meeting) Other organisations

 Support this policy (British Canoeing, Hampshire CPRE, South Downs Society and Sussex and Hampshire Wildlife Trusts)  Consider that there is a significant omission from the Local Plan as there is no mention that the sea cliffs are suffering from rapid coastal erosion which will impact on coastal footpaths, housing, parking, visitor and recreational facilities and the important chalk grassland SSSI’s. The policy should do more to guard against the loss of dwellings and recreational facilities. The National Trust’s recent report ’Shifting Shores’ is cited as giving valuable guidance on managing costal retreat. (Eastbourne Downland Group, The Gilbert Estate)  Request amendments to the policy and supporting text as concerned that with current rates of erosion it is very likely, within the lifetime of this Local Plan, that the National Trust tourist facilities and the offices at Birling Gap will be unsafe to occupy. Consider that the Local Plan fails to recognise the importance of tourism to this area in the supporting text or implicitly in the policy. Advise that a clear link is established between Policy SD23: Sustainable Tourism and this policy to ensure that the second purpose of Heritage Coasts which is to “encourage and help the public to enjoy, understand and appreciate these areas” is properly recognised. This will aid the re-provision of facilities and facilitate the necessary space for the Trust to provide its countryside management services. Suggest the supporting

397 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues text is amended to recognise the second purpose of Heritage Coasts and that there is a link provided to Policy SD23 on Sustainable Tourism to ensure this purpose is achieved. (National Trust)

Individuals

 Support this policy.  Support this policy and consider it is needed to allow for the necessary management of the coast, including coastal erosion and flooding. The best approach at present to achieve appropriate management is through future modifications of the South Marine Plan.

398 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Chapter 6 Introduction and Section 6A Introduction There were a total of 1 representation on the Chapter 6 Introduction and 2 representations on the Section 6A Introduction. A summary of the main issues raised is set out below.

National agencies No comments received Borough, City, County and District Councils No comments received Parish and Town Councils

 Section 6a Introduction: Failure to identify transport infrastructure requirements makes the plan legally non-compliant (conflicts with PPG on ‘What should a Local Plan contain). (Kingston PC)  Section 6a Introduction: Should identify infrastructure requirements in relation to the existing road network and traffic, management of speed and volumes, and the need for enhancements to the road network to complement the development strategy (Kingston PC)  Section 6a Introduction: Should identify infrastructure requirements in relation to parking, including the need and location for additional car parking, and possible parking restrictions. (Kingston PC)  Section 6a Introduction: Should identify infrastructure requirements in relation to access to the National Park, including identifying where existing access is inadequate and proposing schemes for improving it. (Kingston PC) Other organisations No comments received Individuals

 Chapter 6 Introduction: Support the section’s emphasis on sustainable access, not just transport, sustainable tourism and cross boundary issues.  Chapter 6 Introduction: Should add more references to accessibility, which could be significantly enhanced  Chapter 6 Introduction: Support stress on sustainable transport; should be complimentary with highway authority policies.  Chapter 6 Introduction: Should use the phrase ‘people and wildlife’ in appropriate locations, as per its use in paragraph 5.23.  Section 6a Introduction: The chapter is inadequate and does not begin to deal with the planning and environmental issues that arise from traffic within and increasingly across the National Park now and in the foreseeable future. Traffic already has a wide adverse impact on the Park’s special features and this can only worsen as a result of development around its boundaries. The evidence base is paltry and the policies largely generic and unrelated to an analysis of the current and future effects of traffic.

399 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD19: Transport and Accessibility There were a total of 46 representations on this policy. A summary of the main issues raised is set out below.

National agencies No comments received

Borough, City, County and District Councils No comments received

Parish and Town Councils

 Support (Buriton, Fernhurst PCs, Madehurst Parish Meeting)  Policy is weak and generic, not National Park specific. (Cheriton PC)  Policy duplicates aims of NPPF (Twyford PC)  No strategic approach to traffic on the strategic or minor road network. NPA needs to consider traffic impact of new development both in the National Park and beyond its boundary, and mitigate these impacts through the policy, including through considering the introduction of traffic restrictions. (Cheriton PC, Rodmell PC, Stedham PC, Twyford PC)  Support emphasis on sustainable transport, cycle use and restrictions on heavy goods vehicles (Petersfield TC)  Support elimination of transport through local offices and fast internet. Should also mention driverless cars. (Stedham PC)  Inadequate consideration of ways to facilitate access to the National Park (Rodmell PC)  Inadequate consideration of the existing road network and traffic, and how to regulate it. Particular concern over C7 Newhaven-Lewes- should not be used as a strategic link road- LP should include propoasls to manage traffic flows, in accordance with RITSD. (Rodmell PC)  SD21: Policy should summarise the policies of ‘Roads in the South Downs’, to give them increased status. (Cheriton PC)  SD21: Para 6.31: Should review traffic flows on all routes through the park, and lower the threshold of 10%. (Cheriton PC)  Need to consider impact on narrow lanes of delivery vehicles, which, being larger, can cause more damage to verges etc. than motor cars. (Cheriton PC, Petersfield TC)  Transport assessments should be carried out by the Highways Authority, not the developer, but at the developer’s expense. (Fernhurst PC)  Point out importance of transport to sustainable tourism (Liss PC)  Need to strike balance between improving communications (especially East/Wes) and conserving the landscape. (Liss PC)  SD21: Policies should protect sunken and rural green lanes used as walking routes. Would support policy banning motor vehicles on BOATS. (Liss PC)  SD21: Policies should achieve quiet road surfaces (Liss PC)  SD21: Policies should reduce signage clutter (Liss PC)

400 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Policies should prevent main highways becoming development boundaries. (Liss PC)  SD22: May need policy to provide for electric car charging points. (Liss PC)  Would support ongoing sensitive management of A29 (Madehurst PM)  Consider routes for HGV use (Petersfield TC)  Must assess impact of more significant developments (Rowlands Castle PC)  Request Rowlands Castle station be considered as a vital gateway to the Park, though outside the boundary (Rowlands Castle PC)  Para 6.1: amend to ‘duty in pursuit of its purposes’ (Selborne PC)  Para 6.9: Committed development in the area should include development outside the NP, and development with planning applications pending consideration. All TAs, TSs and TPxs should assess cumulative impact, regardless of development size.. (Rowlands Castle PC)  Para 6.9: Delete reference to TA and TS- need for these is determined before the application is considered. (Twyford PC)  Delete reference to transferring freight form road to water- unrealistic (Twyford PC)  Para 6.13:M Reference is inadequate,- should list all strategic roads, which should include B3335/B3354, as meriting special protection from the effects of development, to avoid rat- running away from them onto smaller roads. (Twyford PC)  Consider replacing national speed limit with 50mph on all roads other than strategic roads  SD20: Should be more encouragement for improvement of on-road cycling facilities (i.e. cycle tracks) (Twyford PC)  SD21: 6.28: Footnote should state ‘freely available for inspection on the National Library of Scotland website http://maps.nls.uk/os/ (Twyford PC)  SD21: 6.29: Requirement to protect hedgerows and banks may conflict with requirement to provide a safe access. (Twyford PC)  SD21: 6.30: Raise threshold from one net additional dwelling/100m2 of floorspace, to 12-15 two-way vehicle movements in the peak hour (half the threshold for a Transport Statement) (Twyford PC)  SD22: Criteria 2, 4: references re. EV charging facilities (cannot say ‘where feasible’ and ‘must’) (Twyford PC)  SD22: Criterion 3: add sub criteria requiring the provision of secure cycle facilities and, where feasible, EV charging facilities. (Twyford PC)  SD22. Criterion 5: Add new clause requiring proposals for new, relocated or extended public parking outside settlements to be appropriate to its location. (Twyford PC)

Other organisations

 General support (Angmering Estate, Friends of Lewes Society, South Downs Society)  Support focus on walking, cycling and public transport (Lewes District Green Party)  Support criterion 4(c) (The Chichester Society)  Policy should include potential Arundel bypass (Angmering Estate)  Traffic from additional development, redevelopment or extensions of LP allocations and developments in the setting of the NP should also be minimised. (DMH Stallard LLP, client not stated)  Traffic from additional development, redevelopment or extensions within the Mackley Industrial Estate, Henfield, should also be minimised. (Hopegar Properties)  Criterion 1 should include the phrase ‘where appropriate’ to cover applications where there is no scope to minimise travel requirements. (NFU South East Region, South Downs Land Mangers Group)

401 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Criterion 2: Add text as follows: ..significant number of journeys (compared to traffic associated with the existing legal/permitted use of a site)… (Springs Smoked Salmon)  The policy is reactive, there is no transport strategy. LP should bring together include any transport proposals e.g. from county councils on the Policies Map. Concern over proposed new bridge at Exceat increasing traffic, and also the future of the cliff-top road at Belle Tout (will it be replaced?) Proposals for A27 widening at Polegate should be shown where they fall within the NP. Request that planning inspector flags this issue for early review of the Plan. (Eastbourne Downland Group)  Need more emphasis on utility cycling- the quality and quantity of routes for them in towns and large villages needs to be improved. (Petersfield Cyclists)  Criterion 2: Add the following text: public transport routes, main roads and provide good access for pedestrians and cyclists from the new development to nearby amenities and services including public transport links. Movement along the footpaths and cycle ways must be a safe and attractive experience for users.  Criterion 3: add the following: Development will not be permitted where it would adversely affect the amenity of users of footpaths, or cycle ways and where no equally attractive, safe and convenient satisfactory remedial measures, such as re-routing , can be undertaken. (Petersfield Cyclists)  Criterion 4: add the following: Support will be given to proposals that improve and extend the existing network of cycle routes and footpaths for utility journeys and for commuter journeys, thus enabling better access to local amenities,to local employment, to rail/bus stations, to green spaces, to new housing where appropriate to the open countryside for recreation. (Petersfield Cyclists)  Criterion 4(d): should refer to wherever cycle journeys are likely end, e.g. shops and banks. (The Midhurst Society)  Add the following paragraph to the policy: Paragraph 6: Economic contributions may be required for transport enhancements to improve the safety and convenience of non-car modes of travel including (but not necessarily limited to) footpaths, bridleways, cycleways, car-sharing facilities, public transport provision and infrastructure, charging points for electric vehicles and bicycle parking and travel planning. (Petersfield Cyclists)  Approach will be challenged by Syngenta and Shoreham Cement Works (South Downs Society)  Glossary: Add terms; ‘Recreational journeys, ‘Utility journeys’, ‘Sustainable modes of transport’. (Petersfield Cyclists)  Criterion 1: Policy will restrict additional vehicle movements to existing visitor attractions in the countryside. Propose inserting text as follows: Development proposals at existing facilities and services (including visitor attractions) which currently generate significant vehicle movements will be required to demonstrate how any increase can be satisfactorily accommodated, alongside opportunities for encouraging more sustainable transport modes for accessing the site. (National Trust)

Individuals

 Support (various individuals)  Policy is weak and generic, not National Park specific. No attempt to quantify current traffic flows or forecast the future.  Criterion 1: Strengthen by changing to ‘minimise the need for travel and promote the use of…’.  Criterion 1: qualify in terms set out at NPPF Para 34.  Criterion 2: remove ‘where relevant’ from before ‘the cycle network’ to give cycling equal status to the other modes.

402 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Support elimination of transport through local offices and fast internet. Should also mention driverless cars.  Support seeking of opportunities to reduce negative impacts of traffic  No strategic approach to traffic on the strategic or minor road network. NPA needs to consider traffic impact of new development both in the National Park and beyond its boundary, and mitigate these impacts through the policy, including through considering the introduction of traffic restrictions. In particular: the C7 Lewes-Newhaven (signage to encourage traffic onto the A26 instead); traffic through Owslebury arising from Eastleigh LP proposals;; routes through Alfriston and Telscombe. (Various individuals inc. Lewes District Council, Cllr Vic Ient)  Market housing in villages will not minimise the need to travel, since its occupants are likely to be commuters rather than working in the community where they live, and are likely to need two cars per household.  Should include review of potential additional public transport routes/stops, to link to PROWs. (Hampshire County Council, Cllr Jackie Porter)  Syngenta and Shoreham Cement Works may need special treatment, from the point of view of transport. (Lewes District Council, Cllr Vic Ient)  Strongly encourage use of the rail and bus networks for passenger and commercial traffic, especially rail freight at Newhaven port and rail and bus travel for students at Newhaven UTC. (Lewes District Council, Cllr Vic Ient)  Policies should state that major roads, roads in towns, many (not just historic) rural roads, the footpath and bridleway network are important to the National Park and need protection/sensitive planning and maintenance.  Policies should state presumption that any new major roads do not damage the parks landscape and special character.  Strategic roads should not be treated the same as any other infrastructure, as they are uniquely intrusive with widespread environmental impacts.

403 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD20: Walking, Cycling and Equestrian Routes There were a total of 52 representations on this policy. A summary of the main issues raised is set out below.

National agencies Natural England: Very concerned over potential impacts on Chichester to Midhurst route on biodiversity: Regarding Singleton and Cocking Tunnels SAC: Support the omission of the tunnels from the safeguarded route, but remain concerned over increased recreational access to the vicinity of the tunnel, which will expose the SAC to a significant risk of disturbance and damage. Project level HRA would capture this but need to also clarify this in the policy, adopting a precautionary approach. Regarding West Dean Tunnels: The tunnels contain a significant number of hibernating bats including Annex I species. Advise that alternative route be secured.

Borough, City, County and District Councils

 Support safeguarding of Devils’ Dyke Route (Brighton & Hove City Council)  Welcome reference to restoration of Lewes-Uckfield line; consistent with BHCC City Plan. (Brighton & Hove City Council)  Para 6.21: should state that non-motorised transport routes created prior to restoration must not prejudice future restoration. (Brighton & Hove City Council)  Para 6.25: where public path amendments relate to planning issues then the SDNPA as the planning authority is responsible for making PPDOs- not the Highway Authority (East Sussex County Council).  General support (Winchester City Council)

Parish and Town Councils

 General support (Buriton PC, Fernhurst PC, Iford PM, Madehurst Parish Meeting)  Concern over resurfacing of PROWs- avoid hard surfaces for the sake of horses, off road cyclists, and the protection of forest floors. (Bury PC)  Cycle paths on roadways are particularly dangerous, should be avoided (Fernhurst PC).  Para 6.16: Revise wording of last sentence, which is hard to understand. (Selborne PC)  Para 6.22: Welcome guidance on crossing points. Seeking to improve safety of crossing C7. (Iford Parish Meeting)  Support reopening of Lewes-Uckfield railway (Lewes TC)  Further amendments needed to protect rural green lanes and quiet roads used as walking routes. Would support ban on vehicles on BOATs (Liss PC)  Strongly support safeguarding of potential cycle/walking route from Petersfield to Petworth (Petersfield TC)  Does not adequately address the facilitation of access to the NP by footpaths, rods, traffic management, parking and public transport (Rodmell PC)  Dislike the formulation ‘development proposal that facilitate such use will be permitted.’ This should not be automatically the case: prefer ‘welcomed’. (Rowlands Castle PC)  SDNPA needs to produce a local cycling and walking infrastructure plan as specified by DfT. (Stedham with Iping PC)

404 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Should be more encouragement for improved on-road cycling facilities (Twyford PC)  Welcome protection of Meon Valley Trail. Should recognise vulnerability of crime around it and allocate sufficient budget to minimising crime. (West Meon PC)

Other organisations

 General support (British Horse Society)  Should require improvements to bridleways and footpaths if there is evidence of historic use (CPRE Sussex)  Need to set active travel in a broader context, and address the connectivity of the right of way network and CROW Access Land. (Eastbourne Downland Group)  Support safeguarding of disused railway lines for non-motorised use (Fittleworth and District Association)  Concerned that plan’s effectiveness will be compromised by NPA’s lack of funds and powers (Fittleworth and District Association)  Add new routes to Criterion 2: Most of the former railway line from Lewes to Hamsey (Friends of Lewes Society)  Criterion 2: Policy should be more proactive, SDNPA needs to take the lead in creating an action plan and timetable; there should be targets and triggers for the delivery of the network. (The Midhurst Society)  Criterion 2: Welcome this section. Label the New Alresford to Kings Worthy route ‘Watercress Way’ (ultimately intended to run to Sutton Scotney). This route would be of immense value- off road travel along this part of the Itchen Valley, especially for cyclists and horseriders, is currently poor. (Watercress Way, two representors)  Criterion 4: Policy should be more proactive; there should be targets and triggers for the delivery of crossing points. (The Midhurst Society)  Support policy regarding former Lewes-Uckfield railway line (Lewes District Green Party)  Policy is sound but SDNPA should reconsider the decision not to safeguard the Cocking and Singleton Tunnels for restoration. Cycleways share railway tunnels with bats elsewhere, e.g. Combe Down and Devonshire Tunnels, near Bath. (Sustrans, Midhurst Area Cycling)  When new NMTR are being developed, should engage with adjacent councils to ensure they are continued outside the SDNP (Sustrans)  Policy should include a statement in favour of restoring former railway lines where they have been previously developed, including use of compulsory purchase where necessary (Sustrans)  Welcome safeguarding of Lewes-Uckfield railway line. Note that it may be necessary to deviate slightly from the original route. (Railfuture)  Welcome proposed cycle route between Petersfield and Midhurst, road access currently unsafe for cyclists. Further improved access west and south of Petersfield would also be beneficial.  Para 6.24: The example given in the third sentence currently gives the impression of cyclists and horse riders on a footpath. (South Downs Land Managers Group)  Para 6.24: Final sentence: change to may will be required to provide a mitigation contribution. Such contributions should be ring fenced for dealing with the problems arising from additional pressure on rights of way across farmland (South Downs Land Managers Group)  Design of new non-motorised routes and connections should take into account the needs of land management, especially livestock grazing. (South Downs Land Managers Group)

405 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Policy is entirely reactive, not positively prepared. Should encourage improvement of the bridleway network and upgrading footpaths to bridleways where there is evidence of historic use. Should specifically encourage provision for wheelchair/all terrain scooter access. (South Downs Society)  Criterion 6(b): insert wording as follows: amenity value, biodiversity value and tranquillity (Sussex/Hampshire Wildlife Trust)  Development and associated traffic increases on local roads are already harming and fragmenting the network of safe routes. (British Horse Society)  Propose replacing the phrase ‘Will be permitted provided’ with ‘’Will be permitted where’ (Glynde Estate)

Individuals

 General support (Hampshire County Council, Cllr Jackie Porter)  Object to the policy since part of the Petersfield-Chichester railway route runs through their garden- risk to domestic food production and biodiversity.  Need to take opportunities to install facilities for cyclists on roads e.g. good junction design cycle parking close to main entrances, etc.  The Watercress Way is a charity seeking to open more sections of the old railway line from Alresford to Kings Worthy, with further links to the north. WCC and HCC are supportive of this project. (Hampshire County Council, Cllr Jackie Porter)  Should reword for more positive encouragement of bridleway networks. (Lewes DC, Cllr Vic Ient)  Off road route development should provide for users of mobility scooters(Lewes DC, Cllr Vic Ient)  New footpaths must adopt straight lines rather than following field headlands, especially where they connect communities. New footpaths should not follow more than one boundary of a residential property, nor be directly against hedges, but should leave a 4m buffer for wildlife. New footpaths should be inaccessible to motorised transport. (Various individuals)  New non motorised transport routes should not lead to the diversion of or substitute existing footpaths. (Various individuals)  Should refer to creation of new routes/improvement of existing routes (Lewes DC, Cllr Vic Ient)  Should give clearer support to the restoration of the Lewes-Uckfield line to railway use. (Lewes DC, Cllr Vic Ient)  Policy imprecise and repetitive. Should actively promote the creation of new bridle paths.  Should commit to a local cycling and walking plan, as pecific b DfT Technical Guidance for Local Authorities, April 2017.  Criterion 1: New development may not always be able to contribute to a network of non- motorised routes. Add ‘where possible’.  Policy needs to emphasis that the PROW network is a key part of the Park’s character and economy, but is fragile and needs protection and good maintenance.  Busy roads, including B roads, form barriers to the Downs for horse riders. Gates and parking areas are often unsuitable for horse riders. Frustrations over coordination between route managers and information provision.

406 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD21: Public Realm, Highway Design and Public Art There were a total of 26 representations on this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Welcome and support the reference to historic rural roads in the policy, and also paragraphs 6.28 and 6.29, as part of a positive strategy for the historic environment, as per paras 126 and 157 of the NPPF.

Borough, City, County and District Councils No comments received

Parish and Town Councils

 General support (Buriton, Fernhurst, Rowlands Castle PCs, Iford, Madehurst PMs)  Support protection of historic rural roads (Madehurst PM)  ‘Context-sensitive street design and management’ is vital in retaining the purposes and character of the NP (Buriton PC)  Extend policy to include financial support for community highway management projects. (Iford PM)  Need for policies to protect sunken and rural green lanes and quiet roads used as walking routes; to achieve quiet road surfaces; to reduce signage clutter. (Liss PC)  Widening of the A29 contradicts policy on historic rural roads (Madehurst PM)  Criterion 2: list of factors should include tranquillity. (Colemore and Priors Dean PM)  Criterion 2: Add ‘historic rural roads including sunken lanes’ (Selborne PC)  Paras 6.28, 6.29: Expand to include sunken lanes (ref East Hants Local Plan policy HE19). There are more than 60 miles of such lanes containing microclimates with enormous and internationally important ecological variety. (Selborne PC)  Support paragraphs 6.28-6.32, in particular monitoring of the cumulative effect of development on traffic. (Iford PM)  Para 6.29: List of characteristics in third paragraph should include tranquillity. (Colemore and Priors Dean PM)  Para 6.31: Strongly support 10% threshold as potential grounds for refusal. (Colemore and Priors Dean PM)  Para 6.31: Strongly support principle of assessing cumulative impact. Question how this would be applied to future proposals. (Colemore and Priors Dean PM)  Paragraph 6.31, third sentence: change to ‘conserve and or enhance’ (Harting PC)  Support new public art (Lewes TC)  SDNPA should support putting much used paths/historic highways on the Definitive Map. Rural roadside margins should be recognised for their biodiversity value. (St John Without PM)  6.28: Footnote should state ‘freely available for inspection on the National Library of Scotland website http://maps.nls.uk/os/ (Twyford PC)

407 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 6.29: Requirement to protect hedgerows and banks may conflict with requirement to provide a safe access. (Twyford PC)  6.30: Raise threshold from one net additional dwelling/100m2 of floorspace, to 12-15 two- way vehicle movements in the peak hour (half the threshold for a Transport Statement) (Twyford PC)

Other organisations

 Welcome inclusion of policy on historic rural roads. Need to interpret the term widely, and explain in Glossary. Policy needs to be robustly worded enough to pick up implications of small and large developments. Similar considerations should apply to historic lanes in towns. (South Downs Society)  Welcome support for public art and also the proviso about appropriate locations- not all locations appropriate for all types of art. (South Downs Society)

Individuals

 General support  Particular support for historic rural roads policy, including sunken lanes. (Various individuals)  Current issue of damage to historic rural road fabric by traffic from existing development e.g. internet delivery vehicles and 4x4s is not addressed by the policy: could introduce restrictions on vehicles over a certain size on minor roads.  Criterion 2: Add the text ‘or where it would adversely affect the character, setting or historical, ecological and archaeological value of ancient tracks and lanes.’ There are 60-70 miles of such sunken lanes in East Hampshire and parts of West Sussex that go back to pre-Roman times, often housing rare plants or insects. Ref. East Hants Local Plan policy HE19.  Criterion 3: Add the text ‘The design and layout of new development must be compliant in design with Highway adoption standards and must give priority…’ Need to ensure the public realm is truly in public ownership, not apparent ownership. (Hampshire County Council Cllr Jackie Porter)  Need further definition of ‘historic rural roads’ to avoid subjective interpretation by developers. (Lewes DC, Cllr Victor Ient)  Historic lanes/alleys/twittens within towns also need protection. (Lewes DC, Cllr Victor Ient)  Concerned over development at the entrance to ancient byways in villages. (Lewes DC, Cllr Victor Ient)  Need more attention to B and C roads with policies to keep traffic increases on them to a minimum, and specify what sort of traffic is suitable for these roads, while directing traffic from new developments onto A roads instead. (Lewes DC, Cllr Victor Ient)  Need policies addressing safety for non motorised users. Where developments increase traffic on the Park’s roads, the NPA should insist on adequate traffic calming and speed limit restrictions. Off-road routes are an inadequate substitute for dealing with traffic on the minor road network. Propose re-categorising some rural routes as ‘green routes’ with priority for non-motorised users. (Lewes DC, Cllr Victor Ient)  Any new vehicle movements associated with agricultural building conversions should be routed away from public rights of way, for example on existing farm tracks; this routing should be secured through S106 agreement. .

408 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Should be bolder, including shared space and other contemporary, people-centric ideas.  Should summarise ‘Roads of the South Downs’ in the policy, to give it statutory status as the only relevant Park-wide document on the topic.  6.31: Threshold of 10% is unacceptably high, especially in a National Park setting; should require Transport Statements to detail all expected traffic flows on all routes.

409 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD22: Parking Provision There were a total of 21 representations on this policy. A summary of the main issues raised is set out below.

National agencies

 No comments received Borough, City, County and District Councils

 No comments received Parish and Town Councils

 General support (Fernhurst and Slindon PCs)  Very disappointed by removal of the commitment to produce park wide parking standards. Current HCC standards are inadequate, geared to urban areas. Unreasonable to expect NDPs to produce new standards. (Liss PC)  All new development in rural areas should provide sufficient parking to prevent overspill. Village roads are increasingly clogged by parking. (Elsted and Treyford PC)  Should consider demands for parking by visitors to the National Park which lead to parking in adjacent areas, for example Rowlands Castle. (Rowlands Castle PC)  Paragraph 6.47: Third sentence: expand to read ‘duty in pursuit of that purpose'. (Selborne PC)  Remove the sentence ‘Whever feasible, electic vehicle charging facilities must also be provided. Cannot say ‘Wherever feasible’ and ‘must’. Add new sub criteria to criterion 3: ‘(c) provide secure cycle facilities’ and ‘(d) where feasible, electric vehicle charging facilities should be provided’. Remove reference to EV charging from criterion 4. Add allowance for new, relocated or extended public parking outside defined settlements. (Twyford PC) Other organisations

 Commitment to electric charging facilities should be stronger, to comply with NP Vision and Circular (CPRE Sussex)  Criterion 3: Should include provision of appropriate tree cover (Friends of Lewes Society)  Welcome requirement for electric charging facilities at new car parks, should also support installation of such points at existing car parks. (Lewes District Green Party)  Consider the provision of seasonal parking to overcome the disruption caused to farming operations near visitor ‘hot spots’ (South Downs Land Managers Group)  Criterion 1: add a criterion that ‘the car park site can be linked to other parts of the settlement by attractive walking routes, to allow easy onward journeys on foot’ (South Downs Society)  Suggest former Holmbush Caravan Park site as a location for a supermarket over a ground floor car park. (The Midhurst Society)  Criterion 1 and paragraph 6.43: Welcome amended wording following Regulation 18 consultation (The National Trust) Individuals

410 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Remove words ‘wherever feasible’. Electric charging points should be mandatory other than in exceptional circumstances. (Lewes District Council. Cllr Victor Ient)  Should encourage provision of bicycle charging points. (Lewes District Council. Cllr Victor Ient)  Parking provision should be linked to the off road pathway network. (Lewes District Council. Cllr Victor Ient)  Parking provision should include provision of recycling facilities, which the provider of the parking facility should be required to empty and maintain. (Lewes District Council. Cllr Victor Ient)  Criterion 1: Should begin with the need for parking, not simply state ‘will be permitted’ Access should take priority.  Premature to require EV charging points in all new dwellings, in particular for affordable housing. Electric cars are expensive, technology may change.  If new / extended / re-located parking is permitted, there should be compensatory closing of some of the numerous ad hoc parking areas which currently harm the landscape.

411 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Introduction 6b Understanding and Enjoyment of the National Park - Introduction There were a total of 1 representations on this section. A summary of the main issues raised is set out below.

National agencies

 No comments received

Borough, City, County and District Councils

 No comments received

Parish and Town Councils

 This section should address and manage the impacts of commercial shooting and hunting (Kingston PC)

Other organisations

 No comments received

Individuals

 No comments received

412 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD23: Sustainable Tourism There were a total of 43 representations on this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Supports criteria c), d) and g) of this policy Natural England: Policy also needs to explicitly protect against impacts on biodiversity from tourism activity

Borough, City, County and District Councils

 The marketing requirements should be in line with other business uses with a minimum marketing requirement of 18 months (Chichester DC)  SD23 should include criteria / limitaions on the size of visitor attractions / accommodation. The policy should also refer to impacts on visual amenity and tranquillity (Winchester DC)

Parish and Town Councils

 Support for policy SD23 (Fernhurst PC, Madehurst Parish Meeting, Rowlands Castle PC)  Local Plan should contain a policy on major events (Cheriton PC)  Local Plan should contain a policy addressing the impacts of commercial shooting and hunting (Rodmell PC)  Policy needs to ensure tourist accommodation meets the needs of visitors to the National Park (Bury PC)  Policy should address the growth in ‘shepherd hut’ accommodation in the National Park (Bury PC)  Reuse of farm buildings for tourist activity should be carefully monitored and supported by sound business case (Bury PC)  Clarify that references to ‘special qualities’ means ‘the special qualities of the National Park (Selborne PC)  Para 6.56 should be reworded to better reflect the National Park purposes  Policy needs greater guidance on and distinction between visitor accommodation and visitor attractions/facilities. Separate policy on visitor accommodation should allow for development in settlements/ through conversion or linked to well established attractions (Twyford PC)

Other organisations

 Tourist accommodation outside the National Park can also contribute to the SDNP objectives (Madehurst Parish Council)  Support for the policy (Alice Holt Communty Forum, Friends of Lewes Society, Leconfield Estate, Lewes District Green Party, South Downs Society, The National Trust, Wiston Estate, Glynde Estate)

413 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Local Plan should contain a policy on major events (Upper Itchen Valley Society)  Clarity sough on how proposals should demonstrate an increase in awareness, understanding and enjoyment of the special qualities (Angermering Estate, Brighton & Hove Council’s Downland Estate, West Dean – The Edward James Foundatation, Leconfield Estate)  Criteria (b) is too restrictive – some tourism-related activities require a remote location and cannot make use of sustainable transport modes (Angermering Estate, Brighton & Hove Council’s Downland Estate, West Dean – The Edward James Foundatation, Leconfield Estate)  Marketing campaign requirements are too onerous and should be more flexible (Angermering Estate, Brighton & Hove Council’s Downland Estate, West Dean – The Edward James Foundatation, Leconfield Estate)  Policy should allow greater flexibility for different types of tourist accommodation to meet market demand (Angermering Estate, Brighton & Hove Council’s Downland Estate, West Dean – The Edward James Foundatation, Leconfield Estate)  Para 6.56 should be reworded to better reflect the National Park purposes (CPRE Hampshire)  Clarify that references to ‘special qualities’ means ‘the special qualities of the National Park (CPRE Hampshire)  References to active travel should be set in broader context than just relating planning applications (Eastbourne Downland Group)  Policy is overly restrictive on development outside settlement boundaries (farm diversification or WEP related only). Allowance should be made for ‘buildings only’ tourism development (NFU South East Region)  SD23 should be reworded to require applicants to demonstrate a net benefit to the local econmy (South Downs Society)  SD23 should also reference replacing facilities lost through cliff erosion (The Gilbert Estate)  A specific policy on Birling Gap and the unique challenges faced at this location should be included in the Local Plan (The Gilbert Estate)  The wording of Policy SD23 should be more to take into account the significant contribution that development such as Bohunt Park can make to sustainable tourism (Green Village Investments).

Individuals

 Local Plan should contain a policy on major events (multiple individuals)  Local Plan should contain a policy that addresses the impacts of commercial shoots (Lewes District Councillor Victor Ient)  Policy needed to address the impacts of commercial sports venues including golf courses and sports pitches  Reference to the role and importance of visitor gateways (such as Liphook) should be reinstated in the Local Plan  Large-scale events which require security fencing should be refused  Criteria 1(b) is too restrictive and unrealistic – tourist related activities (e.g. public house) often exist in remote rural locations  Criteria 2 should require either a viability assessment or evidence of a robust marketing campaign – not both  Criteria 1(b) should be removed – repeats Policy SD19

414 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 SD23 should ensure tourism development benefits the local community and economy (Lewes District Councillor Victor Ient)  SD23 should also address the need for cooperation between statutory bodies in prmoting and managing tourism in and around the National Park e.g. the NPA should be working with ‘gateway towns’ outside the National Park  Recognition should be made to a limit on carrying capacity of certain locations within the National Park for any additional tourism visits  Provision should be made for free horsebox parking where free car parking is provided

415 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD24: Equestrian Uses There were a total of 12 representations on this policy. A summary of the main issues raised is set out below.

National agencies

 No comments received Borough, City, County and District Councils

 No comments received

Parish and Town Councils

 Support for the policy (Fernhurst PC, Liss PC  Add detail on the use of agricultural land for equestrian use (Bury PC)  Strengthen policy by discouraging cumulative equestrian uses / field fragmentation (Liss PC)  Allowance should be made for the sympatheic subdivision of fields and use of appropriate fencing materials (Rowlands PC)  Para. 6.68 final sentence should be clarified (Selbourne PC) Other organisations

 Support for the policy (CLA, South Downs Society)  Criteria 1(a) should refer to the ‘special qualities’ of the national park (also paragraphs 6.53 and 6.58) (CPRE Hampshire)  Additional paragraph should be included on the requirements for planning consent for the keeping of horses for recreation (CPRE Hampshire)

Individuals

 Restrict the expansion of existing equestrian uses onto agricultural hinterland / open countryside (multiple individuals  NPA should produce good practice guide on keeping horses in the countryside  Enforcement of this policy will be key  Policy should address impacts on footpaths and recreational enjoyment of the National Park

416 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Chapter 7 Introduction There were a total of 5 representations on this section. A summary of the main issues raised is set out below.

National agencies No comments received.

Borough, City, County and District Councils No comments received.

Parish and Town Councils

 Support quality, vision and breadth contained in the Pre-submission Plan especially Section 7, Housing. (Lavant PC)  Support affordable housing policies. (Petersfield TC)

Other organisations

 Presumption against major infrastructure development is inappropriate, if proposal seeks to address long-standing issues that are detrimental to residents and users of the National Park. (The Midhurst Society)

Individuals

 7.1 states that the approach to sustainable development is primarily based on the SDNPA Duty, however this is inconsistent woth the NPPF definition of sustainable development. The environmental role has not been considered.  The phrase ‘people and wildlife’ used in Chapter 5 should equally be used in Chapter 7. Figure 1.1 is inappropriately abbreviated to exclude the caveat that the Duty is in pursuit of the purposes.

417 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Chapter 7a Development - Introduction There were a total of 6 representations on this subsection. A summary of the main issues raised is set out below.

National Agencies No comments received. Borough, City, County and District Councils

 Concern over potential shortfall of at least 380 dwellings in East Hants in respect of commitment given in Memorandum of Understanding and in paragraph 7.20 of the Pre- submission Plan. Question whether SDNPA has considered all opportunities for meeting the need in E Hants, e.g. additional dwellings within Petersfield, Liss and in/around Liphook. Unclear as to strategy for meeting overall housing requirements, therefore Plan is unsound. (East Hampshire District Council) Parish and Town Councils

 Subsection does not reflect S.62 of the 1995 Act / NPPF paragraph 7 insofar as it does not adequately consider environmental objectives. (Selborne PC, Cheriton PC) Other organisations

 Housing development at Lower Hoddern Farm, Peacehaven should be allocated for, as the promoted site does not deliver many of the National Park’s special qualities, is a highly sustainable location, is appropriate to support gateway function of Newhaven, and would assist cross-boundary housing delivery in line with NPPF paragraphs 178 & 179. (EPV (East Sussex) Ltd.) Individuals

 7.3 incorrectly refers to the Spatial Strategy as justification for medium growth – but no justification given. 7.4 does not explain how or why the 53 settlements [listed in Policy SD25] have been chosen.

418 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD25 Development Strategy There were a total of 146 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Highways England state they have no concerns at this time regarding the potential impacts of planned development as contained within the Authorities emerging Local Plan. This assumes that the maximum housing and the employment provision contained therein and otherwise modelled is not exceeded. Portsmouth Water states that SD25 settlements Singleton, West Meon and Funtington have been identified to be within or in close proximity to the Company’s Groundwater Source Protection Zones for public water supplies. They wish to be consulted on proposals within or in close proximity to these zones. Borough, City, County and District Councils

 SD25 pt 2 should be amended to refer to a ‘genuine and proven need for a countryside location’ and reference appropriate uses e.g. agriculture, forestry. (East Hampshire District Council)  Support core approach of dispersed medium level of growth that supports affordability, sustainability and vitality of settlements, and minimises need for car journeys on rural roads. Conclude that the level of development proposed, with appropriate mitigation, can be adequately accommodated without severe impact on the transport network. (Hampshire County Council) Parish and Town Councils

 Support the strategy. (various PCs/TCs)  Support 7.12 landscape-led approach. (Selborne PC)  Support all proposed changes to Buriton settlement boundary (Buriton PC)  Support SD25 and tightening of the settlement boundary as shown in the Policies Map. (Corhampton & Meonstoke PC)  Support Liss being treated as a single village, and recognition that settlement boundaries may be defined in neighbourhood plans. Welcome strategy of medium growth dispersal across the National Park. (Liss PC)  7.3 implies that evidence for a plan to adopt a medium level of dispersed growth is in Chapter 3 but this is absent and instead in Sustainability Appraisal. Spatial strategy not consistent with housing number for Cheriton which is higher. (Cheriton PC)  Approach in SD25 does not properly reflect opportunities provided by neighbourhood plans. In Easebourne there is limited previously developed land available, the need should be met through a range of site allocations or windfall, in tandem with Whole Estate Plan. Easebourne has unique and important heritage setting and this has not been adequately assessed. Distinction between ‘strategic allocation’ and ‘strategic site’ is unclear. Policy should include wording to prevent coalescence of settlements. Settlement boundary is unjustified. Allocations should be excluded from boundary until they are built out, parts of boundary do not comply with methodology. No evidence of Duty to Cooperate. (Easebourne PC)  On the basis of the Sustainability Appraisal, many of the site allocations arising from SD25 are not justified, particularly in landscape terms. Propose more flexible approach to allow

419 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues alternative sites to be allocated for small-scale development in settlements without a boundary, particularly on brownfield sites. (Harting PC)  No land available for housing development in Kilmeston. (Kilmeston PC)  7.10 is too inflexible, should recognise that larger towns may have to expand. (Midhurst TC)  Consultation on changes to settlement boundaries has been inadequate. (Stedham with Iping PC)  Support changes to settlement boundary whilst noting that they are in some places both extensive and restrictive. (Steep PC)  Allowing building of new smaller dwelling for retired agricultural workers would help free up existing larger dwellings, and help numerous farms and estates. (Steyning PC)  SD25 pt 2d allowing re-use of previously developed land is contrary to objectives of SD1, SD6, SD7, SD8 and SD19 and in conflict with statutory purposes, regarding keeping landscapes free of development, and may lead to haphazard and unplanned development. Policy should be limited to sites closely associated with other buildings and settlements. (Twyford PC)  East Worldham should be given a settlement boundary on the basis of consistency between EHDC and SDNPA Local Plans, to support Worldham Village Design Statement, and in line with NPPF objectives to promote and secure sustainable development to maintain the vitality and viability of existing communities. This reflects that Worldham is sustainably located only 2 miles from Alton. (Worldham PC) Other organisations

 General support for principles of SD25. (various organisations)  Support inclusion of Greatham in SD25. (Cove Homes)  SD25 would result in the development of new housing in unsustainable locations (various organisations)  The policy and supporting text should be amended to include ancillary school facilities, such as staff accommodation, within the definition of exceptional development (SD25 pt 2). (Bedales School)  SD25 pt 2 should be expanded to include a similar policy to Winchester District Local Plan Part 1 Policy MTRA5 which supports retention and development of major commercial and educational establishments that occupy rural locations. (Prince’s Mead School Trust)  SD25 omits any mention of infrastructure e.g. should require that current infrastructure can cope with new development. (The Midhurst Society)  SD25 should give more explicit indication of exceptional development in the countryside (e.g. SD25 2b – essential need for a countryside location), as worded there is too much uncertainty. (Madehurst Parish Meeting)  Sites are being unnecessarily excluded due to falling within a designated Neighbourhood Plan Area. SD25 is too restrictive and places too much reliance on neighbourhood plans coming forward which could delay housing delivery, hence more sites should be allocated in the local plan, and a fallback position included to trigger a site allocations DPD if a neighbourhood plan becomes excessively delayed. Wording to allow flexibility for sites to come forward in the National Park adjacent to settlements outside but abutting the National Park should be reintroduced, and some of these sites allocated, e.g. the site ‘Land at Sweetland’ at Steyning. (CALA Group Ltd)  Object to scale of development proposed for Coldwaltham which is disproportionate compared with other rural villages in East and West Sussex, would urbanise the village, and is unnecessary given lack of local housing need. (Coldwaltham Meadow Conservation Group)

420 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Object to omission of Swanmore from the Settlement Service Availability Assessment and SD25 as land at Dodd’s Lane, Swanmore is sustainably located to help meet affordable housing needs. (Consentium Limited)  Welcome tightly drawn boundary around East Dean. Whole Estate Plans should have wider scope than just planning. (Eastbourne Downland Group)  Support reinstatement of East Dean settlement boundary but do not believe this will yield the number of dwellings needed. (The Gilbert Estate)  Growth on the edge of Peacehaven would help address unmet housing need in Lewes district (including in the National Park), and could be delivered in a way which contributes to the English National Parks Vision and Circular, the Special Qualities, General Policy 50 of the South Downs Management Plan and complies with NPPF paragraph 116. The Lower Hoddern Farm site is a highly sustainable location adjacent to the existing built-up area. (EPV (East Sussex) Ltd)  Various comments on structure of policy which needs improving for clarity. Approach in SD25 does not properly reflect opportunities provided by neighbourhood plans. SD25 should include a settlement hierarchy. Distinction between ‘strategic allocation’ and ‘strategic site’ is unclear. Methodology for determining settlement boundary for Greatham is unclear, allocations should be excluded from boundary until they are built out, parts of boundary do not comply with methodology. SD25 does not indicate how development will be best and most suitably delivered. Significant shortcomings in scoring within Settlement Facilities Assessment with respect to Greatham. Decision to include Greatham in SD25 is unjustified, and at odds with the Inspector’s Report on the East Hants District Local Plan: Second Review (2006) which identifies that significant residential development should not be encouraged. SD25 is not consistent with NPPF as it fails to direct development to the most appropriate locations and instead applies a broad-brush approach. (Greatham Voice)  Stroud settlement boundary should be amended to include the Seven Stars public house. It is not sensible to show a boundary that reflects development on three sides of this site. Settlement boundaries should include built form and closely associated infill land. Public houses should be included in the Settlement Facilities Assessment as a community facility. (Hall & Woodhouse Ltd)  Development proposed in many smaller villages has not been assessed for landscape impact, and are likely to cause harm. Sites adjacent to Midhurst (land south of Barlavington Way, land fronting Holmbush Way) should be included within the Midhurst settlement boundary as sustainable locations for new housing. (ICS Estates Ltd)  Sheet settlement boundary should not exclude part of the allocated site SD89 (Land at Pulens Lane) which as stands has no apparent connection with the settlement boundary methodology given it cuts through the site rather than extend to the natural boundary of the River Rother. (Landowners of the site covered by proposed Policy SD89 at Pulens Lane, Sheet)  Insufficient consideration given to advice in NPPF paragraph 55 to look at the role larger settlements play in supporting smaller communities, e.g. Petworth and adjoining villages of Tillington and Byworth. Splitting of settlements into ‘broad areas’ does not help with understanding why settlements do or do not have boundaries. Recommended alternative is to balance landscape capacity with services and facilities, and relationship of a settlement with other places. (Leaconfield Estate)  West Meon settlement boundary should be amended to include the Storeys Meadow site, as it is surrounded by development to the north, west, south and east by development that reads as part of the village. (Naboth’s Garden Ltd)

421 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 The Settlement Facilities Assessment 2015 and Settlement Hierarchy Study 2013 are both flawed. Some settlements have been under-scored and facilities such as sports fields, community halls, places to eat and employment should have been assessed. e.g. Selborne, where existence of a pre-school has been omitted. The apportionment of housing to settlements is also inconsistent with the scores given. Approach to settlement boundaries unreasonably limits reasonable infill development and will impact on the level of windfall development. (Newton Valence Farm)  Cooksbridge should be included in the list of settlements in SD25, as there is a suitable site available for development in a location that is close to a primary school and a railway station. The settlement should be reassessed in the Settlement Facilities assessment and the SA. (Rydon Homes Ltd.)  West Dean and Singleton taken together are broadly the same size, and with similar facilities, as settlements listed in SD25, and also benefits from the presence of West Dean College. A West Dean settlement boundary would represent a more consistent approach. (West Dean – The Edward James Foundation)  Bohunt Park is a site in a highly sustainable location within Liphook, the Settlement Facilities Assessment should be reviewed to include it. The site has potential to significantly contribute to meeting housing needs along with other economic, recreational and social opportunities. This would be more sustainable than identifying sites in villages with low sustainability scores. (Green Village Investments)  SD25 pt 2d does not accurately reflect NPPF paragraph 55(3), given redundant agricultural buildings are not defined as previously developed land, thereby there is concern that the conversion of these buildings to residential is prohibited. SD25 also does not reflect NPPF para 55 in respect to the optimum viable use being appropriate for heritage assets, and exceptional quality / innovative development being material. Smaller farms should be given opportunity to submit an estate or farm plan in light of NPPF para 28 which relates to all types of rural enterprise. (NFU South East Region)  Provision for adoption of Whole Estate Plans is particularly welcomed. (Sompting Estate)  Policy on enhancing rural communities and protecting open countryside are strongly supported. SD25 pt 3 should refer to Whole Estate Plans for schools, colleges and other institutions. (CPRE Hampshire)  Welcome encouragement of Whole Estate Plans but would like SD25 pt 2 to be more specific in respect of ‘essential need for a countryside location to reflect NPPF paragraph 25. (CPRE Sussex)  The requirement of a Whole Farm Plan should be commensurate with the scale and impact of the development proposed. Delete word ‘large’. (South Downs Land Managers Group)  Support in principle for Whole Estate Plans, but concerned that SD25 expects formal endorsement by the National Park Authority. SD25 should also allow for partnership- produced (but not endorsed) WEPs to carry material weight. (The National Trust)  Support approach to allow small settlements to accommodate new housing to meet the needs of local people and businesses. Whole Estate Plans should be flexible. (Elizabeth Lawrence Ltd)  The requirement for an estate plan should be amended to reflect that an estate plan will not always be required, e.g. where development opportunities are small in scale. (Angmering Estate)  SD25 does not include all villages in the National Park – only 53 of them. Reliance on NDPs to ‘fill the gap’ is well meaning but is not positive planning. (Glynde Estates) Individuals

422 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Support principles of the development strategy. (Lewes District Council, Cllr Joanna Carter)  Support for settlements listed (and/or omitted) in SD25.  The spatial strategy is not landscape-led as it is based on existence of facilities and services. Should be more flexibility to allow for small scale development outside settlement boundaries, only if little or no negative landscape, wildlife or cultural heritage impact.  Inappropriate to redraw settlement boundaries specifically to include site allocations, as this is a self-justifying procedure.  Support expansion of Droxford settlement boundary to include Land at Park Lane and the adjacent school.  Buriton benefits from a nursery, primary school, library, post office and other facilities & services which have not been considered within the Settlement Facilities Assessment. (various individuals)  The settlement boundary for Selborne accurately reflects the views of the community as reflected in the VDS, VCP and Parish Council view.  Insufficient consideration given to advice in NPPF paragraph 55 to look at the role larger settlements play in supporting smaller communities, and focusing development opportunities / drawing settlement boundaries to reflect this. Examples of Abbots Worthy (close to Kings Worthy) and Exton (close to Corhampton & Meonstoke) are given. (2 individuals)  Local residents in Steyning do not want housing and other infrastructure projects built on greenfield sites and in the National Park around Steyning, including Bayards Fields which some note is shown in the Wiston Whole Estate Plan. Some consider that school and health centre in Steyning are at capacity. Some consider that it would set precedent for further development in the countryside. (various individuals)  Object to Itchen Abbas settlement boundary as the village is clearly larger than the boundary shown. (Hampshire County Council, Cllr Jackie Porter)  Chawton settlement boundary is overly tight and restrictive. The boundary should not be arbitrary lines on a plan, but follow defensible physical natural boundaries.  Certain properties have been excluded from the Clapham settlement boundary in error.  It is not clear what is meant by a ‘Whole Estate Plan’ that has been endorsed by the National Park, i.e. what is the process for endorsement?  Object to Lodsworth settlement boundary which does not take into account existing recent development.  Object to Poynings settlement boundary as it unreasonably excludes land north of Cora’s Walk, Poynings.  Object to creation of a settlement boundary for Owslebury, as shown it cuts through properties, and has caused local concern and division amongst villagers. The village should be treated as open countryside.  Object to Owslebury settlement boundary as it is haphazard and unreasonably excludes land at Holly Hatch.  Object to the approach taken to revising the settlement boundary for Kingston near Lewes, which on the one hand extends the boundary to incorporate allocation site SD77 (Land at Castelmer Farm) whilst on the other hand contracting the boundary to exclude a more suitable alternative (Land at Audiburn Farm). The Authority should have sought sites within the existing settlement boundary ahead of extending the boundary outwards.  Removal of settlement boundary for Blackmoor is unjustified, given proximity of services in Whitehill-Bordon, therefore does not comply with the procedural requirements in Policy SD25.  The scores given in the Settlement Facilities Assessment are incorrect / give misleading results. (various individuals)

423 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 The conservation and enhancement of small hamlets at the foot of the South Downs is essential.  Supporting text (7.11) should include definition of brownfield to only include previously developed by permanent structures. Description of ‘overdevelopment’ (7.14) should be clarified.  The process for developing Whole Estate Plans must be more transparent and open to the public. Not all brownfield sites are appropriate for development. (Lewes District Council, Cllr Victor Ient)  Wording on Whole Estate Plans should be stronger, to call for community wide consultation on WEPs. (2 individuals)  Policy SD25 should include proviso that expansion of any settlement must be contained within an existing defensible boundary, and the landscape and townscape character features maintained and enhanced.  Request strong policy driver to repair and restore incremental degradation of the urban fringe.  Approach to settlement boundaries unreasonably limits reasonable infill development and will impact on the level of windfall development, vitality of village – not positively prepared (examples of land east of Cotehele, Upper Farringdon; land north of Cora’s Walk, Poynings; and Selborne are given). (various individuals)  Further development at Cheriton/Hinton Marsh is contrary to NPPF paragraph 7 as more development around the headwaters of the River Itchen would impact upon the River Itchen SAC and upon BAP irreplaceable habitats.  Object to any further development in South Harting.  Greatham has limited access by public transport and limited facilities, and may not therefore be appropriate for development on the scale proposed.  Slindon settlement boundary is welcomed but is drawn too tight thereby making it unlikely that smaller dwellings could be added.  Object to scale of development proposed for Coldwaltham which is disproportionate compared with other rural villages in East and West Sussex, would urbanise the village, and is unnecessary given lack of local housing need.

424 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Section 7b Introduction – Homes (Strategic) There were a total of 4 representations on this policy. A summary of the main issues raised is set out below.

National agencies No comments received.

Borough, City, County and District Councils

 Request clarification whether the affordable housing requirement is part of the overall objectively assessed need figure, or additional to it. Inconsistent numbers on affordable housing need comparing 7.19 (i.e. 293) to 7.52 (i.e. 294).

Parish and Town Councils

 The Local Plan housing strategies should recognize the economic circumstances prevailing in different settlements and propose innovative methods for ensuring that developments are configured in a manner which assists affordability. Options could include splitting some “houses” into flats. (Kingston-near-Lewes PC)

Other organisations

 The approach to housing has not robustly tested Housing Market Areas, or come up with a figure for objectively assessed need across the National Park and how the deficit will be dealt with. Pre-submission Plan should be withdrawn and resubmitted with a full explanation of how the deficit will be addressed. (Buriton Estates)

Individuals

 Commend wording ‘sustainable development within the limits of the environment and to ensure Purposes 1 and 2 are not compromised’ which should be applied across all housing sections.

425 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD26: Supply of Homes There were a total of 99 representations on this policy. A summary of the main issues raised is set out below.

National agencies Portsmouth Water: Two settlements named in the policy, Corhampton and Droxford, are within Groundwater Protection Zones. These are areas which are sensitive given our abstraction of water. Further allocations are proposed for Lavant which are both within Source Protection Zone 2 and near to Source Protection Zone 1. Portsmouth Water should be consulted on any development proposed within these zones due to the sensitivity of the groundwater catchments.

Borough, City, County and District Councils

 Discrepancies in housing figures, and minor wording issues, are highlighted. (various local authorities)  Worthing has a shortfall in housing supply against assessed need of around 6,500 dwellings, and for Adur it is around 3,100. Engagement across the sub-region to address this is ongoing. It is accepted that the South Downs National Park is unlikely to be in a position to meet its own need let alone accommodate any of the shortfall arising from neighbouring areas. (Adur & Worthing Councils)  Shortfall of 197 homes per annum within the National Park is noted. Highlight need for robust evidence of work done to meet housing need within the National Park and elsewhere in housing market areas, and pressure on neighbouring authorities to accommodate extra housing. (Waverley Borough Council)  Support Duty to Cooperate statement that housing provision in the National Park part of Winchester is over and above provision already made for whole of district in the Winchester Local Plan Part 1. (Winchester City Council)

Parish and Town Councils

 Support policy (various PCs)  Reference to Cheriton/Hinton Marsh should be deleted as site proposed for allocated is not suited for development. (Cheriton PC)  50 dwellings for Easebourne is unjustified, based on flawed evidence and inappropriate for the village and represents a 150% increase in the number put forward in the Preferred Options Local Plan. Suggestions that neighbourhood plans cannot plan for a lower number than in strategic local plan policies, or that their ability to determine where allocations are located should be limited, should be removed. The King Edward VII development in Easebourne parish (402 net dwelllings) should be a material consideration in determining the number for Easebourne. (Easebourne PC)  Information in Figure 7.3 is incorrect/unclear. (various PCs)  Object to allocation of only 9 houses in Itchen Abbas, which is the only one of four villages in the parish to have a settlement boundary. More houses are needed to sustain village life and meet identified affordable housing need. (Itchen Abbas PC)

426 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Not convinced that delivery of 4,750 net additional homes is the maximum that can be accommodated without detriment to the purposes of the SDNP. Settlements that should be included in SD26 include Glynde/Beddingham, Firle and Falmer. (Ringmer PC)  No reference as to whether new houses will be permitted outside settlements. Needs clarifying. (Upham PC)

Other organisations

 Support policy (various organisations)  Housing provision of 250 homes per annum is inadequate compared with an objectively assessed need of 447, and will result in an excessive undersupply. Some organisations considered this would compromise the objective of addressing socio-economic and community needs. Some respondents commented that this could have a supressing impacts on economic growth. Further respondents stated that the capacity led ‘bottom up’ approach (as opposed to starting with OAN and working downwards) is inappropriate / conflicts directly with the courts’ interpretation of NPPF paragraph 47. A further respondent cited the 2017 Budget announcement that 300,000 dwellings per year are planned nationwide, therefore more opportunities should be taken to address the shortage. (various organisations)  The housing provision figure for the National Park should be stated as a minimum as an approximate figure does not support positive and effective planning. The Plan should test the potential of Petersfield to deliver more than the 805 dwellings set out in the Neighbourhood Plan. (Home Builders Federation)  Support Medium Growth (+60%) option tested in the Sustainability Appraisal which would deliver an additional 1,007 dwellings to meet local housing needs. (Alfred Homes)  Housing provision figure should be termed as ‘at least’ not ‘approximately’ to reflect socio- economic benefits of more housing. Some respondents have related this to a particular settlement(s). (several organisations)  Displacing housing need to areas outside the National Park will increase car travel and reduce tranquillity. (Angmering Estate)  Objections to omission of various settlements from Policy SD26, or insufficient homes allocated to settlements that are included, to address general and affordable housing needs. Reasons behind these objections include sustainability of locations/settlements, limited impact on landscape, importance of enhancing vitality in relevant rural communities, and suitable sites that have been missed/incorrectly assessed in the SHLAA. One respondent felt there was an inconsistent approach regarding settlement sizes/importance e.g. comparing Petworth (150) with Liss (150) Fernhurst (220). Another respondent stated that a settlement could be apportioned more housing as only broad locations need be identified for development for the later part of the Plan period. (various organisations)  Site allocations should additionally be made in neighbourhood plan areas, to take account of stage of production or local support. (CALA Group Ltd.)  Essential that policy takes account of National Park purposes and the constraints this entails. There should be no requirement to make up shortfalls relating to these settlements in inappropriate locations elsewhere in the National Park. (Campaign for National Parks)  It is not clear whether a year-on-year delivery of 250 homes per year, or a stepped trajectory based on anticipated completion rates, is intended. This should be clarified. (CPRE Sussex)

427 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Object to basis of the HEDNA which has recycled dated previous work related to other local authorities’ local plans. Failure to maximise opportunities to increase housing on sites with permission. There is no agreed proposal for how the deficit between OAN and housing requirement will be managed and dealt with. (Deansmore Properties Limited, Newton Valance Farm)  Policy should include sustainable settlements which are outside the National Park. (DMH Stallard LLP  Planning permissions granted since 1 April 2015 in Pyecombe mean that the 8 dwellings allocated has been exceeded before the Plan is adopted. (Britecroft Ltd)  The Plan should have a separate policy dealing with neighbourhood plans. Figure 7.3 is not up-to-date and is unclear in relation to permissions post-April 2015. Housing provision of 38 dwellings is not evidenced, therefore the number should be 30 as in the Preferred Options consultation. Increase in the number does not suggest a capacity-led approach. Object to reliance on one site with no contingency. (Greatham Voice)  There should be more consideration of cross-border locations on the edge of the National Park given OAN is not being met e.g. at Liphook. Policy is too reliant on development of strategic sites and other allocations which have overly optimistic assumptions applied, given the nature of the National Park. Discounts should be applied to site allocation supply figure. The windfall allowance is too high. The Plan should undertake a systematic review of sustainable locations for development that relate to otherwise sustainable settlements. (Green Village Investments)  There is a residual requirement to identify more housing sites for 207 homes that will need to be identified through subsequent non-strategic allocations. No sites are currently allocated on the boundary of Peacehaven/Newhaven or in the south east of the SDNPA area – an allocation here could also improve the existing harsh edge of development. (EPV (East Sussex) Ltd.)  Number of homes apportioned to Lewes (875) seems at the high end of the scale. (Lewes District Green Party)  Should either Old Malling Farm or North Street Quarter sites fail to go forward, there is limited scope within the current Lewes Neighbourhood Plan to absorb such numbers and green fields may be put at risk. (Houndean Residents Association)  Statement “To seek to meet the full, objectively assessed needs for the area would conflict with the statutory purposes and duty” is disputed as this is not positive planning. SHLAA should have tested all sites including those under 5 dwellings. One suggestion that a site allocations DPD is prepared for a particular settlements to allocate sites of less than 5 dwellings. (various organisations)  Winchester OAN is not being met as the figure used for the Winchester JCS predates both the NPPF and the designation of the National Park. (Naboth’s Garden Ltd.)  Paragraph 2 of the policy should include further criterion to refer to the realisation of opportunities provided by Whole Estate Plans. (Newton Valance Farm)  Shoreham Cement Works should be added to the settlements listed in the policy, with an estimate of 2,000 dwellings. (South Downs Project)  Proposal to allocate no further sites in Petersfield additional to the Neighbourhood Plan is flawed given the Neighbourhood Plan end-date of 2028 and SDLP end date of 2033. Housing provision of 31 dwellings in Sheet should be deleted in favour of less constrained sites in Petersfield. (Pulens Lane Residents Action Group)  Allocation of 10 houses to Steep seems to reflect a SHLAA-led approach not a landscape-led approach. SHLAA does not recognise open space/village green designation in the East

428 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues Hampshire Local Plan. Sustainability appraisal ‘medium level of growth dispersed’ does not include Steep. (Save Our Village Green)  Concern over impact on infrastructure (particularly traffic congestion) of apportioning 175 dwellings to Midhurst. (The Midhurst Society)  Would welcome positive wording in the policy to recognise benefits of student housing. (The Edward James Foundation – West Dean)  Given numbers planned for in Lewes, Petersfield and Fernhurst, it is unclear if the demand for school places has been properly planned for. This needs to be rectified if the plan is to be ‘positively prepared’. (Education & Schools Funding Council)

Individuals

 Support policy, or specific settlement housing numbers. (various individuals)  No mention of Bramshott and Liphook. Yet there is a sustainable site within walking distance of schools, services and the station and offering potential for new infrastructure requirements. (East Hampshire DC, Cllr Angela Glass)  Seek agreement to additional housing on exception sites within the Itchen Valley parish, subject to community agreement. (Hampshire County Council, Cllr Jackie Porter)  Not consistent with national policy: there should be no ceiling on housing delivery and housing numbers should be expressed as a minimum to reflect positive planning / to significantly boost housing supply.  No evidence to support open market house-building in South Harting.  Liss lacks strong architectural heritage and has benefit of a railway station and good road access, compared with this historic towns of Petersfield and Petworth.  The Authority is not permitted to set housing target for South Harting nor other areas, but must exercise their powers to protect the landscape unfettered.  Facilities offered by settlements have changed since the SA was prepared, therefore allocations should change to reflect newer evidence.  Housing for Petersfield should increase to reflect that the neighbourhood plan only extends to 2028 whereas the SDLP period is until 2033. Land South of the Causeway should be included as a strategic site.  It should be made clear that the National Park is not bound by any specific housing targets.  No requirement for the amount of extra housing being proposed in Greatham. One concern was inappropriateness of scale and density of development.  Reference to Cheriton/Hinton Marsh should be deleted from policy as the SA and HRA that support the strategy are flawed.  Object to allocation of houses in Sheet.  Object to further housing in Easebourne.  Concerns over lack of 1- and 2-bedroom houses in Kingston-near-Lewes for downsizers.  Rural aspects of the National Park should be given separate consideration given wide coverage of general policies.

429 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD27 Mix of homes There were a total of 36 representations on this policy. A summary of the main issues raised is set out below.

National agencies No comments received.

Borough, City, County and District Councils

 Clarification urged for part 3 of the policy (provision for older persons accommodation) on sites over 5 units). Footnote (*) should limit substitution to ‘some’ 1 bedroom dwellings and be ‘subject to evidence needed’. Details on how mix will be required on smaller sites should be provided. Should state that 2 bedroom units should be provided as 50:50 mix of flats and houses. (Chichester District Council)  Object to footnote (*) which allows 1 bedroom affordable housing to be substituted with 2 bed units. Current Government policy which limits eligibility for larger units etc. means that need for smaller units is very high. Policy should refer to dwelling sizes and accessibility by adopting Nationally Described Space Standards and requiring Part M4 Category 2 [accessible dwellings] particularly for affordable units. Older person schemes need a critical mass of development to be viable and sites close to large settlements should be provided to achieve this. In paragraph 7.37 ‘homes’ should be substituted for ‘houses’ as priority need and take- up is by families with children. (Winchester City Council)

Parish and Town Councils

 Support policy. (Liss PC, Selborne PC, Tichborne PC)  Policy is welcome as there is a lack of smaller properties in the parish. (Buriton PC)  Policy welcomed as a pragmatic approach. (Corhampton & Meonstoke PC)  Mix of housing is too prescriptive and will need regular reassessment. (Fernhurst PC)  Support as makes homes more attainable (affordable) to maintain local family connections. However a pragmatic approach will in reality be required. (Hawkley PC)  Supporting text should mention self-build which offers opportunities to local families, in line with Government policy. (Midhurst TC)  Principle commended, but policy is too prescriptive. Localism Act requires that a neighbourhood plan takes precedence over the local plan with respect to housing types – policy should be reworded to reflect this. (Ringmer PC)  Agree with policy, except to limit the size (i.e. floorspace) of houses and omitting any 4 bedroom dwellings. Policy should allow for local circumstances and refer to neighbourhood plans. (Twyford PC)

Other organisations

 Support policy as it reflects the HEDNA and SHMA. (various organisations)  It is not for the development plan to specify the mix of open market homes. Policy as drafted would artificially constrain the supply of open market housing which overall will raise

430 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues cost of home ownership (constrain on upsizing referred to by some). At least 80% of all homes as 2 or 3 bedroom homes is a significant percentage to attain. May lead to out-of- context developments, homogenisation, undue impact on local infrastructure. More flexibility should be written into the policy. One respondent referred to evidence specific to Petersfield suggesting an alternative mix as appropriate. (various organisations)  Policy should require the mix of market housing to be approximate or flexibly applied (one respondent noted specifically an issue with small sites). One respondent cited marginal viability on small sites, and also suggested removal of reference to ‘National Park Purpose 1’ in part 2(b) of the policy. A further respondent referred to the Whole Plan Viability Study which refers to the importance of flexibility for specific sites. (various organisations)  Recognition should be made of the different demographics of settlements. (The Midhurst Society)  A standalone policy to address the needs of older people should be introduced, given it is clear that the needs of older people makes up a high percentage of the need. (McCarthy and Stone Retirement Lifestyles Ltd.)

Individuals

 Should positively support provision of social housing in villages to re-dress balance against expensive ‘detached house style’ villages. (Lewes District Council, Cllr Victor Ient)  Policy should be amended to provide greater flexibility e.g. to say that the mix should be in line with the identified local need set out in the SHMA. Should be amended to allow for larger dwellings. The need for a housing need survey to evidence an alternative mix is unduly onerous.  Target for older people’s housing is ludicrously low given current demographics. Little is said about innovative solutions. Little mention of housing for the disabled.  Should reduce the number of mansions through sub-division into smaller units. Question any requirement for 4 bedroom houses.

431 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD28 Affordable homes There were a total of 65 representations on this policy. A summary of the main issues raised is set out below.

National agencies No comments received.

Borough, City, County and District Councils

 Generally support approach although in practice it is difficult to secure onsite units on sites where only one or two affordable units are to be provided. Specific changes to policy requested: lower threshold should be 4 not 3 dwellings on a site; include further guidance on levels of integration, and state that policy may not be circumvented by under-delivery of housing. (Chichester District Council)  Part 1(b) should signpost to paragraphs 7.72 and 7.73 to explain ‘meaningful financial contribution’. Correct inconsistencies in parts 1 and 2 re lower thresholds in policies for on- site financial contributions. Amend 7.67 to state that all viability appraisals should be independently at the applicant’s expense. (East Hampshire District Council)  Object to part 4 of the policy which appears to exclude local housing authorities and registered providers, who are likely to be the main agents of delivery, from involvement in occupancy conditions and local connections criteria. Policy should refer to these, plus housing associations and HARAH. (Winchester City Council)

Parish and Town Councils

 Welcome/support policy. (Cheriton PC, Liss PC, Petersfield TC, Slindon PC, Steyning PC, Buriton PC)  Welcome policy but would like it strengthened to ensure affordable housing is pepperpotted throughout the development and is tenure-blind. (Easebourne PC)  Support policy, but consider it is not always desirable or economically viable to combine market and affordable housing on a single site. (Hawkley PC)  There is a concern about part 3 including ‘where feasible’ as it is too lenient / the emphasis should be on the party wishing to take the property out of being an affordable home. (Lavant PC, Selborne PC)  Re 7.58: concern over last sentence re exceptional viability constraints, which is an easy get- out clause for developers. (Selborne PC)  Regarding 7.62, there is experience of applying cascade of local connections is frustrated due to adjoining parishes falling under different district councils. Unclear on approach to CIL where affordable housing is to be provided off-site. Note that managing just 2 affordable homes on a 6 home development might be difficult. (Amberley PC)  Concern re how SDNPA will identify what is a genuinely affordable rent. (Elsted & Treyford PC)  The affordable housing mix is too high and a disincentive to any development. (Fernhurst PC)

432 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Requirement that affordable housing should take preference over all other requirements is a decision that should be based on local circumstances. Policy should refer to ‘except as provided for by development briefs or allocations in neighbourhood plans, or as justified by local circumstances.’ (Twyford PC)  There is a need for larger family homes in West Meon as it is strategically important to support existing families and this should be a consideration for the housing mix of the site. (West Meon PC)  Concern over emphasis on the word ‘affordable’. Support level of affordable housing. (Lewes TC)

Other organisations

 Support policy reflecting that affordable housing to meet local needs is crucial, and reflecting evidence in the HEDNA/SHMA. One respondent welcomed policy in respect of supporting younger generations to remain in the locality. (various organisations)  Policy (sliding scale of affordable housing requirement) does not reflect the Written Ministerial Statement (WMS) made by the Minister Brandon Lewis MP on 28 November 2014, also reflected in Planning Practice Guidance (PPG) Paragraph 031 Ref ID: 23b-031- 20161116. This sets thresholds of 10 units or less or 1,000 sqm or less for seeking on-site affordable housing, and of 5 units or less in National Parks / Designated Rural Areas for seeking commuted sums. PPG does not make an exception argument to be made based on a specific need within the local authority area. The Government’s approach reflects that small developers have tighter cashflow / lower viability margins and will otherwise be disincentivised to build houses to meet the housing need. (various organisations)  A target of 50% affordable housing on sites of 11 or more may prevent the delivery of homes, which does not reflect the objective set out in NPPF paragraph 47 to assist the delivery of much needed affordable homes in the National Park. One respondent expressed surprise that a minimum 50% is sought given the previous viability study prepared by Dixon Searle LLP recommended a maximum 40% level be sought on sites of 10 units or more. Others considered this level would, on basis of viability evidence, put the Plan’s delivery at risk, particularly in medium- to low-value settlements. (various organisations)  50% affordable housing is not considered achievable on previously developed land (PDL), which is a site typology not tested by BNP Paribas and has sometimes significantly higher costs of development compared with greenfield sites. Policy should instead require c.30% on PDL sites but with flexibility for site specific costs. (West Sussex County Council, Cowdray Estates)  The burden of this policy together with other policy requirements will in many cases fail to allow a competitive return to a willing landowner (NPPF paragraph 173 cited). This will mean that no sites will come forward. Examples of other competing requirements are Policy SD27 Mix of homes, high design standards, low densities and provision of zero carbon homes. One respondent cited evidence of decline of SME house builders over the last 30 years. (various organisations)  Unclear on what part 2 of the policy cross-refers to. Viability exception should also apply to larger sites of 11+ dwellings. (Barlavington Estate)  Levels of affordable housing contribution are far too prescriptive and not justified due to huge flexibility in house prices across the region. Example given of conversion of former employment buildings to provide modest sized dwellings for private rent. (Bryan Jezeph Consultancy Ltd)

433 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Requirement to provide complex viability assessments discourages landowners from bringing forward proposals. (Bryan Jezeph Consultancy Ltd)  The phrase ' meaningful financial contribution, to be negotiated case by case' is very vague and does not provide the necessary level of guidance for any potential developer to assess the prospects for development. (Bryan Jezeph Consultancy Ltd)  Current policy wording is ambiguous and may in some cases lead to no contributions being made to affordable housing or other aspects. Recommend policy is reworded. (Comer Homes)  The typologies used in the Whole Plan Viability Assessment (BNP Paribas, 2017) do not reflect the lower densities being proposed on some allocation sites, and is considered to underestimate the build cost of flats. The study also does not test larger allocations made through the Plan which are critical to housing supply. (Cove Homes)  Given a high affordable housing requirement of 50%, the overall housing target should be increased to nearer the ‘high’ level. To not do so will mean the OAN will be far from met and strategic housing need will not be addressed, putting significant pressure on surrounding authorities. Propose alternative requirement of 35-40% affordable housing. (EPV (East Sussex) Ltd)  Too much emphasis/reliance placed on Community Land Trusts – there are very few in existence. Local housing authorities and registered providers are likely to be the main agents of delivery. HARAH is a good example of a successful delivery partnership. Policy should emphasise these. In 7.61 the phrase ‘genuinely affordable’ requires clarification. Linking affordability so closely to Local Housing Allowance makes the policy too rigid to adapt to new measures and affordable housing products. Alternative wording suggested. Request option for local connections to extend to parishes adjoining the National Park. (Hampshire Alliance for Rural Affordable Housing - HARAH)  For developments of 10 dwellings or less, the level of affordable housing delivery is unlikely to generate interest from Registered Providers (RPs) who will see significant management issues in serving a small number of isolated units in remote locations within the National Park. Community Land Trusts (CLT) will be very difficult to administer given the nature of these organisations and the complexity of delivery/management. (Murray Planning Associates)  Links should be made between these policies and SD34 Sustaining the Local Economy. Affordable Housing development that is to be built with locally sourced sustainable building materials should be looked on more favourably, thus supporting the local forestry industry. (South Downs Land Managers Group)  Welcome approach to including all development in Use Class C3 being subject to the policy. However consider that 7.68 is in contravention of PPG paragraph 017, Ref ID: 10-017- 20140306 which makes clear that planning applications should be considered in today’s circumstances unless a scheme phases delivery over a medium or longer term. This is confirmed in Government guidance ‘Section 106 Affordable Housing Requirements Review and Appeal’ and RICS guidance GN 94/2012 Financial Viability in Planning. (McCarthy and Stone Retirement Lifestyles Ltd)

Individuals

 Policy is contrary to NPPF paragraph 173 requiring that sites should not by subject to a level of policy burdens that threatens viability, and Written Ministerial Statement of 28 November 2014 and PPG ref: 3b-031-20161116 which sets a lower threshold of 5 units in national parks and only tariff style contributions up to 10 units. (various individuals)

434 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Young people are being priced out of villages and the policy does not go far enough. Support a positive policy of temporary accommodation for young people to stay living in the countryside. (Lewes District Council, Cllr Victor Ient)  Welcome policy upper threshold of 11, percentages, and move to prevent developers circumventing the policy by dividing sites or claiming unviability. (Cllr Joanna Carter, Green Party, Lewes District Council)  Statement that insufficient affordable housing provision which is contrary to the policy is a significant factor weighing against approval is wholly unjustified and in conflict with the NPPF and PPG. Policy is not supported by evidence, including that prepared in relation to the Old Malling Farm strategic site where the Secretary of State’s Inspector concluded that 40% affordable housing was reasonable.  Concern over strict requirement to integrate affordable units throughout a development, given some Registered Providers (RPs) require affordable units to be located together for management purposes. Exceptional circumstances requiring an off-site payment should be expanded to smaller sites, to allow for where RPs are not in a position to manage the properties.  The Authority appears to countenance acceptance of Neighbourhood plans which fail to set concrete targets to be achieved within measurable timescales. No suggestion that larger sites should be looked at to maximise affordable housing numbers. Some Neighbourhood plans seek to limit site density although this may mean that the financial viability of such sites to provide affordable housing becomes an issue. The affordable housing target of 293 per year over the plan period seems very low.  The sliding scale in the policy is not flexible and will not help those who need affordable housing.  Concern that the policy creates too much of a burden on small holding landowners looking to deliver less than 5 new homes. Policy fails to take into account the following criteria: the needs of the local community for additional market housing; the need for downsizing opportunities; the proportion of affordable housing already provided in the community; the likelihood of affordable housing being provided in other areas, and the limited supply of land. The policy could undermine recently made neighbourhood plans that meet locally identified needs in a different way to that proposed by this blanket approach.

435 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD29 Rural Exception Sites There were a total of 27 representations on this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Would prefer paragraph 7.80 to read “…on the ability of the natural and historic environment to contribute to ecosystem services…”

Borough, City, County and District Councils

 Object to part 3 as the policy (and 7.81 with respect to councils) should refer to housing associations, councils/local housing authorities, registered providers, HARAH and the Hampshire Community Housing Partnership. Where sites/settlements are near the edge of the National Park, local connections criteria should include adjoining parishes outside the Park. Market housing provided where justified by viability (7.79) is a key issue that should be addressed in the policy itself. (Winchester City Council)

Parish and Town Councils

 The policy is welcomed/supported. (Cheriton PC, Liss PC, Petersfield TC, Steyning PC)  Would wish to see the wording of the policy and supporting text tightened so that the role of the Parish in identifying need, subsequent allocation, size, type and occupancy criteria/conditions is formalised, and role as link between SDNPA and local housing authority recognised. Amended wording suggested along these lines. (Corhampton & Meonstoke PC)  Policy fails to appreciate the high cost of land and building in the SDNP, and would be more successful if it allowed for a small number of market houses to fund the social housing and/or community facilities. (Itchen Abbas PC)  Policy should recognise that it is not always possible to provide affordable housing in perpetuity given a community land trust’s potential need to sell houses to raise capital for further developments, or given potential future Government instruction to housing associations to implement Right to Buy. (Midhurst TC)  Community targets, and an overall SDNP target, for rural exception schemes should be included in the Plan similar to the Lewes District Local Plan. This will contribute to meeting overall housing delivery. (Ringmer PC)  Add to part 1(d): ‘It is shown that there is community support for the site…’ Amend 7.81 to say the choice of site should be supported by the community. (Selborne PC)  Object to omission of allowing a market element of 30% for rural exception sites, which puts it at odds with both the Winchester JCS and has been adopted by the Twyford Neighbourhood Plan. This would encourage more land to come forward and would not reduce the willingness of the community to support such sites. (Twyford PC)

Other organisations

436 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 To be consistent with national policy (NPPF para54), Policy SD29 should allow for mixed tenure schemes to facilitate the provision of significant additional affordable housing to meet local needs. (Cowdray Estates Office)  Rural exception sites should allow for some/up to 30% open market housing in line with Policy CP4 of the Winchester JCS and Policy CP14 of the East Hampshire JCS. Reasons given include: to meet the aspirations of local communities; provide for mixed communities through a mix of market and affordable housing; 100% affordable housing renders such sites undeliverable due to squeeze on housing association funds; important for meeting the objectives of the NPPF and English National Parks Vision and Circular. (various organisations)  Policy should at least allow the inclusion of open market homes on exception sites where schemes arise from endorsed Whole Estate Plans. (Glyne Estates)  Policy should take account of evidence on delivery from elsewhere, for example how landowners might be incentivised to bring sites forward. Sites in villages may have a value far in excess of current agricultural land value, for example as an alternative use as private amenity/garden land. Values generated by 100% affordable scheme might be lower than the current use value of a potential site. This can be squared by allowing such sites to contain an element of higher value open market housing, or by being flexible on site selection. (The Leconfield Estates)  There is no apparent effective vehicle through which to convey the aspirations and opinions of local people in Madehurst. Object to apparent link between rural exception sites and tourism (7.10). (Madehurst Parish Meeting)  Links should be made with Policy SD34 Sustaining the rural economy. Affordable housing built with local sustaninable building materials should be looked on more favourably. It is not clear ow the policy actually encourages their delivery. (South Downs Land Managers Group)  The policy should be reworded to stress that community involvement is essential from the outset and not only in respect of design, layout and types of dwellings. Question the ability of housing providers to guarantee local connection criteria for affordable homes on a long term basis. (South Downs Society) Individuals

 Support policy.  Important to choose sites carefully to ensure access to sustainable transport and services. (Lewes District Council, Cllr Victor Ient)  Rural exception sites should allow for up to 30% open market housing in line with Policy CP4 of the Winchester JCS and Policy CP14 of the East Hampshire JCS, to address near drying up of affordable housing supply.

437 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD30: Replacement Dwellings There were a total of 28 responses on this policy. A summary of the main issues raised is set out below.

Specific consultation bodies – national agencies and utility providers No comments received.

Specific consultation bodies – other local authorities

 The constraint of only being able to provide a 30% uplift could be limiting and does not appear consistent with the SDNPA landscape led approach (Brighton & Hove City Council)  The Estate supports Policy SD30 criterion 2 however the use of the term small would benefit from being more precise to avoid future uncertainty (Brighton & Hove City Council)  Preventing the loss of smaller dwellings would be better if it was pro-actively addressed by an increase in the supply of such dwellings to ensure an appropriate mix of housing is available (Brighton & Hove City Council)  Criterion 1(b) refers to loss of light; we consider that the policy should be amended to include overshadowing/overbearing impacts (East Hampshire District Council)  Recommend that a new criterion (1c) is inserting to an assessment on the character and appearance of the area (East Hampshire District Council)  Supporting text should address Lawful Development Certificates (East Hampshire District Council)  There is no limit on the size of replacement dwellings within settlements but there is a limitation on extensions (East Hampshire District Council)  Support Policy SD30 (Cllr Jackie Porter, Hampshire County Council)  SD30 makes no reference to design issues – presumably to avoid repetition with other policies – but this needs to be stressed (Winchester City Council)

Parish and Town Councils

 Text change suggested (East Lavington Parish Councils)  Typos in Paragraphs 7.87 and 7.89 (Harting Parish Council; Selborne Parish Council)  Supports Policy SD30 (Hawkley Parish Council)  Supports Policy SD30 but also suggests an addition clause (1c) “the replacement dwelling(s) should not be detrimental to the dynamic character of a settlement already comprising large (>400m²) housing (Itchen Abbas Parish Council)  Objection. Policy SD30 is contrary to general protection of countryside and National Park, and has not been consulted upon. Not the same as EHDC Local Plan policy H9; it invites interpretation and challenge. Changes suggested (Liss Parish Council)  Supports policy subject to typo corrections but has concerned about impact on rural area. Suggests text changes (Selborne Parish Council)  No objection provided it is made clear that this would not prevent the building of a granny annexe; should be made clearer that this applies only outside settlement boundaries; will object if anything in excess of 2 dwellings as it risks creating pockets of housing remote from

438 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues villages (for example a 5000 sq/ft house could be replaced by 6/7 dwellings); larger grounds would need different maintenance regime if sub-divided (Twyford Parish Council)  Additional clause needed in SD30 addressing impact on street scene (Upham Parish Council)

Other organisations and individuals

 The policy would provide opportunity for developers to seek sub-division of many properties in the countryside contrary to policy SD25 which precludes development in the countryside other than in exceptional circumstances (Individual)  Within East Hampshire there are currently many developments of low density housing within “Areas of Special Housing Character” which have been protected from intensification of development by saved policy H9 of the East Hampshire District Local Plan. Policy SD30 criterion 2 puts at risk the ability to maintain valued character and landscape of such areas (Individual)  The Estate does not believe that imposing an arbitrary limit on the net increase in internal area of 30% is appropriate and as such the policy should be amended accordingly (Cowdray Estate)  The policy is overly restrictive. There are a number of properties within the SDNP where a significantly larger replacement dwelling can be justified as they are already large properties and so making them substantially larger still will not alter the mix. Durford Wood (near Petersfield) is an example of this type of area and as such the policy should be amended accordingly (Durford Wood Landowners Limited)  Support policy but seek further clarity on how it would be provided in practice (Leconfield Estate; The Edward James Foundation)  The policy should be rewritten to make it clear that it should be generally applied - unless there is cause for exception (Individual)  Inconsistency of approach in planning policy – it would mean that you could built houses in the countryside but not in “enclaves” (such as Abbots Worthy) (Individual)  Policy SD30 has no conditions attached (Individual)  Policy SD30 is laudable but in practice will increase dwellings in unsustainable locations whilst the settlement boundaries have been rightly redrawn (Individual)  It is not clear how the 30% increase threshold for extended or replacement dwellings has been established; may be weakened by appeal decisions (South Downs Society)  Would welcome alteration to SD30 which concerns replacement dwellings to confirm that dwellings that are subject to cliff erosion can be replaced on a more appropriate long-term site (The Gilbert Estate)  Additional criterion relating to reducing carbon footprint than the existing dwelling (Midhurst Society)

439 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD31: Replacement Dwellings There were a total of 23 responses on this policy. A summary of the main issues raised is set out below.

National agencies No comments received.

Borough, City, County and District Councils

 Policy SD31 should be amended to refer to character and appearance, and replace reference to ‘loss of light’ with ‘detrimental… by virtue of overshadowing/overbearing impacts…’ (East Hampshire District Council)  Policy makes no reference to the need for appropriate design, materials, character, form or style – if this is to avoid repetition, important that the need to meet all policy requirements is stressed. (Winchester City Council)

Parish and Town Councils

 Strongly support policy (Liss PC, Selborne PC)  Excellent policy, 7.97 should include something about home deliveries and noise. (Bury PC)  Object to 7.94 - larger may be permitted where no harmful intrusion on the landscape which will encourage larger dwellings. (Elsted & Treyford PC)  30% limit is too low and prescriptive – each case should be judged on merits (Fernhurst PC)  Policy SD31 should be ‘grandfathered’ so as to apply only to houses which change hands in future i.e. people who owned the properties prior to this policy should not be subject to it. Question whether 30% rule will help with homes being ‘attainable’. (Hawkley PC)  There appears to be no mechanism to stop an applicant growing their home by up to 30% every few years; this is a serious oversight. (Lavant PC)  Should explicitly state that stock of smaller ‘starter homes’ must not be eroded. There should not be a block where family circumstances may require greater flexibility. (Rowlands Castle PC)  Not clear on whether policy applies both within and outside settlement boundaries. If outside of it, the limitation is supported. Granny flats or annexes outside the settlement boundary should be treatd as a special case and not limited to 30%. (Twyford PC)

Other organisations

 The constraint of only being able to provide a 30% extension is too limiting; the amount of development should not be constrained as a percentage. Amount of development should be based on its specific impacts – examples given included impact on landscape and scenic quality, in line with the landscape-led approach; proportionate in size and scale to existing dwelling; heritage assets and their settings. Some considered 30% as arbitrary and inappropriate. (various organisations)

440 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 The overall policy objective is supported although it is unclear whether it will be effective in controlling unsightly roof dormers (Friends of Lewes Society)  Not clear how the 30% was established. Absolute thresholds may be too inflexible, as opposed to guidelines beyond which higher levels have to be individually justified. (South Downs Society)  Additional criteria should be added that any extension must not increase the carbon footprint of the existing dwelling. (The Midhurst Society)

Individuals

 Policy should be redrafted to anticipate the reality of circumstances that exist (e.g. extension of dwellings on large plots that have capacity to accommodate this).  Concern expressed over enlargement of houses when it is smaller dwellings that are needed.  A consistent 30% limit would be better as the reasons for exceptions to this will not be clear.

441 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD32: New Agricultural & Forestry Workers Dwellings There were a total of 57 responses on this policy. A summary of the main issues raised is set out below.

Specific consultation bodies – national agencies and utility providers No comments received.

Specific consultation bodies – other local authorities

 Policy wording is too restrictive; Criteria 2(c) could preclude a new dwelling if other dwellings had been sold off for valid reasons and does not take account of unforeseen changes of circumstances; the 120m² limit appears arbitrary and not consistent with the landscape led approach or there is a specific circumstance that dictates the need for a larger dwelling (Brighton & Hove City Council Estate Dept.)  We consider that Policy SD32, criterion 3 should be amended to make it clear that the first preference will be for re-use as an affordable unit and only then as an open market dwelling where it can be robustly demonstrated that is not viable / unsuitable for use as an affordable unit (East Hampshire District Council)  Too often in the past we have seen agricultural workers houses only built a few decades ago being allowed to be retained for non-agricultural purposes. Often these buildings are in totally unsuitable locations. This backdoor method of improving the value of land should be discouraged. Developers should be required to demonstrate an absolute need. Any temporary permissions should limited to temporary building so they can be removed when the permission expires (Lewes District Council)  A number of policies inc. SD32 make no reference to the need for appropriate design, materials, character, form or style, all of which can have an adverse effect on visual amenity and local character if not appropriately addressed. It is assumed that this is to avoid repetition with other policies, but it is important that the need to meet all policy requirements is stressed (Winchester District Council)

Parish and Town Councils

 There seems to be no mention of the difference between Horticultural use and Agricultural use (Bury Parish Council)  Policy SD32 supported (Fernhurst Parish Council)  The restriction of this policy (SD31) to new housing for agricultural and forestry purposes is not sound, as it does not recognise the full range of rural activities for which rural housing might be required, and is thus not fully in accordance with NPPF para 55 (Ringmer Parish Council)  Support Policy SD32 (Selborne PC)  The general sequence runs that an agricultural smallholding is created and a barn will be put up. This will then be converted to a dwelling. A more rigorous application of a) will be essential (Upham PC)

442 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Other organisations and individuals A high number of individuals (approx. 30) submitted the same letter which made the following ley points:-

 Reduction of time period in the emerging policy from 10 years to 5 years. The reason given by the SDNPA for the reduction in the time period is that there were objections to the ten year period from "various Estates" that considered the ten year period to be too restrictive. These are the organisations that can directly benefit financially from the time reduction so they would obviously want this change. The SDNPA has decided that the five years period is a common figure for business plans and that "five years strikes a reasonable compromise between disposing of property". These reasons for reducing the time period are very questionable for the following reasons:

i. The SDNPA guidance for Whole Estate Plans quotes a practical period of 15 years for a WEP, the same as a Local Plan. Five years for a business plan is very short term and ten years is a reasonable compromise. ii. Business plans would not normally take into account personal issues such as death and divorce. iii. Interested organisations that supported the ten year period would not have commented. The ten year period was reasonable and should not have been changed. iv. Example of the Wiston Estate set out.

 Generally supported but considered potentially restrictive because criteria 2(c) could preclude a new agricultural/forestry dwelling if other dwellings had been sold off for perfectly valid reasons, and it does not take into account unforeseen changes of circumstance (e.g. economic cycles); the specific limit of 120m² appears arbitrary, and not consistent with the ‘landscape-led’ approach followed by the SNDPA (Angmering Estate)

 I support SD32 overall and it has been well put together. In 7.100 I consider that the minimum should be 10-15 hectares, as it is unviable to run any kind of bona fide agricultural business on less than this. I do not think that an ag-tied dwelling should be permitted for small-scale hobby farming, and in keeping the minimum at 5 there is a risk that this will encourage unsuitable and unviable applications; There should be a requirement for the business to submit audited accounts as proof (Bignor Park Estate)

 Support Policy SD32 (CLA)

 We support SD32 as we believe that it is in line with national guidance. However, we would like to see further evidence of how the 5 hectares criterion in para 7.100 has been arrived at and we also like to see para 7.100 expressed as part of the policy text. In section SD32 bullet (4) it should be demonstrated that at the end of any temporary permission the financial viability is proven if any buildings approved under this policy are to be retained and that occupancy terminates if the enterprise ceases (CPRE Sussex)

443 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 It does not cater for other essential rural workers and in this respect it is inconsistent with paragraph 55 of the NPPF/the Plan’s strategic objectives (Elizabeth Lawrence Ltd, Glynde Estates)

 7.100 in respect of rural workers should refer to ‘making a core contribution to the operation and viability of that enterprise’

 Part (d) only allows for 120 m² of habitable floorspace. Many farmworkers have families and may require a larger amount of floorspace. The wording of the policy is too prescriptive and should be amended to ensure it provides sufficient flexibility to allow for larger dwellings where there is a demonstrable need (Leconfield Estate)

 We’re concerned with the word “extensive” (Part 2.a) as this would be open to a considerable degree of interpretation and very likely to lead to objections or appeals; could be a discrimination against holdings below the “extensive” size criterion, whatever that may be? The relative size of the enterprise is not engaged by NPPF 55, which relates to the “the essential need for a rural worker to live permanently at or near their place of work in the countryside”. The essential and permanent need criteria would not in every case be linked with the question of holding size as it would be plausible for a viable rural undertaking to involve relatively small areas of land in some cases. Furthermore given that NPPF 28 relates to the sustainable growth and expansion of all types of rural business, the introduction of a requirement that those businesses are “extensive” would contradict national guidance? In our view the use of the word “extensive” should simply be deleted as it has no relevance to the material planning issues. The use of this word is not proportionate, effective or consistent with national policy (NFU and South Downs Land Management Group)

 Supported. At 2a) the proposed enterprise should be required to demonstrate financial viability. At 4 (temporary dwellings) the applicant must be able to provide evidence of the intention to proceed towards the development of an agricultural or forestry enterprise. At the end of any temporary permission it must be demonstrated that the financial viability is proven if any buildings approved under this policy are to be retained (South Downs Society)

 Policy SD32 defines the criteria for permitting the development of new and temporary dwellings for agricultural and forestry workers (Page 139 ). An additional criterion should be applied namely that such permanent or temporary dwellings must be constructed according to best sustainable and environmental practice (Midhurst Society).

 There is a mismatch in the time frame between the established criteria (three years) of clause 7.100 and the disposal criteria (five years) of 7.102. This seems unreasonable because a new owner could be burdened by the actions of a previous owner and this is not consistent with the duty of the NPA to seek to foster the economic and social well-being of the local communities (Individual)

 SD32 requires “conserve and enhance” focus (eg shepherds managing flocks to conserve rare chalk grassland, woodsmen managing broadleaved woods, nature reserve wardens protecting rare biodiversity – benign “agrienvironment” not intensive “agri-business”) (Individual)

444 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

445 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD33: Gypsies and Travellers and Travelling Showpeople There were a total of 21 responses to this policy. A summary of the main issues raised is set out below.

National Agencies Environment Agency: Support that provision made for foul water infrastructure.

Borough, City, Council and District Councils

 Note the joint site search exercise between the two authorities and regret no suitable sites identified (Brighton & Hove City Council)  A new GTAA has been recently finalised and once published it should be taken into account. If there is a shortfall in meeting needs EHDC expect the SDNPA to have analysed all potential sources of supply before approaching adjoining authorities to meet any unmet need. (East Hampshire District Council)  A new GTAA has recently been produced and it is understood that the SDNPA is satisfied that the need for additional pitches can now be met without additional provision. The City Council supports this conclusion. (Winchester District Council)

Parish and Town Councils

 Concerned that Gypsies are able to build on agricultural land that others are not. (Bury PC)  Support (Fernhurst PC)  Policy does not require the consideration of the protection of the landscape or any of the other interests and objectives of the SDNP. These objectives are required to be considered in any development within the settled community. (Hawkley PC)  Concerned traveller sites not evenly dispersed across district. (Liss PC)  Support SDNPA working with other parties to ensure sites do not cause harm to special qualities. (Madehurst Parish Meeting)  Should be clear whether figures are based on earlier definition of Gypsies and Travellers. It should be stated that the SDNPA has been working with partner authorities to test all reasonable options for meeting unmet need outside the National Park boundaries. Wording of policy should make it clear that all other policies in the Development Plan apply. The requirement for a local connection is contrary to the PPTS 2015. Needs greater reference to Travelling Showpeople. The term ‘locality’ is vague. Part d) should apply to whole policy not just infrastructure. Concerned about removal of parts of policy contained in Preferred Options version. (Colemore & Priors Dean PC)  Policy seeks to avoid over concentration of sites, yet sites in Greatham and Hawkley. Sites should be screened. Remove ‘unacceptable’ before ‘harm’ in 3 f) (Selbourne PC)

446 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues Other organisations

 Assessment of need was not based on 2015 guidance. Policy is based on inaccurate and out of date evidence. There was only a limited response to the survey work. Request an up to date GTAA is undertaken. (Greatham Voice, Hawkley PC, Heine Planning)  To avoid harm, previously developed land should be considered. (South Downs Society) Support inclusion of site allocations in plan but query why not listed in policy SD33 and why point 2 of policy refers to unidentified sites. (Heine Planning)  The assessment fails to have regard to the application (and current appeal) for Three Cornered Piece, Nyewood, Harting. As the SDNPA have established they are unable to find sufficient suitable sites this site should be revisited. Various pieces of supporting information supplied. Considered as an Omission Site. (Heine Planning)  Aspects of Policy are not compliant with national guidance in PPTS: no requirement to demonstrate a local connection; no justification for criteria 3b – Travellers are entitled to choice of accommodation by location, tenure and price; the term ‘in the locality’ is vague; criteria c is considered unnecessary, given the small scale of existing provision, scattered nature of most sites around the periphery of the NP and small need identified. (Heine Planning)  Assessment of need does not cover the National Park as a whole. Background paper based on an update of a number of different studies. No apparent cross boundary cooperation between the constituent authorities within the NP. Several studies are out of date. No assessment of recent applications/ appeal decisions in districts such as Chichester and Horsham. Query how the NP can claim that there is no further need in Chichester. There appears no allowance for in migration even though Councils are aware that in the past some families have relocated to this area. (Heine Planning) Individuals

 Potential of all unauthorised sites / those with temporary permission in East Hampshire must be considered as part of the site search. The site search was not comprehensive (Cllr Budden, Liss PC)  Support criteria 1. Expect the need is higher than reported, seek more proactive action. The definition of gypsy and traveller goes beyond ethnicity to include van-dwellers of diverse ethnic backgrounds, including new age travellers. Plan should recognise the need to provide sites for all travellers, and to ensure sites are not restricted to those of a certain ethnic background. (Cllr Carter)  Should review whether there is still a current need as there may be a decreasing demand for sites. (Lewes District Council, Cllr Ient)  Site at Warren Barn should be allocated for Travelling Showpeople and the requirement for pitches in Hampshire increased to 15 to include them. The impact of the site could be mitigated by landscaping and improvements to the adjoining land in the ownership of the applicant. Considered as an Omission Site.  Allocations fail to meet full need, insufficient sites to provide a 5 year supply. No new sites have been allocated.  Suggest using largest allocations to accommodate pitches e.g. Midhurst Caravan site.

447 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD34: Sustaining the Local Economy There were a total of 26 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Sports England: requested that the value of sport to the local economy be reflected in the Local Plan.

Borough, City, County and District Councils

 Concerned that the policy has no limits on the scale of business uses that may be permitted or whether they are located inside settlement policy boundaries. (Winchester City Council)

Parish and Town Councils

 Support and welcomes policy (Buriton PC, Fernhurst PC, Rowlands Castle PC, Selborne PC)  Concern over noisy light industrial sites (Bury PC)  Considers the policy to be unduly restrictive (Liss PC)  The Local Plan should relate to all types of employment and not just farming, forestry and tourism (Midhurst TC)  There should be a commitment to minimum broadband speeds of >10Mbs rather than just superfast broadband (Stedham with Iping PC)  Suggestions that the chapter should be renamed economic development, that the phrase local economy should be defined and questioned the use of brownfield land (Twyford PC)  The policy should be amended to allow NDP policies to take precedence (Twyford PC)

Other organisations

 Suggested changes to criterion 1(a) to promote the flexible development of permitted and allocated sites (JLL on behalf of Gentian Developments Limited)  Suggested changes to criterion 1(f) to refer to wider employment uses outside the traditional B use classes (JLL on behalf of Gentian Developments Limited)  Welcome the focus on green and micro businesses (Lewes District Green Party)  Suggestion that the policy should reference creative businesses such as Glyndebourne (Lewes District Green Party)  Reference should be made to Shoreham Cement Works as a specific location with significant employment opportunities (South Downs Project)  Locally sourced sustainable building materials should be used to build affordable housing (South Downs Land Managers Group)  The permitted scheme at North Street Quarter, Lewes will result in the loss of many small and micro businesses (South Downs Society)  Support for employment allocation at Longmoor (Whitehill & Bordon Regeneration Company on behalf of Defence Infrastructure Organisation)

448 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Suggestion that the policy should be widened to include other businesses particularly the digital technology sector  The focus on the three key sectors is inconsistent with the positive approach taken to employment land in Policy SD35 (Glynde Estates) Individuals

 Suggestion that all planning applications should provide evidence that they will benefit the local economy.  Suggestion that planning applications that do not provide irrefutable evidence that they foster the economic and social well-being of local communities should be refused  There should be a commitment to minimum broadband speeds of >10Mbs rather than just superfast broadband.  Support for employment allocation at Longmoor (EHDC Councillor)  The Local Plan should relate to all types of employment and not just farming, forestry and tourism  Supply chains should be local to avoid inappropriate development in the National Park  Reference should be made to renewable energy schemes that make a positive impact on climate change

449 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD35: Employment Land There were a total of 18 representations on this policy. A summary of the main issues raised is set out below.

National Agencies No comments received.

Borough, City, County and District Councils

 Supports the approach to meet the objectively assessed needs for employment (Brighton & Hove City Council)  Policy SD35 and appendix 3 now provides the necessary details for marketing requirements for change of use applications (Chichester District Council)  A definition of ‘fit for purpose’ should be added to the supporting text (East Hampshire District Council)  Clarification is required on whether the additional employment land requirements in Policy SD35 are already permitted or allocated as per figure 7.7. The policy should be clearer to avoid ambiguity (Winchester City Council).

Parish and Town Councils

 Supports the policy (Fernhurst PC and Selborne PC)  Supports the policy on safeguarding and the requirement for 18 months’ marketing (Liss PC)

Other organisations

 Clarification should be added to the policy that employment sites allocated for other uses do not need to meet the marketing requirements set in policy SD25 (Comer Homes).  Welcome the safeguarding of existing employment sites such as Cliffe Industrial Estate (Lewes District Green Party)  Add Shoreham Cement Works as a specific location that will provide employment (South Downs Project)  Welcome the commitment to safeguard and allocate employment sites but concerned about the loss of small and micro enterprises at North Street Quarter, Lewes (South Downs Society)  Policy SD35(2) should refer to ‘conserving and enhancing’ rather than ‘potentially adverse impact’ (Sussex/Hampshire Wildlife Trust)  Considers that the approach taken by the Employment Land Review (ELR) has resulted in requirements for new employment land being significantly underestimated for the plan period. A demand of 67.18 hectares of new employment land is identified from an analysis of forecast economic growth over a 20-year period (2013 – 2033) based upon extrapolated Experian econometric demand forecast data and ONS Business Register and Employment Survey (BRES) data. Over two thirds of the demand is for B8 warehousing. The demand figure does not take into account latent demand which is expected to arise from a number

450 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

of emerging sectors in this area (Whitehill & Bordon Regeneration Company on behalf Defence Infrastructure Organisation)  Evidence prepared in the context of Whitehill and Bordon has identified a number of growth sectors which include a focus on the digital economy, speciality manufacturing and agri- tourism industries and support service as advocated and supported by the M3 Enterprise LEP. As currently worded the Local Plan would significantly restrict the ability of companies to expand and cluster within the SDNP catchment area. This would result in companies seeking locations outside of the area, resulting in a significant adverse impact on economic growth and employment diversification, which is of fundamental importance in achieving a prosperous and sustainable economic future for National Park residents (Whitehill & Bordon Regeneration Company on behalf Defence Infrastructure Organisation).  The employment land requirements set out in policy SD35 should be increased in line with the new evidence on objectively assessed need as follows: B1a/b: 8.2ha, B1c/B2: 8.2 ha and B8: 48.2 ha (Whitehill & Bordon Regeneration Company on behalf Defence Infrastructure Organisation).  Longmoor Depot should be allocated as an employment site (Whitehill & Bordon Regeneration Company on behalf Defence Infrastructure Organisation).

Individuals

 Support for employment allocation at Longmoor (East Hampshire District Council, councillor)  Employment development should be linked to sustainable forms of transport (Lewes District Council, councillor)  The Local Plan should take account of Newhaven Enterprise Zone (Lewes District Council, councillor)  The allocation of Stedham Sawmills does not comply with policy SD35.  Employment sites should not be included within settlement boundaries as this puts them at risk from redevelopment for housing.  Parish councils and local communities should be made aware of marketing exercises.  Policy SD35(2) should refer to ‘conserving and enhancing’ rather than ‘potentially adverse impact’.  Objection to the ‘additional potential supply’ of employment land as it is pre-growth.

451 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

7g: Town Centre and Retail Introduction There was 1 response to this policy. A summary of the main issues raised is set out below.

National Agencies

 No comments received

Borough, City, County and District Councils

 No comments received  Parish and Town Councils

 No comments received

Other organisations and individuals

 The links between the National Park’s towns and the rural hinterland should be explained further.

452 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

SD36: Town and Village Centre There were 12 responses to this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Supports Boroughs, City, County and District Councils

 Policy refers to loss of Use Class A but not to reduction of retail floorspace in existing units. This reduction can affect the viability of shops and should be resisted where possible. (Chichester District Council)  Policy protects the loss of all “A” uses. Policy SD43 includes the loss of pubs (A4 use class) and is duplication (East Hampshire District Council) Parish and Town Councils

 Support (East Dean & Friston PC, Fernhurst PC, Petersfield TC, Liss PC)  Part 2 re historic nature of centres should apply to larger village centres (Liss PC)  Welcomes the support for town centres (Petersfield Town Council) Other organisations

 Support (South Downs Society)  No developments can be considered for Midhurst without reference to the traffic problem between Rumbolds Hill and North Mill Bridge. Without resolving this, it is difficult to see how a new convenience goods store can be contemplated. The Plan should not be constrained by decisions from previous planning regimes e.g. identifying the area adjacent to The Grange Centre as suitable for a medium-sized supermarket. The only access is from Bepton Road which has traffic issues. In view of its proximity to the town's facilities this site might be suited to retirement units (The Midhurst Society)  Support in full (Glynde Estate) Individuals

 There are three supermarkets in the town and not two

453 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

SD37: Development in Town and Village Centres There were 12 responses to this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Support Borough, City, County and District Councils

 Policy protects the loss of all “A” uses. Policy SD43 includes the loss of pubs (A4 use class) and is duplication (East Hampshire District Council) Parish and Town Councils

 Support (Fernhurst PC, Liss PC) Other organisations

 Support (South Downs Society)  The policy should reference the need for adequate infrastructure to support developments. (The Midhurst Society)  Support in full (Glynde Estate and Weston Estate) Individuals

 Banks, cash machines, Post Offices, Libraries, recycling centres are at risk in rural market towns. For the viability of market towns, there needs to be a full range of services, their lack also hinders smaller retailers. (Cllr Porter)  Concern no protection of independent shops and the loss of shops from Lewes High Street. (Cllr Carter)  Query why the primary shopping frontage in Lewes not been changed. The designation of large parts as secondary retail is leading to many charity shops and conversion into residential or offices. Should be primary retail on both sides. (Cllr Carter)  Policy should stress the principle of conserving and enhancing, rather than doing no harm.

454 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

SD38: Shops outside Centres There were 9 responses to this policy. A summary of the main issues raised is set out below.

National agencies

 No comments received Borough, City, County and District Councils

 Policy protects the loss of all “A” uses. Policy SD43 includes the loss of pubs (A4 use class) and is duplication (East Hampshire District Council) Parish and Town Councils

 Support / support with minor textual changes (Selbourne PC, Fernhurst PC)  Traffic generated by shops outside centres needs to be addressed in Local Plan (Liss PC) Other organisations

 Support the approach to farm shops (CLA)  Approach to farm shops is not enforceable, inflexible, suggest a voluntary system showing origin of food. (South Downs Society)  Support in full (Glynde Estate and Wiston Estate)

Individuals  The percentages set out in the policy are not enforceable and another method of ensuring local produce is sold should be devised (Lewes DC Councillor)

455 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD91: Agriculture and Forestry There were a total of 24 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Natural England: Should refer the impact of damage to woodland habitats, in particular to ancient woodland, which is irreplaceable and requires particular consideration.

Borough, City, County and District Councils

 No comments received

Parish and Town Councils

 The policy is particularly important and welcome in rural villages (Buriton PC)  Track surfacing: Public bridleways should not be smoothed and made unsuitable for horses. Hardcore used should be in accordance with importance of forest floors. (Bury PC)  Criterion 1(f): 3 years is too short, would be open to abuse. (Fernhurst PC)  Should be a policy to encourage the use of traditional timber gates and fences where possible, and discourage their damaging replacement with steel gates. (Elsted and Treyford PC)  Should refer to smallholders/small livestock flock owners and how their buildings would be assessed. Such landowners have responsibility for land in key locations. (Rowlands Castle PC; Stedham with Iping PC)  Support, but should state how outside storage will be controlled. (Selborne PC)

Other organisations

 Supporting text should give a more balanced account of the impact of agriculture on the National Park. Plan should acknowledge the negative landscape/public access impact of excessively intensive farming, and provide guidance on the avoidance and mitigation of its adverse effects. (Eastbourne Downland Group)  Generally support policy (Various estates, CLA)  Wording should recognise that sometimes new buildings are required to replace buildings that are no longer fit for purpose, or to accommodate new farming practices. (Various estates)  Should include an emphasis on the importance of protecting agricultural land , as per NPPF para 112 (CPRE Sussex)  Need to demonstrate non-NP sites have been assessed first is too prescriptive and inconsistent with PD rights (Various estates)  Question if it complies with national policy for the NP to export activities deemed unseemly, to other areas. (South Downs Land Management Group)  Requirement to demonstrate that suitable buildings have not been lost in last three years is too prescriptive and inconsistent with PD rights. Delete. (Various estates)

456 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Proposal to open new tracks as paths for permissive usage where appropriate seems unfair to the applicant / Unrealistic and overly burdensome; issues with public safety, security and biosecurity, may cause loss of crops/livestock, additional insurance and public liability premiums. Delete. (CLA, NFU South East, South Downs Land Managers Group) The following comments relate to the requirement to remove existing buildings that have a negative landscape impact:

 This requirement seems to imply that this applies even to operational buildings, which is onerous and would not provide flexibility in supporting the rural economy. Decision on whether a building is creating a negative landscape impact is highly subjective (Various estates)  Existing buildings that are necessary for business operations should not become a negotiation tool; remove this section (CLA)  Gives the impression that every building within a planning unit would require a LVIA. This and the cost of demolition would impose a disproportionate cost on the applicant- not compliant with NPPF paras 21, 173 and 154. Remove criterion or limit the unit of consideration in LVIA to the application site boundary. (NFU South East,  Would have significant impact on farm viability. Remove or amend so it applies only to buildings within the site which have been redundant for 10 or more years and would require substantial reconstruction to improve their appearance or their impact cannot be reduced by some other means. South Downs Land Managers Group)

Individuals

 Does not address buildings for hobby farmers and smallholdings  Should highlight the importance of agricultural land for food production, and that that could be a possible reason for refusing or limiting development; no measures to ameliorate the visual impact of large barns. Should include positive encouragement for materials and roof treatments which minimise visual landscape impact; should give particular consideration to the impact of large barns on rural roads, discouraging access through villages; impact of major changes to agricultural on open downland (e.g. Steyning pig-farm). Policy should positively discourage the building of farm structures on the Downs, and where structure sexist, strongly encourage the landscaping of their roofs to lessen the visual impact. (Lewes DC, Cllr V Ient)  ‘Where feasible’ in criterion 1(b) should have commas before and after.  Criterion 2(c) Should require ‘enhancement’ rather than ‘,minimising impacts’  Remove the words ‘where appropriate; should state ‘dedicated access in perpetuity’.  Para 7.189- Remove the words ‘within the context of the NP purposes and duty’, and replace ‘agricultural’ with ‘agriculture’.  Para 1.90-1.191- Should stress local native species planting

457 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD40: Farm and Forestry Diversification There were a total of 17 representations on this policy. A summary of the main issues raised is set out below.

National Agencies No comments received.

Borough, City, County and District Councils

 Winchester City Council request a reference to the need for appropriate design, materials, character, form or style, or else to stress the need to meet the requirements of all other policies.

Parish and Town Councils

 The policy is particularly important and welcome in rural villages (Buriton PC)  Support (Selborne PC)

Other organisations

 Support the policy (Eastbourne Downland Group)  Policy broadly acceptable but could be worded more flexibly; this would make the policy more consistent with Class R PD rights (Various estates)  Should make specific allowance for ‘estate diversification’ (BHCC Downland Estate)  Support requirement for a financial viability test to ensure proposals are intended to form part of and contribute to a functional farm unit. (CPRE Sussex, South Downs Society)  Unreasonably restrictive to expect diversification activities to remain subsidiary to the farm/forestry operation, and to avoid severance or disruption to the holding. (CLA)  Remove requirement for subsidiarity. Ownership is not a material planning consideration and a change would not be considered development. There is little planning justification for this control over ownership structures, which would impose a burden in direct antipathy to the ambitions of NPPF paras 21 and 28, contrary to the National Park Duty, and would be unenforceable. (NFU South East, South Downs Land Managers Group)  Replace criterion (a) (ii) with “Diversification activities are not detrimental to the farming or forestry operation, in terms of physical scale” (South Downs Land Managers Group)  Remove requirement not to sever or disrupt the farm holding; severing the farm holding may be advantageous to businesses for various reasons and the policy does not meet their development needs. (South Downs Land Managers Group)

Individuals

 Conversion for commercial use will add to traffic and pollution on country lanes. Transport sustainability should be tested for such planning applications. Diversification should not

458 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues involve renting or selling off farm buildings for commercial use. (Lewes District Council, Cllr V Ient)  Should not prohibit diversification schemes which contribute to the second purpose of the National Park.  Add new paragraph stating that ‘Development proposals which are not supported by irrefutable evidence proving that they would be subsidiary to the farming or forestry operation in terms of both physical scale and income stream will be refused.’  Remove requirement for diversification to be subsidiary in terms of income stream; the income stream from diversification will often be bigger than from farming.  Remove requirement for subsidiarity. Should not prohibit diversified activities from contributing more than 50% of farm business income.  Criterion 1(a)(iii) is unnecessary, as such severance would not be interest of the farm business.

459 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD41: Conversion of Redundant Agricultural or Forestry Buildings There were a total of 36 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Historic England: welcome Criterion 2 in principle, but require the removal of the words ‘wherever possible’ from Criterion 2(c), or the addition of a mitigating caveat to specify where harm would be acceptable. They support paragraph 7.216, and also paragraph 7.211 although the latter should include more on the landscape and historical context for traditional farm buildings. Natural England require that the policy state a need for protected species surveys (for example, for bats and barn owls) in conversion proposals.

Borough, City, County and District Councils

 East Hants District Council request that criterion 1 should include reference to the relationship with neighbouring properties.  Winchester City Council request a reference to the need for appropriate design, materials, character, form or style, or else to stress the need to meet the requirements of all other policies.

Parish and Town Councils

 Paragraph 7.214 would appear to give ‘carte blanche’ to almost any proposal (Fernhurst PC)  Support the policy. (Liss and Selborne PCs)  Question how the removal of disused buildings, as per Paragraph 7.207, will be achieved. (Elsted and Treyford PC)  Criteria for assessing whether a building is ‘redundant’ should be specified. (Rowlands Castle PC)  Paragraph 7.213: replace ’priority’ with ‘intended’ and ‘SD47’ with ‘SD40’ (Selborne PC)  In the context of losing their settlement boundary, would like the policy to allow the demolition and redevelopment of redundant farm buildings with open market housing, Redevelopment with local workers’ housing may not be economically viable- should remove that requirement. (East Worldham PC)

Other organisations

 Welcome the policy (BHCC Downland Estate)  Should be strengthened to avoid abuse as a circuitous route to housing development (CPRE, South Downs Society)  Support the opportunity to utilise redundant buildings and encourage the authority to do so (CLA)  Should allow for open market housing in some circumstances, e.g. where there is a need for on-farm housing due to the implications of succession or retirement, or as a farm diversification project where there are no other suitable alternative uses. (NFU)

460 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Requirement for buildings to be located near infrastructure and services is not required under recent PD right changes (Part Q) (Various estates)  Policy of requiring proximity to infrastructure restricts conversions in isolated situations, contrary to NPPF Para 55 (Leconfield Estate)  Virtually all agricultural/forestry buildings are in isolated locations; too restrictive (Springs Smoked Salmon)  Rather than simply requiring proximity to infrastructure, should provide detailed policy criteria and guidance based on potential landscape impacts, including loss of buildings important to local character. (Leconfield Estate)  Restriction of residential conversions to agricultural/forestry workers is not consistent with NPPF para 55; does not provide a means by which NPPF 55 (3) can be delivered. 7.214 point 4 should be changed to ‘Housing may be acceptable where it can be proved that all other uses are unviable’ (Various estates/agents; South Downs Land Managers Group)  Should cover all redundant rural buildings, not only agricultural/forestry buildings, to match NPPF para 55. (Various estates/landowning companies)  Should have a tighter definition of ‘agricultural or forestry buildings’ (CPRE)  Should make more acknowledgement that conversion to residential can be acceptable (Various estates/landowning companies)  Criterion 1(c): Major alterations should be encouraged when they would improve the building’s appearance. Amend criterion accordingly (Springs Smoked Salmon)  Leaving a building empty would be likely to harm the landscape in the long term. (Springs Smoked Salmon)  Older and some new country houses are generally found attractive and modern farm complexes are thought of as blots on the landscape. Where the latter are redundant they should be converted to open market housing where it can be demonstrated that the landscape benefit outweighs the status quo or the landscape harm that might result from commercial conversion. (Various estates/landowning companies)  No reference to highways implications; some conversions may lead to a reduction in traffic. Amend criteria (a) and (b) to allow for conversion where this is the case.  Policy should also allow for redevelopment of agricultural buildings, especially where stemming from Whole Estate Plans, or where built form and environmental impact would be reduced from the status quo. Ref. appeal decisions. (Various estates/landowning companies)  Restriction of residential conversions to agricultural/forestry workers will significantly restrict the supply of housing in rural areas. (Angmering and BHCC Downland Estates)  Restriction of residential conversions to agricultural/forestry workers will result in the loss of many important local buildings (Leconfield Estate)  Restriction of residential conversions to local worker occupancy will constrain the development of local communities, which is fundamentally opposed to the NPA’s Duty (South Downs Land Managers Group)  Policy should allow more opportunities for the conversion of agricultural buildings to residential when appropriate to do so; for example, when they are located in a predominantly residential area. (BHCC Downland Estate)  The requirement that conversion should not result in the need for another agricultural building would prevent the conversion of older buildings which are no longer suitable to be used for agricultural purposes. As currently worded, the policy would prevent new purpose built agricultural buildings being permitted, harming farm viability. (Parker Dann)  Concern over allowing conversion of non-traditional farm buildings. Need rigorous wording to dissuade speculators from trying their luck, erecting ‘agricultural’ buildings, then converting the buildings to business or tourist use with the intention of a further conversion

461 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues to residential in a few years’ time. This could be prevented by only allowing the conversion of agricultural buildings aged over, for example, fifty years old. (Bignor Park Estate)  Should include a requirement that buildings are ‘established’ for a period of time, as per SD32 (CPRE)  Should allow for exceptional cases where the condition, size, design and location of a redundant building- including one of heritage significance- will preclude its change of use if the National Park’s Special Qualities are to be protected. (South Downs Society)  Where buildings are converted to tourist accommodation, there should be restrictions on the length of time a visitor can stay on the site, and a requirement for the operator to submit occupancy records/lettings register on a regular basis/on demand, to avoid the use becoming de facto full residential. (CPRE, Bignor Park Estate)  Section 2 unnecessary, this topic should be covered by heritage policies.  Requiring the removal of agricultural buildings would harm farm viability, is disproportionate and unsustainable in terms of the disposal of materials. (South Downs Land Managers Group)  Para 7.213 should refer to SD40, not SD47 (South Downs Land Managers Group)

Individuals

 Diversification should not involve renting or selling off farm buildings for commercial use. (LDC, Cllr V Ient)  Conversion for commercial use will add to traffic and pollution on country lanes. Transport sustainability should be tested for such planning applications. (LDC, Cllr V Ient)  Restricting residential conversions to local workers’ housing artificially constrains local communities, and is therefore inconsistent with the NPA’s Duty to foster the wellbeing of local communities, since ‘foster’ means ‘promote the development of’ and this cannot be realised where entrants to a community are predetermined by an unrelated authority.  Instead of restricting housing to local workers, should restrict it to housing which is a primary residence (not second home)  Policy over-restrictive, not compliant with national policy and legislation  To comply with NPPF para 49, there should be a presumption in favour of sustainable development for housing applications regardless of settlement boundaries.  Should cover all redundant rural buildings, not only agricultural/forestry buildings, to match NPPF para 55. (Various individuals)  Should make more acknowledgement that conversion to residential can be acceptable (Various individuals)  Older and some new country houses are generally found attractive and modern farm complexes are thought of as blots on the landscape. Where the latter are redundant they should be converted to open market housing where it can be demonstrated that the landscape benefit outweighs the status quo or the landscape harm that might result from commercial conversion. (Various individuals)  Policy should also allow for redevelopment of agricultural buildings, especially where stemming from Whole Estate Plans, or where built form and environmental impact would be reduced from the status quo. Ref. appeal decisions. (Various individuals)  In many cases, conversion to residential use without an occupancy restriction is likely to be the optimum viable use for an historic building  Question how ‘local worker’ would be defined, how it would be decided if the need to be accommodated outside settlement boundaries, and what would happen if they changed jobs.

462 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Residential conversion should be encouraged as part of the national drive to provide more housing.  Any action by Government to interfere with the market is to be avoided.  Change criterion 1(g) to read ‘residential uses will be permitted where special circumstances can be demonstrated’

463 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD42: Infrastructure There were a total of 18 representations on this policy. A summary of the main issues raised is set out below.

National agencies Portsmouth Water: Should mention regional infrastructure and the benefits of green infrastructure as part of regional ecological works outside the NP perimeter. Promote potential reservoir at Havant Thicket. Thames Water: General support. Propose adding the following text: “Developers will be required to demonstrate that there is adequate water supply, waste water capacity and surface water drainage both on and off the site to serve the development and that it would not lead to problems for existing or new users. In some circumstances it may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing water and/or waste water infrastructure. Drainage on the site must maintain separation of foul and surface flows. Where there is an infrastructure capacity constraint the Council will require the developer to set out what appropriate improvements are required and how they will be delivered.”

Borough, City, County and District Councils

 Support (Winchester City Council)  Welcome the clarity provided by the Position Statement on the A27 corridor. Would welcome collaborative approach between SDNPA and Highways England on proposals for M3 Junction 9. Would welcome reference to this scheme in the supporting text. (Hampshire County Council)

Parish and Town Councils

 Support (Selborne PC)  Support, in particular the emphasis on infrastructure delivery being integrated with development phasing. (Liss PC)  Major road building which reduces the flow of traffic into and through the National Park should be supported, even where there is an environmental cost to it (Amberley PC)

Other organisations

 General support (Angmering Estate)  Policy should include potential Arundel bypass (Angmering Estate)  Support minimisation of infrastructure impact and specific reference to strategic road proposal approach. (Campaign for National Parks)  Should insert a criterion summarising the Position Statement on the A27 and refer to it, bringing it into the frame of a development plan policy. (Folkington Estate)  Criterion 1 welcomed (Lewes District Green Party)  Support. Reassured by reference here to the approach to strategic road schemes. (south Downs Society)

464 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Criterion 1(b): amend to ‘The design minimises the impact on conserves and enhances the natural beauty…’ for consistency with the landscape-led approach of the rest of the local plan. (Wildlife Trusts)  Local Plan should identify settlements where infrastructure is over-stretched, and reject all further planning applications there until the infrastructure problems are resolved.  Too early to say whether CIL will be effective in covering the infrastructure funding deficit. Alternative sources of funding needed, including commercial sponsorship, and increased/ new Council charges to residents and visitors. Developers will be re  Plan should state current usage and capacity of the existing sewage treatment, telecoms, social and parking infrastructure. Developers should be required to demonstrate the adequacy of existing infrastructure or provide for additional infrastructure. <>

Individuals

 Criterion 1(a): Not necessary or justified- goes beyond NPPF- does it require an EIA type exercise?  Criterion 1(a): Not effective: ‘least environmental harm’ not clearly defined. If it is related to the NP Special Qualities, it should state impacts on the special qualities, rather than least environmental harm. Alternative wording proposed.  Paragraph 7.219: Add the text ‘presumption against major infrastructure in the National Park except in exceptional circumstances’.  Fully support proposal to protect the environment regarding major infrastructure development. Major road building schemes would cause damage to the National Park disproportionate to the economic benefits. (Lewes District Council, Cllr Victor Ient)  Criterion 1, paragraph 7.222: The phrases ‘Least environmental harm’ and ‘minimises impact’ should be replaced by something more affirmative on conservation and enhancement.

465 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD43: New and Existing Community Facilities There were a total of 17 representations on this policy. A summary of the main issues raised is set out below.

National agencies No comments received

Borough, City, County and District Councils

 Criterion 2: amend to include requirement for any alternative community facilities to be of an equivalent or better quality. (East Hampshire District Council)  Supporting text should define ‘local need’ - including reference to meeting the social, recreational and cultural needs of the community, or providing for older and younger people, and set out how such a need can be demonstrated. (West Sussex County Council)  Supporting text should state that proposals affecting waste management facilities will be considered against the relevant Waste Local Plan. (West Sussex County Council)  Should stress need to meet all policy requirements, or refer to the need for appropriate design. (Winchester City Council)

Parish and Town Councils

 Policy particularly important and welcome in rural villages (Buriton PC)  Support, in particular where it relates to new recreational facilities. (Iford PC)  Criteria for provision new community facilities should be more general for development within settlement boundaries (Liss PC)  Criterion 2: Remove text ‘…or have an unacceptable adverse impact upon…’. (Selborne PC)

Other organisations

 Unclear how the policy relates to settlement boundaries. (CPRE Sussex, South Downs Society) ‘Where the settlement which the community facility serves has a boundary, then the facility should be located within or adjacent to that boundary.’  Community faciltiies outside settlement boundaries should be permitted in appropriate cases where they serve the adjacent settlement and there are no suitable sites within that settlement. (South Downs Society)  Criterion 1: Support, although object to a potential conflict with SD23 with regard to public houses, where expansion may cater primarily to tourists rather than meeting a local need. Add the words ‘or complies with another relevant policy in the Plan’ onto criterion 1(a). (Hall & Woodhouse Ltd)  Criterion 2/Appendix 3: Unsound; remove the requirement in Part 2 of Appendix 3 for a demonstration of financial non-viability, which is not stated in Criterion 2. A robust marketing campaign that is unsuccessful would be enough to demonstrate non-viability. (Hall & Woodhouse Ltd)

466 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Appendix 3: Para. 2.4 criterion (c): add ‘if appropriate’ at the beginning; on-site marketing boards can divert away trade and business from a facility. (Hall & Woodhouse Ltd)  Support, as a landowner (Hampshire County Council)  (also SD57) Should recognise existing community facilities on the North Street Estate and try to rehouse them in the new development. (Lewes District Green Party)  (also SD79) Should make provision for new community facilities at Old Malling Farm to address local deficit. (Lewes District Green Party)  Include active support for community renewable energy generation in this policy. (South Downs Society)

Individuals

 Support; multi-use facilities could benefit rural communities, though would need careful management (Hampshire County Council, Cllr Jackie Porter)  Vague and not focussed enough on new facilities. No mechanism for requiring development to provide new community facilities. SDNPA should produce a template for NDPs on the provision of new community facilities.  No clear guidance on new community facilities outside settlement boundaries. These should be permitted in appropriate cases where they serve the adjacent settlement and there are no suitable sites within that settlement. (Lewes District Council, Cllr Victor Ient)  Should use the phrase ‘conserve and enhance’ rather than ‘would not have an adverse impact’, to remedy historic damage done. In particular relates to criterion 2(b).  Support references to Assets of Community Value and Article 4 directions.

467 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD44: Telecommunications and Utilities Infrastructure There were a total of 15 representations on this policy. A summary of the main issues raised is set out below.

National agencies No comments received

Borough, City, County and District Councils

 Insert additional criterion 1(f) ‘They do not have a negative impact on neighbouring properties and/or uses’. (East Hampshire District Council)

Parish and Town Councils

 General support (Rowlands Castle PC, Selborne PC)  Welcome emphasis on mitigating impact of existing infrastructure (Liss PC)  Support emphasis on need for superfast broadband (Liss PC, Madehurst Parish Meeting, Elsted and Treyford PC)  Improved broadband and other infrastructure would not be supported as a ‘trade-off’ for a development that would otherwise be deemed inappropriate. (Madehurst PC)  Need to find additional funding for broadband, existing funding may not permit undergrounding as well as rapid roll out. (Elsted and Treyford PC)  Should strike a balance between planning requirements and the viability of infrastructure enhancements, especially for farmers. (Rowlands Castle PC)  Paragraph 7.236: first sentence- should end ‘special qualities of the National Park’. (Selborne PC)  Paragraph 7.238: refer to ‘placed underground’, not ‘undergrounded’. (Selborne PC)  Request commitment to promote basic minimum broadband speed of >10Mbps, in addition to superfast. (Stedham with Iping PC)  Should emphasise benefits to reduced transport resulting from improved broadband (Stedham with Iping PC)  Use opportunity of new developments to enhance internet to neighbours. (Stedham with Iping PC)

Other organisations

 General support (South Downs Society)

Individuals

 Criterion 1: should amend to ‘development proposals… are actively encouraged with a presumption of support, and will be permitted…’  Criterion 1(a)- should delete; unsound, biased against new infrastructure

468 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Criterion 1(b)- replace with ‘it can be demonstrated that they have been selected as the most appropriate solution taking account of all reasonable alternatives’ (intended to include use of existing infrastructure)  Fully support  Propose for septic tanks be registered on every new planning application, to make the SDNPA aware of the systems in use and their impact on the environment. Advise on or require updates to septic tank systems when changes to properties are made (Hampshire County Council, Cllr Jackie Porter)  Minimise overhead telecoms wires and masts; preference for burying cable. Resist local drop wires too in sensitive areas. (Lewes District Council, Cllr Victor Ient)  Work with other National Parks and mobile operators to find solutions to 4/5G mobile provision that do not harm the National Park landscape. (Lewes District Council, Cllr Victor Ient)  Make clear who is responsible for providing superfast broadband infrastructure- it should not be individual developers in rural areas.  Add clear and correct definition of ‘’superfast broadband’ to the glossary. Current reference to 100Mbps is incorrect.  Utilities should enhance the NP, not just avoid an adverse impact. Need to change the policy so as to prevent the use of standardised, urban designs.  Paragraph 7.241 is well phrased regarding landscape enhancement.  Not enough about anticipating the rapid change of technology over the plan period, for example promoting fast broadband speeds for local communities in general (as opposed to new development) by working proactively with other bodies.

469 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD45: Green Infrastructure There were a total of 29 representations on this policy. A summary of the main issues raised is set out below.

National agencies Environment Agency: Supports this policy. Natural England: Requests that reference to the Green Infrastructure Framework is re-instated in the Local Plan with provision to embed the Framework into the Local Plan. The Framework area stretches beyond the National Park boundaries, into the neighbouring LPAs and therefore provides an exemplar opportunity to secure a joined-up, landscape-scale approach to Green Infrastructure from a robust evidence-base. Portsmouth Water: Considers that the benefits of the Havant Thicket Winter Storage Reservoir application should be mentioned in this section. This could assist future green infrastructure provision immediately adjacent to the National Park and reduce visitor pressure on the South Downs and the protected harbours. Borough, City, County and District Councils

 Welcome a policy on Green Infrastructure. The South Downs Way Ahead Nature Improvement Area (NIA) which seeks to protect chalk grassland should be referenced in this policy as should the Brighton and Lewes Downs Biosphere Reserve (also known as "The Living Coast"). (Brighton and Hove City Council)  Support this policy. (Horsham, Mid Sussex and Winchester District Councils)

Parish and Town Councils

 Welcome this policy. (Buriton, Liss and Selbourne Parish Council, Madehurst Parish Meeting, Petersfield Town Council)  Specific reference should be made to the Itchen Valley as strategic green infrastructure. (Twyford Parish Council)

Other organisations

 Welcome a policy on Green Infrastructure, however reference to the role of community food growing projects as an element of green infrastructure should be included in this policy. (Brighton & Hove Food Partnership)  Request an additional criterion in this policy to protect the South Downs Way Ahead Nature Improvement Area, and the Brighton and Lewes Downs Biosphere Reserve. (Brighton & Lewes Downs Biosphere Partnership)  Support this policy. (Eastbourne Downland Group, Lewes District Green Party, Petersfield Town Development Committee, South Downs Society, Sussex and Hampshire Wildlife Trusts, and The British Horse Society)  Support this policy as the proposal at Bohunt Manor would fully meet the criterion providing a strategic cross boundary green infrastructure resource. (Green Village Investments) Individuals

470 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Support this policy. (Various individuals and Cllr Jackie Porter, Hampshire County Council)  Consider criterion 1b) and the requirement to ‘meet the needs of existing communities’ does not relate to a site-specific impact and is therefore unsound and contrary to National Policy.  Request equestrian use is included wherever recreational and leisure walking and cycling activities are mentioned.

471 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD47: Local Green Spaces There were a total of 63 representations on this policy. A summary of the main issues raised is set out below.

National agencies No Comments received. Borough, City, County and District Councils

 Welcome the designation of Green Ridge as a Local Green Space (LGS). (Brighton and Hove City Council)  Object to the inclusion of LGS6, Land at Common View (Allotment Gardens) in Stedham as LGS as these are not statutory allotments and the site is not accessible to all for recreational purposes. (West Sussex County Council)

Parish and Town Councils

 Disappointed that a number LGS’s identified in earlier versions of the Local Plan have been removed, in particular the Pickle Lane site in Weston as it has historic, public access, wildlife and tranquillity benefits. (Buriton Parish Council)  Welcome that two of the three the sites put forward by the parish council for designation as LGS have been accepted. However, land at The Fridays, part of which is allocated for housing, should not be available for development. (East Dean & Friston Parish Council)  Object to the decision to exclude three areas within Hambledon from LGS designation, i.e. Mason's Field and The Donkey Field which are both used for village activities; and The Whitedale 'Millennium' Field which has a magnificent view across the valley to the hangars and is a rare, unspoilt flower meadow. (Hambledon Parish Council)  Support this policy but consider that this policy should also make reference to LGS designated in Neighbourhood Plans. (Liss Parish Council)  Strongly support the LGS designations in Selbourne. (Selbourne Parish Council)  Additional LGS’s will be designated in the Stedham with Iping Neighbourhood Plan. (Stedham with Iping Parish Council)

Other organisations

 Support this policy. (Various organisations)  Strongly oppose the inclusion of LGS8 – Dowlings, Little Mead and Church Meadow as LGS’s as they do not fulfil the NPPF criteria for designation. (Derek Warwick Developments Ltd)  Object to the inclusion of Tide Mills as LGS as it fails to accord with NPPF criteria for designation in that it is already protected by its location within the National Park, it is not located in close proximity to the community serves and it is an extensive tract of land. (DMH Stallard LLP on behalf of Newhaven Port & Properties)  Object to the inclusion of LGS94, The Horsefield and LGS 96, Went Way Allotments in East Dean as LGS as these sites do not fulfil the NPPF criteria for designation. The sites are

472 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues already protected by existing designations, there is no public access and LGS 94 is an extensive tract of land. (The Gilbert Estate)  Support the designation of Speltham Down (1) and (2) in Hambledon, Half Moon Covert in Midhurst, Dowlings Little Mead and Church Meadow in Selbourne and Top Playing Field, The Forge Field, Jubilee Orchard and The Allotments in Slindon. Also agree that High and Over, part of Seaford Head Nature Reserve and the Village Field in Slindon should not be designated as LGS as they do not comply with the criteria identified in para 77 of the NPPF. (National Trust)

Individuals

 Strongly support the application for Baynards Field in Steyning to be designated as a LGS as it meets all the NPPF criteria. There are many studies and reports on its landscape and historical/heritage importance, including the Conservation Area Appraisal and Review that Horsham District Council carried out this year. This identified Baynards Fields as highly sensitive in the Conservation Area Fringe. Public consultation in the Steyning, Washington, Ashurst and Bramber (SWAB) area showed that 85% of residents are opposed to house building in the National Park area. (A large number of individuals)  Object to the proposed inclusion of Half Moon Covert (Midhurst) as a LGS, as it does not meet NPPF criteria for designation in that it does not contain any statutory wildlife designations and there is no public access to it.  Strongly support the LGS designations in Selbourne. (Various individuals)  Not enough LGS’s have been designated given the size of the National Park.  Object to the site at Burlands Field Selbourne, being designated as LGS, as it does not meet the NPPF criteria. It would be more suitable for housing.  Land south of Church Road in Steep should be designated as a LGS to ensure public access to it.  Barn Field, also known as Under the Hill in Selbourne should be designated as a LGS as it meets the NPPF criteria for designation and its value has been recognised by a Planning Inspector and in the Selborne Village Design Statement and Local Landscape Character Assessment.

473 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy: Introduction to climate change There were a total of 4 representations on the introduction to this section. A summary of the main issues raised is set out below.

National Agencies No comments received. Borough, City, County and District Councils

 Welcome the inclusion of policies on renewable energy, sustainable development and content on Electric Vehicle Charging. (Chichester District Council) Parish and Town Councils

 Minor rewording suggested to para 7.273. (Selbourne Parish Council) Other organisations

 Consider that this section is unsound as it is not consistent with national policy in that the risk of wildfire has not been considered within this section or appropriately cross referenced with relevant sections, including; Green Infrastructure, Agriculture and Forestry, Landscape, Biodiversity or relevant affected communities. Paragraph 164 of the NPPF is specifically quoted. Advise that the SDNPA works with the South East England Wildfire Group (SEEWG), as well as the relevant Local Resilience Forums to address the NPPF requirements. Additionally SDPNA should address paras 94, 99 and 156 of the NPPF which are linked to climate change in terms of wildfire. (Forestry Commission)

Individuals

 Consider that climate change should be the foundation of the Local Plan and therefore this chapter should be leading the way as it applies to all polices.

474 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD48: Climate Change and Sustainable Use of Resources There were a total of 24 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Environment Agency: Support the inclusion of this policy; in particular the direct reference to water efficiency standards and that the tighter standard of 110 litres per person per day has been chosen for residential use. Given the recognition that the SDNP is located in a part of the country recognised as being at serious water stress and the fact that the tighter water efficiency standard has been chosen for residential use, we would have expected to see the tighter standard also being proposed for non-residential use i.e. a BREEAM ‘excellent’ rating as opposed to the ‘very good’ rating. Portsmouth Water: Highlight that in their forecasts for water consumption the target is 125l/h/d as opposed to 110 l/h/d in the Local Plan. Point out that the section ‘On-site Water Use’; Paragraph 7.282 is incorrect as Portsmouth Water’s area of supply is not classified as an area of serious water stress. Borough, City, County and District Councils

 The policy should require major commercial development to meet BREEAM Excellent rather than just Very Good. (Chichester District Council)  Consider that the policy requirements of SD48 are unreasonable for householder applications. (East Hampshire District Council)

Parish and Town Councils

 Enforcing these targets should not be at the expense of the architectural merits of the existing housing stock. (Fernhurst Parish Council)  Support this policy. (Liss, Madehurst, Rowlands Castle and Selbourne Parish Councils)  Overall certain points are welcomed but consider that the energy reduction aspects of this policy are not ambitious enough and should aim for Passivhaus or zero carbon standards. (Petersfield Town Council)

Other organisations

 General support for this policy, however concerned that the policy does not recognise that some forms of low carbon technology (e.g. solar panels on buildings and wind turbines) could have a detrimental impact on the scenic beauty of the National Park. (Angmering, Brighton and Hove Council's Downland Estate, Leconfield and West Dean Estates)  Disappointed that the positive words in the supporting text about meeting high environmental standards in construction, and specifically BREEAM, are disappointingly not carried through into the policy text. There should also be a stronger encouragement to the incorporation of renewable energy measures in new developments. (CPRE Sussex and South Downs Society)  Supports this policy (Eastbourne Downland Group)

475 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Welcome criteria 3, 4 of this policy as they reflect what is practically achievable now. However, the requirement to reduce carbon from residential buildings by an additional 19% compared to Part L of the Code for Sustainable homes is not ambitious enough. The ambition should be that all new developments, including non-residential buildings are zero carbon, including embedded emissions in building materials. This policy should cross reference SD3, which requires major developments to be Zero Carbon. (Lewes District Green Party)  Disappointed to see that an issue as overarching as climate change is placed so close to the end of the plan. Would have liked to see a more strategic policy relating to climate change mitigation and adaptation in the Thriving Living Landscape section of the plan. Strongly support the proposed adoption of the optional water efficiency requirement of 110 l/pppd, which exceeds the Building Regulations requirement of 125l/pppd. Recommend that the reference to viability is removed from part 2 of the policy. (Sussex and Hampshire Wildlife Trusts)  No mention is made of the collection and use of rain water and domestic grey water. (Midhurst Society)

Individuals

 The principles set out in Policy SD3: applying to major development should apply to all developments. Concern over climate change seemingly relegated to a latter section (7k) of main development management chapter. SD48 has low targets and the move should be towards a carbon-neutral National Park and an enhanced environment. The policy targets should be more joined up with that of national agencies and utility companies.  Support this policy, as building and adapting to the highest standards feasibly possible will go some way to mitigate climate change. (Hampshire County Council, Cllr Jackie Porter)  Consider that the policy requirements are not strong enough and should be much clearer as to what is required from each development. Recommend that all new developments to include electric car charging points within the development which would help the Government move towards its 2040 electric car target. (Lewes District Council, Cllr Victor Ient)

476 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD: 49 Flood Risk Management There were a total of 11 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Environment Agency:

 Support inclusion of the flood risk management policy.  However, consider that the current wording of the policy is not as effective as it could be in terms of directing development to Flood Zone 1 and incorporating the recommendations from the Level 1 Update and Level 2 SFRA Final Report regarding what a site specific flood risk assessment should cover.  Specifically, the supporting text in para 7.286 is not in line with the requirements of footnote 5 to paragraph 103 of the NPPF and the last sentence of this para requires rewording to clarify that advice on flood risk should only be sought from the EA where the sources of flooding include fluvial and tidal flood risks and that advice from the Lead Local Flood Authority, Local Authority and relevant water company should be sought on local sources of flooding (e.g. surface water, groundwater, sewer).  Suggest revised wording to address these issues as follows: ‘and directing development to Flood Zone 1, wherever possible’ is included in criteria 1a of SD 49, that the Recommendations for a Site Specific Flood Risk set out in Box 5.1 page 43 of the Level 1 Update and Level 2 SFRA Final Report is included in the wording of Strategic Policy SD 49 and revisions are made to para 7.286.

Borough, City, County and District Councils

 Request amendments to para 7.286 so that it is consistent with para 103 of the NPPF regarding when a site specific flood risk assessment is required and that the ‘Guide to Sustainable Drainage in East Sussex’ is mentioned in the supporting text or footnotes. (East Sussex County Council)  Pleased to see that flooding is covered. (Hampshire County Council)  Criteria 1c should be amended to state a preference for Natural Flood Management over engineered solutions. (Sussex and Hampshire Wildlife Trusts)

Parish and Town Councils

 Policy needs to be more explicit and ensure that no development is permitted within flood plains or locations prone to flooding. (Fernhurst Parish Council)  Support this policy. (Liss and Selbourne Parish Councils)  There is a need to refer in para 7.290 to the role of the District as well as County Councils in supporting Flood Plans. The wording of SD49.1 - “steering development away from areas of flood risk.” should be strengthened. As Flood Action Groups become a stronger feature in local communities they should play an advisory role in planning applications which fall within sensitive zones. (Rowlands Castle Parish Council)

477 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues Other organisations

 Welcomes this policy. (Lewes District Green Party and South Downs Society)

Individuals

 Flood risk management (para7.287) gives the opportunity to enhance the National Park landscape and the goal should be for decreasing surface water run-off.

478 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD50: Sustainable Drainage Systems There were a total of 12 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Environment Agency: Support the inclusion of this policy. However, with reference to para 7.296, the EA does not need to be consulted regarding the suitability of SuDS. Suggest removal of reference to EA. Natural England: Support policies promoting good practice such as Sustainable Urban Drainage (SuDs) Portsmouth Water: Requests the inclusion of additional text in para 7.294 regarding requirements for deep bore soakaways systems.

Borough, City, County and District Councils

 Recommend amendments to the policy wording as LLFAs are only required to comment on ‘major’ development proposals, and the LLFA does not have the power to ‘require’ SUDs but only for them to be considered. Suggest revised wording for the second sentence of criteria 2 of this policy to ‘give priority to’ the use of suitable sustainable drainage systems and remove reference to being required by LLFA’s. Also suggest revised wording for para 7.295 that LLFA’s are only consulted when there is a high risk of surface water flooding. (Hampshire County Council)

Parish and Town Councils

 Support this Policy (Liss and Selbourne Parish Councils)  Request paragraph 7.294 to be amended so that when considering the use of deep borehole schemes these do not lead the surface water into aquifers or ground with solution features. (Rowlands Castle Parish Council)

Other organisations

 Welcome this policy (Lewes Green Party and South Downs Society)  Welcome this policy, in particular the requirement that SuDS should seek to enhance biodiversity and that arrangements should be put in place for their whole life management and maintenance. Suggest additional information is provided on: the maintenance, management and design of SuDs including through the provision of Service Level Agreements with local land management or nature conservation organisations; that SuDs are designed to protect water quality and greater recognition is given to the role natural management features. (Sussex and Hampshire Wildlife Trusts)  Consider that the policy misses a number of opportunities to promote SuDS more effectively within the plan in order for it to provide a robust line on delivery as well as clarity to planning officers and developers. These opportunities include: providing the definition of sustainable drainage given in Schedule 3 of the Flood and Water Management Act 2010;

479 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues requiring SuDS to achieve greenfield run-off rates for all previously undeveloped sites and developed sites; encouraging retrofitting of SuDS to existing development, listing all the multi-functional benefits SuDS can provide and referencing these in more policies such as SD9, SD14 and SD17. (Wildfowl and Wetlands Trust)

Individuals

 Welcome this policy but consider it could be more sustainable and the inclusion of the wording “where feasible” is a let-out loophole.

480 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD51: Renewable Energy There were a total of 21 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Historic England: Welcomes and supports this policy.

Borough, City, County and District Councils

 Welcome this policy but recognition could also be given to Hydrogen Fuel Cells. (Brighton and Hove City Council)

Parish and Town Councils

 Supports this policy (Liss Parish Council)  Supports this policy but the word unacceptable in criteria 2.c) should be removed as it is unnecessary. (Selbourne Parish Council)

Other organisations

 The support offered to estates and farms by this policy is encouraging. The policy should give more explicit support to schemes that do not have a landscape impact e.g. the Archimedes Screw that was recently installed at Coultershaw Bridge near Petworth. (Angmering, Leconfield and West Dean Estates)  Request the policy is amended to make it clear that the major development test should apply to large scale renewable energy developments. (Campaign for National Parks)  Support this policy but suggest an amendment to criteria 1.c) to include the wording ‘minimal loss’ as in some instances there may need to be a minor loss of high quality agricultural land. (Countryside Landowners Association)  Support this policy, however the wording could be misread to allow inappropriate schemes. (Eastbourne Downland Group)  Support this policy in general but concerned that the policy does not address the effects of biomass schemes, such as wood burning on air quality. (Friends of Lewes Society , Lewes District Green Party and The Midhurst Society)  The plan should also encourage small scale schemes such as solar arrays on pitched roofs, small scale hydro-electricity, small wind turbines on farms, community heating systems and ground-source heat pumps. (Lewes District Green party and The Midhurst Society)  Strong concerns as the policy seems to offer almost unconditional support to major renewable energy schemes whatever their impact. Request that the policy only deals with schemes of modest impact. Support should also be given for community renewables.(South Downs Society)

481 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues Individuals

 All new housing and business sites should be ‘future proofed’ to ensure that parking facilities contain electric vehicle charging points in light of the Government’s support for electric vehicles and rapid advances in battery technology. (Chichester District Council, Cllr Andrew Shaxson)  Support this policy but consider that it is negated by paras 7.302 to 7.307 (Hampshire County Council, Cllr Jackie Porter)  Greater recognition should be given to other forms of renewable energy such as air source and ground source heating, solar tiles. Developers should include a renewable energy plan in support of their applications. If all developments contain a renewable energy fuel source there will be less pressure for large scale schemes. (Lewes District Council, Cllr Victor Ient)  Support small scale and well-sited renewable energy schemes e.g. solar panels on buildings and not open fields. Do not agree that high quality agricultural land should be protected over and above biodiverse-rich land. Biomass should be locally sourced renewable supplies not landscape insensitive-intensive crops.

482 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD52: Shop Fronts There were a total of 8 responses to this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Support

Borough, City, County and District Councils No comments received.

Parish and Town Councils

 Support (Fernhurst PC, Liss PC, Selbourne PC)  Support hand painted signs (Midhurst TC)  Replace ‘required’ with ‘essential’, part 4 of SD52 (Selbourne PC)

Other organisations

 Section out of place between Climate Change and Pollution. (Friends of Lewes Society)  The title should be changed to “Shop fronts and Advertisements”. (Friends of Lewes Society, Selbourne Parish Council)  Should be much stronger link back to Historic Environment Chapter (Friends of Lewes Society)  Supports / Supports Society existing policies (Friends of Lewes Society, South Downs Society)

Individuals

 Need to take opportunities to restore / enhance street scene, joined up policy with police and highways.

483 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD53: Adverts There were a total of 10 responses to this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Support Borough, City, County and District Councils

 Criterion 3 include reference to avoiding vertical light spillage / dark skies. (East Hampshire District Council) Parish and Town Councils

 Support (Fernhurst PC, Liss PC, Selbourne PC)  Replace ‘required’ with ‘essential’, 3) of policy (Selbourne PC) Other organisations

 All references to ‘adverts’ should be replaced with ‘advertisements’ (CPRE Hampshire, Selbourne PC)  Support (Friends of Lewes Society, South Downs Society) Individuals

 Area of Special Advertisement Control should cover all National Park,  Policy does not cover proliferation of signs for events and resulting cluttering and littering.

484 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD54: Pollution and Air Quality There were a total of 16 responses to this policy. A summary of the main issues raised is set out below.

National agencies No comments received.

Specific consultation bodies – other local authorities

 Criterion 3) add that new development leading to the declaration or extension of an AQMA might lead to that development being resisted in the first instance. (Chichester District Council)

Parish and Town Councils

 Support (Fernhurst PC, Selbourne PC)  Park should work with other Authorities to mitigate issues. Rumbolds Hill, Midhurst exceeds guidelines in nitrous oxide. (Midhurst Town Council)  Greater mention of noise pollution and impact on tranquillity (Selbourne PC)

Other organisations

 Policy only addresses development control aspects. Most air pollution comes from road traffic / agriculture. The Plan’s absence of any transport strategy means this issue is not considered / plan should seek to reduce traffic across the NP. (Eastbourne Downland Group, Individual)  Ways to move vehicles away from children walking to school should be considered (Cllr Porter)  Mention monitoring station at Lullington Heath (Friends of Lewes Society)  Include requirement that new major commercial development has an air quality assessment plan. (Lewes District Council, Cllr V Ient)  Seek more support for implementing, monitoring and reviewing air quality action plans and dealing with them when they are not working. (Cllr Carter)  Further information on sustaining dark night skies requested.  Development should make a positive impact, insist on improvements, not just seek them.  Support. (South Downs Society)  SDNPA should be more proactive in identifying areas of poor air quality (e.g. Rumbolds Hill / North Street). AQAP may be appropriate. Roadside shrubs and tree planting can help. (The Midhurst Society)

Individuals No comments received.

485 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD55: Contaminated Land There were a total of 5 responses to this policy. A summary of the main issues raised is set out below.

National agencies Environment Agency - Policy should make specific reference to ensuring that unacceptable risk to the environment should be removed/avoided. Para 7.329 should note that the remedial process needs to be undertaken with care so as not to cause contamination to the environment. Portsmouth Water - Add text to highlight the risk assessments and site investigations should be carried out to ensure development is being carried out in a way that protects groundwater quality. Borough, City, Council and District Councils No comments received Parish and Town Councils Support (Fernhurst PC, Selbourne PC) Other organisations

 Support (South Downs Society)

486 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Chapter 8: Strategic Sites There was a total of 2 representations on this chapter. A summary of the main issues raised are set out below.

National Agencies No comments received. Borough, City, County and District Councils No comments received. Parish and Town Councils

 Northfields Farm and adjacent land in Twyford should be allocated as a strategic site in the Local Plan (Twyford Parish Council). Other organisations

 The former ‘Syngenta’ site in Fernhurst should be allocated as a strategic site in the Local Plan as only referring to the allocation in the made Fernhurst Neighbourhood Plan is inconsistent with the NPPF and does not provide certainty. Reference to the allocation in the Neighbourhood Plan is not sufficient (Comer Homes). Individuals No comments received.

487 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD56: Shoreham Cement Works There were a total of 15 representations on this policy. A summary of the main issues raised is set out below.

National agencies Environment Agency: Policy is not currently effective at protecting the environment and mitigating flood risk. Recommends additional criteria is added 1e) requiring a comprehensive assessment of contaminated land and any risks it may pose to water quality and a clear remediation strategy and 1f) redevelopment takes into account is location close to River Adur and ensure protection of water quality. They also recommend addition text in 2 to include more specific flood risk management requirements to include 1) all housing to located in Flood Zone 1, 2) commercial development may be appropriate in Flood Zones 2 and 3 subject to appropriate mitigation measures, 3) development should avoid other low-lying areas within Flood Zone 1 and incorporate appropriate mitigation measures and if necessary the least vulnerable uses should be directed to those areas, 4) finished floor levels of habitable areas to be in excess of 1:100 AEP plus climate change plus freeboard level, 5) Compensatory measures to be provided of any flood defence measures and 5) safe means of emergency access and egress during a flooding event is demonstrated for all developable areas of the site. Historic England: Welcomes the recognition of the opportunity for the interpretation of the history of the site and supports the aims of criteria 1b). Borough, City, County and District Councils

 Would like to be part of any discussions on the Area Action Plan. (Adur District Council and Worthing Borough Council, Horsham District Council)  Would seek to ensure appropriate uses which would contribute to the local economies of Adur and Worthing, to contribute to regeneration and ensure satisfactory environmental and visual restoration of the site. (Adur District Council and Worthing Borough Council)  Surprised to see B2 uses as appropriate uses for the site given they are likely to generate noise and heavy good vehicle movements. (Adur District Council and Worthing Borough Council)  Question whether employment, leisure and tourism uses would generate sufficient value to bring the site forward for development given the significant costs associated with restoring the site and installing the necessary infrastructure. (Adur District Council and Worthing Borough Council)  Notwithstanding concerns about whether the site is a sustainable location for residential development, the policy should include specific reference to residential being an acceptable use on the site. (Adur District Council and Worthing Borough Council)  Supportive of the need to bring forward the restoration of the site however concerned policy does not address the potential impact on the vitality of neighbouring settlements, such as Steyning. Would like additional text added to the policy to ensure that a viable scheme does not impact on the vitality of neighbouring settlements. (Horsham District Council)  Support the policy and request a broad interpretation in respect of ‘local economy’ and ‘local communities’ to recognise that the site could be considered for types of development serving the coastal conurbation. (Brighton and Hove City Council)

488 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues Parish and Town Councils No comments received. Other organisations

 Support the promotion of the site as a strategic allocation for a mixed use development. (The Dudman Group, South Down Project)  Policy should include reference to ‘residential’ and the in absence of any such reference fails to provide the necessary certainty and transparency. There is a need for housing and such a use can help ensure viability and deliverability (The Dudman Group, South Down Project)  The wording of criteria 2c and 3 together with supporting text are unduly restrictive and lack necessary clarity. (The Dudman Group)  Support the approach set out in the policy and stated opportunities and delivers a range of benefits (South Down Project, University College London)  Support the policy however unclear if residential uses are supported. If the intent is to resist residential then the policy wording should be clear. (South Downs Society)  Support the identification of employment needs and support main objective to restore the site. (South Down Project)  Object to paragraph 8.24 as it fails to provide policy context for a ‘self-sustaining eco village’. South Down Project’s aspirations can be realised and incorporated into the policy and Area Action Plan. (South Down Project)  Reference to mineral sites being excluded from the definition of previously developed land is incorrect. The NPPF states any exclusion applies only to minerals sites where provision for restoration has been made through the development control procedures. (Tony Thorpe Associates)  Would like to see full restoration of the site in line with the purposes of the SDNP following the end of its operational activities. (Sussex and Hampshire Wildlife Trust)  Extant permission runs until 2042 with a basic restoration scheme, given the timeline for restoration falls outside the lifetime of the Local Plan concerned about the sites progression to allocation. Potential for the development of the site to lead to slow erosion of the integrity of the National Park. (Sussex and Hampshire Wildlife Trust)  Without the Area Action Plan in place it is difficult to determine the suitability of the site for allocation. Need to clearly answer the question whether developing the site to allow for restoration is less harmful to the National Park’s purposes and special qualities than leaving the site until restoration can be enforced in 2042. The policy does not answer this question. (Sussex and Hampshire Wildlife Trust)  Criteria 3 should be given greater priority. (Sussex and Hampshire Wildlife Trust) Individuals

 Object to the policy, the site should not an opportunity for development but fully landscape restored. Development of the site will lead to further incremental developments and erosion of the National Park’s integrity.  Site is terrible eyesore and should be redeveloped for housing to protect neighbouring communities of Steyning, Bramber and Upper Beeding where farmland and attractive and valued parts of the SDNP are under threat from development. (2 individuals)  Site can make a contribution to the Housing needs of Brighton and Hove, and Adur and Worthing.

489 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Sandiford principle is aimed at protecting greenfield sites with the National Park and should not be used as a justification for greening a major brownfield site that has huge economic potential.  Policy is not proven to be economically viable.  Timing of Area Action Plan should be included in Local Plan.  Employment land allocations should refer to jobs as well as land allocation.

490 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD57: North Street Quarter and adjacent Eastgate Area, Lewes There were a total of 9 representations on this policy. A summary of the main issues raised is set out below.

National agencies Environment Agency: Support the policy but recommend addition text in 3 a) to include more specific flood defence requirements to include 1) adopting a sequential approach to site layout, 2) no development other than Essential Infrastructure or Water Compatible uses in Flood Zone 3b, 3) finished floor levels of habitable areas to be in excess of 1:100 AEP plus climate change plus freeboard level, 4) Compensatory measures to be provided of any flood defence measures and 5) safe means of emergency access and egress during a flooding event is demonstrated for all developable areas of the site. Historic England: Welcomes and supports criteria 3 d) and e) as part of a positive strategy for the conservation and enjoyment, and a clear strategy for enhancing, the historic environment. Borough, City, County and District Councils No comments received. Parish and Town Councils No comments received. Other organisations

 Recognise the need for the policy and welcome the requirement for early provision of the flood defences. (Friends of Lewes Society)  The policy should not include the Wenban Smith building as this is now part of the Lewes Neighbourhood Plan (Houndean Residents Association)  Support the policy (South Downs Society)  Site allocation should be deleted as since planning permission was granted in 2016 no further applications have been submitted demonstrating the site may not be viable or deliverable unlike the land south of Barlavington Way, Midhurst which should be allocated for development instead (ICS Estates Ltd)  Concerned about on-going flood risk as there is evidence that developments that meet the Environment Agency advice are still liable to flood. Suggests additional text to the policy to state that development should make additional provision to prevent buildings and infrastructure flooding under intense rain fall or tidal surges beyond the Environmental Agency’s advice. (University College London)  Recognise that planning permission has been granted but as development has not commenced the scheme could take a different route. (Lewes District Green Party)  Correct factual errors about the age of some of the buildings and recognise that the bus station is a vital asset. (Lewes District Green Party)  Existing creative businesses and community will not fit in low-cost box space work units or the performance hub space. (Lewes District Green Party)  There is no need for more restaurants, cafes or shops and would question the need for office space. (Lewes District Green Party)  Relocation options for existing businesses are not suitable. (Lewes District Green Party)

491 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Policy does not mention the affordable housing requirement, would like to see 50% requirement explicitly mentioned and would like to see a better ratio of affordable rented to shared ownership. (Lewes District Green Party) Individuals

 The policy should not include the Wenban Smith building as it is part of the emerging Lewes Neighbourhood Plan as a housing allocation.

492 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD58: Former Allotments, Alfriston There were a total of 4 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Environment Agency – The policy could be more effective in managing flood risk if it included the requirement for flood storage compensation as recommended in the SDNPA’s Level 1 Update and Level 2 SFRA Final Report. Historic England - Criterion 1 a) should refer to the “special interest, character and appearance” of the Alfriston Conservation Area. Welcomes and supports the recognition of the sensitivity of the site within the conservation area. Borough, City, County and District Councils

 No comments received. Parish and Town Councils

 Alfriston Parish Council broadly welcomes the introduction of affordable housing in the village but has concerns regarding: the deliverability of the site as it is in multiple ownership; part of the site is located in a flood plain and the proposed access is dangerous. Other organisations

 Consider that there are sustainability and deliverability issues with the proposed allocation and that the site at Barlavington Way, Midhurst which performs better in sustainability terms should be allocated instead. (ICS Estates Ltd.) Individuals No comments received.

493 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD59: Kings Ride, Alfriston There were a total of 5 representations on this policy. A summary of the main issues raised is set out below.

National Agencies

 No comments received. Borough, City, County and District Councils

 No comments received. Parish and Town Councils

 Alfriston Parish Council welcomes the development of the site, provided it is done with a design brief. The inclusion of affordable housing is supported. Other organisations

 The ability of the site to accommodate development has not been tested in a LIVIA and land south of Barlavington Way, Midhurst performs better in sustainability terms and should be allocated instead. (ICS Estates Ltd)  Support the policy as it will deliver affordable housing in the village, represents proportional growth, will be become part of the built up area of the village and complies with the NPPF. (Impact Planning Services)  Concerned about the evidence base supporting the allocations, in particular in relation to biodiversity as many of the allocations omit the need for ecological assessment. In addition there are inconsistencies with some sites requiring biodiversity improvements, others biodiversity enhancements and some no biodiversity requirements at all. Also recommend that allocations containing ecosystem services symbols contain a caveat in the policy to ensure that enhancements to natural capital are not limited to those requirements listed specifically in the policy (Sussex and Hampshire Wildlife Trusts) Individuals

 Concerns about asbestos in the roof of the barn and that the existing drainage infrastructure is at capacity.  The site is unsuitable for affordable housing and instead should be developed for houses that are in keeping with the surrounding properties.

494 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD60: Land at Clements Close, Binsted There were a total of 4 responses to this policy. A summary of the main issues raised is set out below.

National agencies No comments received Borough, City, Council and District Councils Hampshire County Council: request pedestrian link from allocation to Footpath 28. Will seek developer contribution towards future maintenance. Parish and Town Councils No comments received Other organisations and individuals

 Land south of Barlavington Way, Midhurst has been subject to a detailed LVIA, Clements Close has not. It is also in a more sustainable community than the site at Binsted. (ICS Estates LTD)  The effect of the settlement boundary around the main village will be to limit development elsewhere and for the other small communities in the Parish to dwindle. The level of development proposed will increase further the pressure on house prices, pricing most people out. Suggest small allocations in the smaller villages and hamlets, total number of homes to increase to approx. 40 and 50% to be affordable.  Allocation is within 5km of Wealden Heaths Phase 2 SPA. A strategic approach to mitigating recreational disturbance is needed. See RSPB comments on SD10. (RSPB)

495 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD61: New Barn Stables, The Street, Binsted There was 1 response to this policy. A summary of the main issues raised is set out below.

National agencies No comments received Borough, City, County and District Councils No comments received Parish and Town Councils No comments received Other organisations and individuals

496 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD62: Land at Greenway Lane, Buriton There were a total of 7 representations on this policy. A summary of the main issues raised is set out below.

National Agencies

 No comments received Borough, City, County and District Councils

 No comments received Parish and Town Councils

 If development goes ahead, should provide a soft landscaped edge to the settlement. (Buriton PC)  Support requirements (a) to (f) in policy. (Buriton PC)  Add requirement to policy for a new foot/cycleway to be provided between the site and Greenway Lane railway bridge- potentially within the field boundary. This would connect the village with the main bus service stop at Greenway Lane roundabout- local bus service to the village is likely to be lost. (Buriton PC)  Re. Kiln Lane alternative site: consider VDS statement on the need not to exacerbate flood risk. (Buriton PC)  Re. Kiln Lane alternative site: site has serious flooding problems, acts as a soakaway to prevent flooding in the village itself, is important to the setting of the village, could casue traffic and road safety problems and necessitate the reintroduction of road signs to the nearby crossroads, and may contain valuable wildlife. (Buriton PC)  If the Kiln Lane site were taken forward, it should be limited to the Preferred Options boundary, the capacity of the local drains increased, should comprise well designed 2-3 bedroom and affordable housing, consider retaining the existing hedgerow to Kiln Lane, and use appropriate traffic calming measures. (Buriton PC)  Consider the increased number of pedestrians likely to use Kiln Lane following the extinguishment of part of Footpath 3. (Buriton PC)

Other organisations

 Propose deletion of the site due to clear adverse landscape impacts and the low rating of the village in the SFA, and its replacement with allocation of land south of Barlavington Way, Midhurst. (ICS Estates)  Evidence base supporting the allocations is insufficient. Ecosystem services approach does not seem to have fed into site selection, but was retrofitted afterwards. Site allocations should be reassessed, including with on-the-ground ecological to ensure existing biodiversity value is properly considered. Inconsistent approach to biodiversity between the different allocations. All allocation policies (not supporting text) should include a requirement for up- to-date ecological information and conservation and enhancement of biodiversity. Allocations containing ecosystem services symbols should contain a caveat in the policy to ensure that enhancements to natural capital are not limited to those requirements listed specifically in the policy. (Wildlife Trusts)

497 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues Individuals

 One representation was made on behalf of three separate landowners of an alternative site at Kiln Lane- logged as three representations, one from each landowner. Key points as follows:  The Kiln Lane site was assessed favourably in both iterations of the SHLAA and proposed as an allocation at Preferred Options. The site has now been withdrawn, apparently due to negative landscape impact, but no reasoning for this change has been given, despite requests- this is unreasonable and unsound.  The Greenway Lane site was rejected from the 2016 SHLAA due to negative landscape impact. Agree with this assessment- the site has a prominent position and is highly visible in views from the scarp slope to S. Propose that the Kiln Lane site has a better relationship to the landscape.  The Greenway Lane site has not been assessed for highway safety. A new access here would be harmful to highway safety and necessary visibility splays for the site would require the loss of significant amounts of hedgerow, contradicting criterion (b) of the policy. This is not the case at Kiln Lane.  The Kiln Lane site is in a more accessible location.  The Kiln Lane site could provide a significant amount of land for wider community benefits, e.g. community parking, allotments and play space. The Greenway Lane site could not.  A community consultation exercise showed that there is strong support for an allocation on Kiln Lane.  Propose deletion of the Greenaway Lane allocation and replacement with an allocation of 8- 10 dwellings at Kiln Lane.

498 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD63: Land south of the A272 at Hinton Marsh, Cheriton There were a total of 7 representations on this policy. A summary of the main issues raised is set out below.

National Agencies No comments received. Borough, City, County and District Councils

 Expect development at this location to provide a contribution towards enhancing the Bramdean and Hinton Ampner Footpath 1 which runs north on the opposite side of the to make a more attractive green travel route (Hampshire County Council). Parish and Town Councils

 Comment that this allocation may impact the parish council’s affordable housing plans (Bramdean & Hinton Ampner Parish Council).  Objection to the policy on grounds: (Cheriton Parish Council) o it does not accord with purposes and duty of the National Park o not consistent with the development strategy, o the quantum is major development, o location to headwaters of the River Itchen SAC, o lack of facilities, o impact on landscape and access problems o flawed and lacking evidence base o a number of specific issues with the wording of the policy which is considered to be imprecise and misleading. Other organisations

 Commented that the site is subject to the following constraints: River Itchen SSSI and SAC, Hinton Ampner House and Gardens, and groundwater flooding from winterbournes. Barlavington Way, Midhurst, does not have these constraints and is a more sustainable site (ICS Estates Ltd).  Support for the allocation on grounds it will support the long term conservation of the Hinton Ampner Estate for wider public benefit and support the purposes and duty of the National Park with regard to housing and recreation space. The National Trust is satisfied that the requirements of the policy can be met (National Trust). Individuals

 Objection to this site on the grounds: (Individual – 18286337) o Not promoted through the call for sites o Unsupported by publicly available assessment to justify deliverability o Unsustainable location with no viable and safe accesses o Rejected in 2016 SHLAA o Potential loss of historic buildings o Lack of facilities and amenities o Not consistent with findings of evidence o Landscape impacts  Objection to this policy on the grounds: (Individual – 18080321)

499 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues o shortcomings with the SA and HRA o proximity of the site to the headwaters of the River Itchen SAC o access problems, o flawed and lacking evidence base, and o a number of specific issues with the wording of the policy which is considered to be imprecise and misleading.

500 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD64: Land South of London Road, Coldwaltham There were a total of 60 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Natural England state that the site lies directly adjacent to Waltham Brooks SSSI and is in very close proximity to Arun Banks SPA, SAC and Ramsar Site. Their key concerns are as follows:

 Concerns over the hydrological impacts on Arun Banks and request that the development be connected to the main sewerage system.  A well-designed SuDs feature is required  The site has been in receipt of Organic HLS for over 10 years. The existing biodiversity value of the site must be ascertained in order to achieve the level of assessment required by the NPPF and to identify potential mitigation/compensation measures.  The remainder of the site left undeveloped should maximise opportunities to maintain biodiversity and seek all opportunities to enhance this.  Notes the intention to provide the residual area of the allocation as accessible, landscaped open space with the primary purpose of providing an alternative to designated sites in the Arun Valley. Concerned that the use of the remainder of the site entirely for recreational use would risk having a deleterious impact on any opportunities maintain and enhance biodiversity.  Advise that the Sussex Wildlife Trust is consulted on this proposal for their views on any impacts on the adjacent SSSI, which they manage.  The number of dwellings delivered at this site should be commensurate with the close proximity of the SSSI/SPA/Ramsar Site and with the existing value of the site for biodiversity.  The NPA will need to demonstrate how the allocation adheres to the mitigation hierarchy required by paragraph 118 of the NPPF namely avoid, mitigate, compensate.  Opportunities to secure a net gain for nature and local communities should be sought, as outlined in paragraphs 9, 109 and 152 of the NPPF.  The NPA should follow the mitigation hierarchy as set out in paragraph 118 of the NPPF and firstly consider what existing environmental features on and around the site can be retained or enhanced or what new features could be incorporated into any potential development proposal. Southern Water commented as follows:

 There is currently sufficient capacity in the water and sewerage networks to accommodate the development.  There is underground water and wastewater infrastructure that needs to be taken into account when designing the proposed development. An easement would be required, which may affect the site layout or require diversion. This easement should be clear of all proposed buildings and substantial tree planting.  The site is also adjacent to Coldwaltham Wastewater Treatment Works (WTW) and there is concern is that the proximity of the new homes to the WTW would have an unacceptable impact on the amenity of the site’s future occupants arising from the WTW’s essential operational activities. It is therefore important that the layout of any development scheme at this site should be informed by an odour assessment, to ensure there is adequate separation from the WTW.

501 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues Borough, City, County and District Councils

 WSCC support the allocation subject to satisfactory Road Safety Audits being carried out prior to the Local Plan examination. Parish and Town Councils Coldwaltham Parish Council commented as follows:

 The policy is unsound because no public consultation took place prior to its publication.  The parish council does not support major development here or at any of the other sites put forward in the village.  The parish council has consulted widely on the scheme and there are significant concerns on both the site and the consultation process.  The parish council supports development which is affordable and would bring new people into the village, especially to support the school.  A housing Survey completed four years ago suggested that the current development of eight affordable houses at Silverdale, Coldwaltham, would go some way to satisfying demand.  Proposes that the SDNPA should consider the potential for small scale developments of 6-8 houses, which would avoid the impact on landscape, traffic and ecology of a new 30 house estate’ in a small community and location.  The status and costs of maintaining the public open space land have not been addressed.  The site is one of only two in the National Park that were judged in the Sustainability Appraisal to have a likely adverse effect on the landscape, which is of high sensitivity in the Arun Valley.  There are a significant number of ecological factors attached to this field.  The Village Plans of 2004 and 2014 rejected large scale development as there is very limited infrastructure, public transport or employment opportunities.  The A29 is a very busy, signposted ‘trunk road’ which carries traffic between the South Coast, via Gatwick and Horsham. Any further access roads from significant housing locations will add to traffic and accident risks, especially at morning and evening peak hours.  This development is extremely upsetting locally. It will result in the coalescence of Coldwaltham and Watersfield and destroy a beautiful view of the South Downs from the A29 (Bury PC) Other organisations The Sussex/Hampshire Wildlife Trust commented as follows:

 The site adjoins the Sussex Wildlife Trust’s Nature Reserve at Waltham Brooks and we therefore have on the ground knowledge of the area.  The Trusts have seen no published evidence which has assessed the biodiversity value/potential of the allocated land itself. There is some high-level consideration of the potential for adverse impact on adjoining and nearby land because they have national and international designations (Waltham Brooks SSSI; Arun Valley SPA/SAC/Ramsar), but none about the site itself or its potential wider contribution to ecosystems services.  Although the Sussex Wildlife Trust has not surveyed the site, a quick visual inspection by their Senior Ecologist has suggested that the site is at least a semi-improved hay meadow, with potential for pockets of acidic grassland. flower-rich hay-meadow. An ecological survey carried out by an appropriately qualified ecologist is required.

502 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 The biodiverse grassland in this location buffers Waltham Brooks nature reserve, acting as part of the National Park’s ecological network and connecting to other nearby designated sites such as Watts Farm Meadow and Alban Head Playing Field Local Wildlife Sites.  The landowner has been in receipt of public funds to create beneficial grassland habitat and this should be weighed in the overall balance of considerations as to whether an allocation is justified.  The existing scale of the need to be met in Coldwaltham does not justify the size of the allocation being made.  No additional criterion has been added to the policy to refer to its phasing to later 5 year periods as indicated as being necessary in the Major Development reports of 2015 and 2017.  Coldwaltham scores poorly in the Authority’s Settlement Facilities Assessment, September 2015. In this regard Coldwaltham does not appear to be a location suitable to meet wider housing needs and provision should be limited to meet specific local needs only.  The provision of 50% affordable housing may not be viable on this site.  The Trusts have seen no published evidence by the Authority as to the likely market interest/viability of a shop in this location  The Trusts welcome, in principle, suitable recreational provision which would help ease recreational pressures on more sensitive habitats, but has seen no analysis to assess whether the size/location/design of the proposed open space would actually fulfil that purpose. The Trusts fear that the opposite may be the case - increased recreational pressures from the additional housing and because the provision of parking and additional open space makes the general location more attractive to walkers.  Paragraph 9.54 of the Plan refers to links to the wider countryside which would only serve to facilitate increased access to the Trust’s reserve. There is already recreational disturbance on the site, particularly from dog walkers. It should be noted that the owner of the allocated site has recently put a gate into the southern edge of the field due to the fence being repeatedly cut, presumably by dog walkers to allow more direct access into Waltham Brooks from the existing housing on Brooklands Way.  The provision of Suitable Alternative Natural Green Space (SANGs) is a now a well- established mitigation strategy where development may adversely impact protected habitats. However, SANGs need to be of substantial scale and carefully designed to ensure that they provide an attractive alternative to the sensitive natural habitat to be protected. The modest size of the open space proposed in policy SD64 raises doubt as to its likely effectiveness. The Trust would welcome a comprehensive approach to this issue and currently views the benefits of this element to be uncertain.  There is doubt as to whether the open space will be delivered as part of the housing development. The SDNPA therefore requires evidence to demonstrate that the new housing would have an unacceptable impact without the open space proposed. The Barlavington Estate commented as follows:

 Supports and welcomes the allocation.  The site is well related to the existing built form and would not result in the coalescence of settlements.  It would not cause adverse harm to the landscape.  The housing figure should be given as a minimum rather than a range.  The reference to ‘open countryside’ to the north in criterion 2b should be deleted as this land is wooded.  Supports the improvements to the public realm in criterion 2j and the removal of the chain fence but notes that this is not within the ownership of the Barlavington Estate.

503 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Supports the concept plan, but notes that this is for illustrative purposes only.  With suitable measures for the protection of off-site SPA, SACs and SSSIs and habitat retention, creation and enhancement, no reduction in the ecological interest of the site or its surrounds is likely to arise as a result of the site’s development.  The site can be safely accessed off the A29.  There are no impediments to delivery and it can be developed in the early part of the plan period.  Does not support this allocation as the site abuts the Waltham Brooks SSSI and is close to an SPA and a Ramsar site which are low lying. Development would impact on landscape quality and threaten biodiversity in this part of the National Park (CPRE Sussex and South Downs Society)  The site at Barlavington Way, Midhurst scores higher in the Settlement Facilities Study and performs better in the Sustainability Appraisal (ICS Estates)  The site is in proximity to the Waltham Brooks SSSI, part of the Arun Valley SPA and Ramsar site. The development is likely to increase recreational pressure on the designated sites significantly and, notwithstanding the conclusions of the HRA, we remain concerned that it cannot be demonstrated that there will not be an adverse impact on the integrity of the Natura 2000 site. The land in question is of high environmental value in its own right, having been managed under agri-environment measures as a flower-rich meadow (RSPB) The Coldwaltham Meadow Conservation Group (CMCG) commented as follows:

 The allocation is contrary to Policy SD1: Sustainable Development as the presumption in favour of sustainable development does not apply to this site.  The allocation is contrary to Policy SD2: Ecosystem Services as it does not include ecosystem services symbols, it cannot provide more, better and more joined up natural habitats and it cannot improve the National Park’s resilience to and mitigation of climate change.  The allocation is contrary to Policy SD3: Major Development as there are no exceptional circumstances and there is no public interest justification.  The allocation is contrary to Policy SD4: Landscape as the development will be an obtrusive blot on the landscape, visible for miles.  The allocation is contrary to Policy SD6: Safeguarding Views as the development would block and spoil key views within the National Park.  The allocation is contrary to Policy SD8: Dark Night Skies as the site is located in the Dark Sky Core.  The allocation is contrary to Policy SD9: Biodiversity and Geodiversity as the development would spoil one of the most biodiverse areas in the National Park.  The allocation is contrary to Policy SD10: International Sites as the site is identified as supporting habitat for barbastelle bats from the Mens SAC. There is no evidence of IROPI that would justify the level of disturbance that the allocation would cause.  The allocation is contrary to Policy SD12: Historic Environment as the allocation fails to recognise the meadow as a heritage asset.  The allocation is contrary to Policy SD19: Transport and Accessibility as the allocation is not designed to minimise the need to travel.  The allocation is contrary to Policy SD22: Parking Provision as the proposed amenity car park will increase traffic in Brook Lane, which is a historic rural road. The new car park will also increase recreational disturbance at the nature reserve.  The allocation is contrary to Policy SD23: Sustainable Tourism as the development will remove the opportunity for people to increase their awareness and understanding of this

504 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues biodiverse cultural heritage asset, which embodies all seven special qualities of the National Park.  The allocation is contrary to Policy SD25: Development Strategy as it is not of a scale and nature appropriate to the character and function of Coldwaltham in terms of its facilities and services.  The allocation is undeliverable.  The appraisal of likely significant effects in the SA is unjustified.  The HRA is deeply flawed. The Wiggonholt Association commented as follows:

 Objected to the previous allocation in the Preferred Options.  The development would have an unacceptably adverse impact on the landscape of the National Park  The development is major development which should not be allowed in a National Park.  Clarity is required on the new parking area and access to the Arun Valley  Criticised the consultation on the proposed site.  It is a greenfield site and development on brownfield land should be prioritised Individuals

 The development will result in the loss of a beautiful and rare flower-rich meadow (several)  The development would impact adversely on the landscape particularly from the higher land south of Amberley and from the South Downs Way (several)  The beautiful view glimpsed from the A29 would be lost (several)  Other smaller sites have been proposed for development and should be developed instead (several)  This is one of two meadows between Coldwaltham and Watersfield and this development would result in the coalescence of these settlements (several)  The development constitutes major development and as there are no exceptional circumstances and it is not in the public interest it should be refuse (several)  The scale of the development is disproportionate top the size of the village and the services it provides (several)  Fair and proper consultation has not taken place in regard to this site as it was not included in the Preferred Options version of the Local Plan (several)  Coldwaltham has been disadvantaged by not preparing a neighbourhood plan (several)  There is a clear conflict of interest in regard to Sir Sebastian Anstruther, who owns the Barlavington Estate and his role as a prominent member of the SDNPA (several)  The development is contrary to Policies SD4: Landscape and SD6: Safeguarding Views (several)  The site currently has no public access and if the open space was opened up in line with the policy it would create an accessible natural greenspace. Local people including school people could become involved in looking after the meadow  If the site is not allocated the whole filed could be ploughed up for cereal production  The alternative sites put forward by the CMCG are made up of medieval assarts bordered by veteran oaks and ancient hedgerows (several)  The alternative sites put forward by the CMCG host a number of protected species including Soprano Pipestrelle Bats (several)  The development of this site is contrary to four of the National Park’s special qualities.

505 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 The Arun Valley is one of the most beautiful and biodiverse areas in the National Park, and the Meadow is one of its most colourful components.  There is a small, but vociferous, pressure group that are determined to prevent any development taking place on SD64.  The alternative sites proposed by the CMCG are unsuitable for development due to problems with access and the presence of protected species (several)  The table that has been produced comparing the alternative sites proposed by the CMCG is inaccurate, factually incorrect and manipulative.  The proposed allocation offers the benefits of a shop, enhanced play facility and access to the meadow.  The Prince of Wales is leading a campaign to save and create wildflower meadows and so this one should not be destroyed.  The proposed site is the most suitable site in the village for development and would provide net gains such as a car parking for visitors.  The CMPG have resorted to publishing false and misleading information on their website in an attempt to whip up support for displacing the entire housing allocation to other sites within the village.  The alternative sites suggested by the CMPG have only recently been put forward and each of them would, if developed, have serious adverse effects on wildlife, biodiversity, landscape value and cultural heritage including the setting of two conservation areas and several listed buildings. There has been no objective assessment of these alternative sites and it is difficult to see how any could now be carried out within the necessary timescales.  There is much local concern about this site being a flower meadow but it should be noted that this concern has only arisen because of the development plans. Previously the site was just seen as an agricultural field and its importance to the village has been grossly inflated.  The impact of development on dark night skies and dark night skies would be much greater at the other sites proposed by the CMPG that the proposed allocation site.  The proposed new access to SD64 would help to slow down traffic on the A29.  The SDNPA should meet with the parish council to discuss the allocation and the alternatives put forward by the CMPG.  The site is an extremely rare hay meadow of which only 3% survive in the UK.  New homes should be built on brownfield sites such as Shoreham Cement Works rather than greenfield sites.  Adverse impact on neighbouring properties.  Does a simple wild flower meadow count for nothing in the face of the developer and his pockets?  Do not believe that the CMCG's campaign represents the views or interests of the village as a whole.  The comparison table published by the CMCG is flawed and misleading. Of the various sites proposed, the SD64 site (site 1) is the most suitable for development. There would be serious problems with developing the other sites including significant extension of the settlement boundary, access issues, impact on ancient fieldscapes, ecological concerns, the visual impact on the landscape and conflict with the precedence set by previous planning decisions.

506 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD65: Land East of Warnford Road, Corhampton There were a total of 2 representations on this policy. A summary of the main issues raised is set out below.

National Agencies No comments received. Borough, City, County and District Councils No comments received. Parish and Town Councils

 The matching of its housing allocation to existing planning consents is welcomed (Corhampton & Meonstoke Parish Council). Other organisations Portsmouth Water: The nature of the location of the site may result in contamination of groundwater. Development at this site is asked to be required to incorporate solution features as a key component of the associated hydrogeological risk assessment to ensure groundwater protection. In addition Portsmouth Water wish to be consulted on such risk assessments (Portsmouth Water). Individuals No comments received.

507 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD66: Land at Park Lane, Droxford There were a total of 10 representations on this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Welcome and support the descriptions of historic environment as part of the positive strategy for the conservation and enjoyment, and a clear strategy for enhancing the historic environment. Also welcome reference to Historic Impact Assessment and/or archaeological assessment. However, Historic England would prefer to see specific reference to Heritage Impact Assessment or Archaeological Assessment or both, with important archaeological remains or other historic features retained in situ wherever possible, or, where not possible, recorded for deposition within a public archive. Portsmouth Water: Site has no mapped karstic features recorded by BGS records nor by LIDAR analysis, however this does not rule out their existence.

Borough, City, County and District Councils

 Welcome point 2.g) of the policy which seeks to prevent no significant harm to the amenity of the route. This will require careful attention to the vehicular access to the site. (Hampshire CC)

Parish and Town Councils

 The following errors are identified: incorrect road name reference, days bus service operative. (Droxford PC)

Other organisations

 There are concerns over the site allocation that points to land at Union Lane being better suited for development. These include harmful impact on historic core, removal of vegetation required for access and visibility, and adverse impact on amenity of the Wayfarers Walk long distance footpath. SHLAA is flawed and contradictory. (Bargate Homes)  The proposed allocation of Land at Park Lane, Droxford should be deleted and the land south of Barlavington Way, Midhurst should be allocated for development instead. (ICS Estates Ltd.)  Site should be reassessed to ensure that the existing biodiversity value has been properly considered. Policy should be reworded to ensure a consistent approach to assessments and net gains, with all allocations including a requirement for up-to-date ecological information and conservation and enhancement of biodiversity. (Sussex/Hampshire Wildlife Trust)

Individuals

508 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 There is already rush hour traffic and traffic associated with school runs on the access roads to the site, which are too narrow to cope with traffic levels. The Park Lane site may be only part of the Droxford housing solution.  Support in principle inclusion of the site. Suggest information box is relocated to be consistent with other allocation policies. 26 to 32 dwellings is unduly restrictive. The site is large and regularly shaped, therefor provides opportunity for at least 35 homes.

509 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD67: Cowdray works yard, Easebourne There were a total of 10 responses to this policy. A summary of the main issues raised is set out below.

National agencies and utility providers Historic England: Welcome and supports paragraph 1 of Policy SD67 as part of the positive strategy for the conservation and enjoyment, and a clear strategy for enhancing the historic environment. However, Historic England would prefer to see reference to Heritage Impact Assessment or Archaeological Assessment or both, with important archaeological remains or other historic features retained in situ wherever possible, or, where not possible, recorded for deposition within a public archive. Southern Water: Assessment reveals that additional local water and sewerage infrastructure would be required to accommodate the proposed development (involving making a connection to the water and sewerage networks at the nearest points of adequate capacity). Request that the need for additional infrastructure at specific sites is recognised within the policy.

Borough, City, County and District Councils No comments received.

Parish and Town Councils

 Easebourne Parish Council has made the following comments: o Support the principle of allocating the site. o Inclusion of the site in the revised settlement boundary is inappropriate, as it allows for potential backland/infill development should the initial scheme fall short of the site boundaries. o Previous consultations did not identify the site, as such there has been no opportunity previously for representations to be made. o The proposed density is out of context with the density and character of the village, and would result in unacceptable harm and impact to the conservation area, landscape setting, biodiversity and (cumulatively with other allocated sites) heritage context. o Existing vehicular access is not appropriate, exacerbated by the limited pedestrian access on the relevant side of the road. Request highways assessment. o Object to likely increase in traffic in relation to residential and commercial development. o Parish Council and community should be consulted on the new footpath proposed. o Seek further security for developer contributions for on- and off-site highways infrastructure. o Request a development brief to be developed, and a concept master plan to be consulted on with the Parish Council and community.

Other organisations

510 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Site is wholly owned by Cowdray Estate which strongly supports allocation as mixed use. Capacity of the site should be expressed as ‘approximately 20 dwellings and approximately 1,500sqm of commercial flooorspace’. (Cowdray Estate)  Site should be reassessed to ensure that the existing biodiversity value has been properly considered. Policy should be reworded to ensure a consistent approach to assessments and net gains, with all allocations including a requirement for up-to-date ecological information and conservation and enhancement of biodiversity. (Sussex/Hampshire Wildlife Trust)  Allocation would put strain on congested and polluted road leading south to and through Midhurst. Traffic easing measures required. Any industrial processes should not cause excessive noise, vibrations or pollution. (The Midhurst Society)

Individuals

 New infrastructure, affordable housing, retail may benefit Easebourne.  Density of housing is too high. Development should preserve and if possible enhance character.  Little provision for affordable housing.  Additional traffic will join congestion on A272 / A286 and add pressure to parking in Midhurst. Concerns over road safety and lack of pavements.  School and surgery in Easebourne are over-stretched / oversubscribed.  Concern over pressure on water supplies, drainage, energy supplies, internet speeds, telecommunications.  Where will new residents find employment? Issue of out-commuting.

511 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD68: Land at Egmont Road (incorporating comment on Easebourne preamble) There were a total of 10 representations on this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Welcome and supports paragraph 1 of Policy SD67 as part of the positive strategy for the conservation and enjoyment, and a clear strategy for enhancing the historic environment. Southern Water: Assessment reveals that additional local sewerage infrastructure would be required to accommodate the proposed development (involving making a connection to the sewerage network at the nearest points of adequate capacity). Request that the need for additional infrastructure at specific sites is recognised within the policy.

Borough, City, County and District Councils

 Support, subject to satisfactory Road Safety Audits being carried out prior to the Local Plan Examination. (West Sussex County Council)

Parish and Town Councils

 Easebourne Parish Council has made the following comments: o New built form in this area will impact on Grade II listed buildings and the conservation area o Site boundary should be redrawn to allow buffer zone to the east of the boundary o 20 dwellings represents too high density; capacity is less than 14 o Over-use of the retained car park will be exacerbated o Access is inadequate to support level of development o A site layout should be undertaken to inform policy/access issues o Request wording to better secure developer contributions for highways and flood risk assessment o This and other sites should be brought forward via a Whole Estate Plan

Other organisations

 Strongly supports the allocation of the site. The capacity of the site at this stage should be expressed as "approximately 20 dwellings". (Cowdray Estate)  Site should be reassessed to ensure that the existing biodiversity value has been properly considered. Policy should be reworded to ensure a consistent approach to assessments and net gains, with all allocations including a requirement for up-to-date ecological information and conservation and enhancement of biodiversity. (Sussex/Hampshire Wildlife Trust)  Allocation would put strain on congested and polluted roads the A286 and A272. Traffic easing measures required. (The Midhurst Society)

512 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues Individuals

 Density of housing is too high. Developments should preserve and if possible enhance the character of the area.  Access via existing school playground is dangerous.  Adjacent land could be released if Conifers School were to move.  Additional traffic will join congestion on A272 / A286 and add pressure to parking in Midhurst. Concerns over road safety and lack of pavements.  Where will new residents find employment? Issue of out-commuting.  No mention of affordable housing.  16-20 homes will overburden existing infrastructure.  With regard to Easebourne generally, no reference to evidence that additional/reinforced school places, medical services, drainage, electrical power, gas, telecommunications will be provided. No requirement for alternative energy sources such as solar and thermal panels, ground source heating, electric car charging, nor carbon-neutral development.

513 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD69: Former Easebourne School, Easebourne There were a total of 13 representations on this policy. A summary of the main issues raised is set out below.

Borough, City, County and District Councils No comments received.

Parish and Town Councils

 Easebourne Parish Council has made the following comments: o Object to allocation of this site. It is majority greenfield land with a Grade II listed building. o The site provides a natural break in built form contributing to the setting of the conservation area. It is only considered deliverable if a visual gap through the centre of the site is retained. Development should be limited to the area of the existing school buildings. o Inclusion of the site in the revised settlement boundary is inappropriate, as it allows for potential backland/infill development should the initial scheme fall short of the site boundaries given public benefit is not outweighed by harm. o The proposed development of 20 dwellings would result in an unacceptably low density of 10 dwellings per hectare. o The option of Conifers School moving to the site should have been considered. o Previous consultations did not identify the site, as such there has been no opportunity previously for representations to be made. o No evidence that proposed access to site is safe. Object to likely increase in traffic in relation to residential development. o Request a development brief to be developed, and a concept master plan to be consulted on with the Parish Council and community.

Other organisations

 Object to exclusion of small part of existing school site to north of school buildings. Capacity of the site should be expressed as 20 dwellings (including dwellings formed htrouhg conversion of the original school building). (Cowdray Estate)

514 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Site should be reassessed to ensure that the existing biodiversity value has been properly considered. Policy should be reworded to ensure a consistent approach to assessments and net gains, with all allocations including a requirement for up-to-date ecological information and conservation and enhancement of biodiversity. (Sussex/Hampshire Wildlife Trust)  Allocation would put strain on congested and polluted roads the A286 and A272. Traffic easing measures required. (The Midhurst Society)

Individuals

 Conifers School in Egmont Road should move to this site such that it can continue in its current use.  Density too high.  Not enough provision for affordable housing.  Not practical to build on the site in transport / parking terms, due to nature of Easebourne Street e.g. no pedestrian walkways, hazardous farm traffic.  Should not treat whole site as former school grounds as most of it is greenfield.  Policy should be more prescriptive regarding line of visual gap. Should preserve views to open countryside.  Development will irrevocably change character, landscape, listed building and conservation area and lead to noise, light pollution and impact on infrastructure.

515 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD70: Land behind the Fridays, East Dean There were a total of 2 representations on this policy. A summary of the main issues raised is set out below.

National Agencies

 No comments received. Borough, City, County and District Councils

 No comments received. Parish and Town Councils

 No comments received. Other organisations

 Consider remaining land to the west of SD70 (part of SHLAA ref. WE002) could accommodate additional development. Do not agree that Land adjoining The Vicarage, East of Gilberts Drive (SHLAA ref. WE001) should have been excluded from the SHLAA on the basis that it could not accommodate 5 or more dwellings as it is 1.56 hectares in size. Also do not agree that Land adjacent to the Village Hall, Gilberts Drive (SHLAA ref WE003), is unsuitable for development just because it is located within the conservation area. Suggest that a Small Sites Allocations document is prepared for sites that can accommodate fewer than 5 dwellings in East Dean. (The Gilbert Estate) Individuals

 The allocation policy is insufficiently detailed compared to other allocations and should be revised.

516 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD71 Land at Elm Rise, Findon There were a total of 8 representations on this policy. A summary of the main issues raised is set out below.

National agencies No comments received.

Borough, City, County and District Councils No comments received.

Parish and Town Councils

 Object to allocation. The Parish Council has set up a working party to review the current made Neighbourhood Plan which will include alternative and more landscape sensitive site allocations to meet the required 30 dwellings for Findon. (Findon PC)

Other organisations

 Findon UNP Working Group: o There are available, deliverable alternative sites with capacity to absorb small scale housing development of around 30 dwellings, in conformity with Policy SD26, where affordable homes to meet local housing need would be more viable, and that would have lower landscape value and sensitivity. These will be included in an updated Findon Neighbourhood Plan which is in the final stages of preparation. o The site proposed for allocation is one of the lowest two ranked sites by a significant margin, from a survey of local residents which received 475 responses. o Properties on the eastern and southern boundaries are at a very low density, therefore proposed development would be out of character with existing built development scale, form and density. o Most of the site is highly visible in the highly sensitive landscape from three viewpoints. o There are local problems with surface water runoff. Shallow soil over chalk does not lend itself to a SuDs design approach. o Stable Lane is located only 100 m south of the site and is a historic lane that has potential to be designated a Quiet Lane.

 The proposed allocation off land at Elm Rise, Findon should be deleted and the land south of Barlavington Way, Midhurst (see photo below) should be allocated for development instead. (ICS Estates Ltd.)

517 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 The allocation is the sequentially preferable site in Findon required to accommodate the housing need, having the greatest capacity to accommodate landscape change whilst viably delivering the required quantum of affordable housing. The allocation boundary should be amended to enable inclusion of additional drainage and open space features, which would also allow more development on the least sensitive western part of the site. The policy should be re-worded to refer to a minimum of 20 dwellings, given there are 24 households in housing need and concerns over deliverability of other sites in Findon. (Seaward Properties Ltd.)

Individuals

 Local consultation has shown that other sites in the village are overwhelmingly preferred to the allocation site, for the reasons that it is a field adjoining other fields. Building on the site would be detrimental to the village and is wholly unnecessary given other sites being available. Reasons for objection include visibility from surrounding areas, current use as paddocks, and increased traffic congestion in village centre. (various individuals)  Concern over flooding risk to existing properties and village arising from proposed development of the site. Water regularly runs down the hill, mud and sludge runoff regularly observed.  There is a large amount of local opposition to the proposed allocation and some uncertainty over deliverability. Alternative sites should be considered to ensure certainty that 30 dwellings can be delivered. (West of Nepcote landowner)

518 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD72 Soldiers Field House, Findon There were a total of 6 representations on this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Welcomes and supports the descriptions of the historic environment of specific sites as part of the positive strategy for the conservation and enjoyment, and a clear strategy for enhancing, the historic environment. However, Historic England would prefer to see reference to Heritage Impact Assessment or Archaeological Assessment or both, with important archaeological remains or other historic features retained in situ wherever possible, or, where not possible, recorded for deposition within a public archive. Borough, City, County and District Councils No comments received.

Parish and Town Councils

 No comments received.

Other organisations

 Findon UNP Working Group: o There are available, deliverable alternative sites with capacity to absorb small scale housing development of around 30 dwellings, in conformity with Policy SD26, where affordable homes to meet local housing need would be more viable, and that would have lower landscape value and sensitivity. These will be included in an updated Findon Neighbourhood Plan which is in the final stages of preparation. o The site proposed for allocation is one of the lowest two ranked sites by a significant margin, from a survey of local residents which received 475 responses. o The building and site are of significant heritage value to Findon and its historic relationship with racehorse training. o Site is within setting of Nepcote Conservation Area which includes Nepcote Green which is the setting for the historic annual sheep fair. A development of 10-12 houses would be highly visible to visitors. o There is no financial viability evidence that redevelopment can better meet local housing needs. There is only enough viability in the site to provide 5 modest sized shared ownership 2/3 bedroom houses, and no dwellings to be provided for affordable rent. o Policy aspiration to achieve long term, sustainable indigenous screening and short term retention of the hedge is not deliverable.

519 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues o The deliverability of SuDs where shallow soil is underlain by chalk is not robustly proven. o Access is privately owned and inadequate for 10-12 dwellings. Redevelopment of the site may need a new parallel access east of Soldiers Field Lane. Public vehicular access to the site access is via narrow sunken lanes not suited to an increase in traffic. o Site is furthest of all sites considered from a bus stop and the village centre, and is outside NPPF guideline distances from local facilities and public transport. o Density of development would be around 4 times that found in the locality. Development would fail to positively enhance the downland landscape and setting of Wattle House, having regard to Purpose 1.

 The proposed allocation off land at Soldiers Field House, Findon should be deleted and the land south of Barlavington Way, Midhurst (see photo below) should be allocated for development instead. (ICS Estates Ltd.)

Individuals

 Support the principle of allocation. Policy should state ‘up to 12 dwellings’ rather than a range. Object to wording ‘planning permission will not be granted for any other uses’ which does not meet the positively prepared test. Object to statement ‘positively enhance the setting of the Wattle House’ which should instead be ‘preserve…’. Requirement to protect all trees on the site boundary should be made more flexible by adding ‘where possible’.

 The proposed development goes against goes against the policy not to encroach on agricultural land, paddocks or green fields in an area of outstanding beauty. It would spoil views of Cissbury Ring and the other side of A24, and negatively impact on wildlife.

 There is a large amount of local opposition to the proposed allocation and some uncertainty over deliverability. Alternative sites should be considered to ensure certainty that 30 dwellings can be delivered.

520 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD73: Petersfield Road, Greatham There were a total of 24 representations on this policy. A summary of the main issues raised is set out below.

National Agencies

Historic England support criterion 2b, and propose inserting a requirement for development to be informed by the Heritage Impact Assessment, Archaeological Assessment, or both, with important archaeological remains or other historic features retained in situ where possible or, where not possible, recorded for deposition within a public archive. Borough, City, County and District Councils No comments received Parish and Town Councils

 Number is too high: represents a 10% increase in number of dwellings in the village, unsustainable due to lack of local facilities. Should by 25 for the village, with 20 on the allocated site and 5 elsewhere. Village has recently lost mobile library. (Greatham PC)  No 4 or 5 bedroom dwellings should be provided. (Greatham PC)  Density is too high compared to the rest of the village. Reduce to 20 dwellings (Greatham PC)  Propose a solar farm on the rest of the site, after reducing dwelling number. (Greatham PC)  Entrance on brow of a hill; request traffic study before any application is agreed. (Greatham PC)  Support requirement for 50% affordable dwellings on site. (Greatham PC)  Would welcome provision of a public open space on site, with an associated cycle/pedestrian route. (Greatham PC)  Want full involvement in decision making about shop provision, bearing in mind past business failures; ‘community type shop’ would be beneficial. (Greatham PC)  Support retention and enhancement of existing trees and new, appropriate site boundaries. (Greatham PC)  Should be in keeping with local heritage assets and CA, should use local building materials. (Greatham PC)  Housing should incorporate sustainable energy capabilities e.g. solar panels. (Greatham PC)

Other organisations

 Site available for delivery within five years. (Cove Homes)  Allow a lower proportion of affordable homes, where 50% is not viable (Cove Homes)  A higher number of dwellings would be suitable on the site, given the dwelling mix requirements and size of the site; see recent pre application proposals. The number of dwellings proposed does not make the best use of PDL. (Cove Homes)  The policy should allow for a care home on site. Local Plan does not currently plan to meet the need for older peoples housing identified in the HEDNA. (Cove Homes)  The policy should not require a shop- no need for a shop in the village (see the marketing report accompanying the application to convert the former village shop to housing). The site is not large enough to justify a shop. Road frontage for a shop will be very hard to achieve so

521 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues passing trade unlikely. Remove reference to a shop, or amend to state that it is dependent on finding an operator for whom it would be viable. (Cove Homes)  A case by case approach to mitigation of recreational impacts on the Wealden Heaths SPA is not workable. Need to amend Strategic Policy SD10 to include a strategic approach to mitigating recreational disturbance, and reference this in Allocation policy SD73. (RSPB)  Additional local sewerage infrastructure would be required to accommodate the proposed development. Need to insert condition requiring a connection to the nearest point of adequate capacity in the sewerage network to be provided, in collaboration with the service provider. (Southern Water)  There is sewerage infrastructure on the site, this needs an easement clear of all proposed buildings and substantial tree planting (Southern Water)  The site is in horticultural use therefore not PDL, so the concept ‘making the best use of PDL’ does not apply. SHLAA assessment as PDL is wrong. (Greatham Voice)  Propose only the portion occupied by a bungalow should be developed, with 30 dwellings, not the portions occupied by glasshouses, thereby avoiding change of use of land, and directing development towards the road, which is more in line with the current grain of development. The east and north areas of the site should be reserved as a buffer zone with the open countryside and Bakers Field. The site currently forms a gap between the denser parts of the village to the NE and the CA to the SW. Adjacent development at Bakers Field not in character with the village. The SA identified that more than 30 dwellings on site would contribute to the SDILCA ‘Forces for Change’. Higher than average density would harm the setting of the village and the CA and the landscape and historical setting. Therefore not appropriate. (Greatham Voice)  Settlement boundary should exclude areas of open space within the site. (Greatham Voice)  Site is worse as a potential allocation than Barlavington Way, Midhurst, and should be discarded in favour of the latter. (ICS Estates Ltd)

Individuals Objections and concerns about the allocation (various individuals), due to:

 Traffic increases; site entrance on brow of hill; area around the site is already very busy at peak times and subject to problem on street parking due to proximity to school and village hall; traffic risk to school children; the street is used as a rat run, with Ham Barn roundabout already not coping at peak times. Request for further consideration of traffic impacts (including EHDC councillor). Impact of traffic on tranquillity.  Lack of capacity at village school and local GPs; cumulative impact on services with development at Whitehill/Bordon  Settlement Facilities Assessment inaccurate, there is no longer a shop, PO, library or bus service suitable for commuting. The village is therefore unsuitable for an allocation, or for this size of allocation (various respondents)  Loss of an employment generating land use  More suitable sites available in the village including unnamed smaller sites, Longmoor Road MOD site.  Damage to dark night skies: current use does not operate after 6pm; would introduce streetlights where few currently exist.

522 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Harm to landscape; little existing screening around the site, would be prominent in views from the northern entrance to Greatham; adjacent road would lose its current rural character.  Impact on recreational experience of local footpaths and bridleways  Off site flooding; the site already contributes to surface and groundwater flooding on Bakersfield, this would worsen with development.  Wildlife on site including toads, rare species of lizards, deer, birds, butterflies and insects  Detrimental impact on Wealden Heaths SPA. Reduce the dwelling number (to 25, 30 or 35 dwellings) and density/developed area of the site (numerous individuals, including EHDC councillor) The volume of development contradicts the number found suitable in the SHLAA; the density is inconsistent with the rest of the village and would remove the feeling of space in the village; impacts as listed above are amplified by a larger number of dwellings. Design requests (various individuals), including:

 The development should not just reinforce, but enhance local distinctiveness  The layout should be linear to match most of the village; an estate led approach would follow the less positive design precedents in the area  A gap of 10m or 15- 20m should be retained between any new buildings and the site boundary (various individuals)  Buildings should be restricted in height to two storeys, or to the same height as neighbouring properties (various individuals)  Additional hedging along the boundary with Bakers Field, hedging to be well maintained (various individuals)  No driveways or parking areas within 5m or 15- 20m of the boundary (various individuals)  More clarity on height, size and layout, to safeguard heritage assets.  Dwellings must not be expensive or upmarket  Shop should be community run, open no later than 7pm, and have no neon signage (various individuals) Alternative uses proposed including:

 Shop with post office and car parking for the school  Solar farm Wording changes requested to descriptions of the village and site.

523 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD74: Land at Fern Farm, Longmoor Road, Greatham There were a total of 11 responses to this policy. A summary of the main issues raised is set out below.

National agencies No comments received Borough, City, County and District Councils Contribution sought for enhancing nearby rights of way (Hampshire County Council) Parish and Town Councils No comments received. Other organisations

 Acceptable subject to development complying with conditions and maintaining screening from Wolfmere Lane (Individual, Cllr Budden)  Greatham Voice and various individuals made the following key points: o Object due to the impact on the landscape. Encroachment into the landscape. Significant change to settlement boundary. o Positioned between two areas of nature designation and within the 5km Wealden Heaths Phase 2 buffer. o The evidence to support the allocation is out of date and in contradiction with itself. Additional 2 pitches when no identified need. Supporting study suggests further pitches would be unacceptable in the location. No reason or justification for this further allocation. o Issues which have been assessed by accompanying Sustainability Appraisal conclude as having ‘uncertain effects’. o Concern that Gypsy and Traveller site proposed within the open countryside, which is contrary to National Planning Policy and SDNPA policies. o Potential impacts on the Shipwrights public right of way.  Policy should include a requirement for enhancements to biodiversity. (Sussex / Hampshire Wildlife Trust)

Individuals

 Allocation of 4 pitches not in proportion to rest of SDNP.  Up to 9 homes could be accommodated along Longmoor Road instead.  Restricts the ability of travellers to settle in other parts of the National Park.  Street frontage development and larger access will harm rural feel.  Increase in traffic from this and surrounding developments is a concern. Traffic calming is needed.

524 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD75: Half Acre, Hawkley Road, Hawkley There were a total of 4 responses to this policy. A summary of the main issues raised is set out below.

National agencies No comments received Borough, City, County and District Councils Support parts of policy seeking protection of the BOAT 25 (adjoining footpath) (Hampshire County Council) Parish and Town Councils Hawkley PC made the following comments:

 Remove allocation from Local Plan.  Large amount of local opposition, site included without the normal public scrutiny, consultation and dialogue with Parish Council.  Allocation relates more to the lack of alternatives than the application of planning policy.  The beauty of the SDNP landscape should not be sacrificed. Previous decisions refusing development on the site refer to it being intrusive in the local environment. Site is surrounded by significant viewpoints,  Understand issues have been raised by other commentators about the completeness of information made available to the consultants undertaking the site study.  Noise, rubbish, disturbance from animals impact on use of adjoining footpath.  Previous temporary permission tied to the special circumstances of the then occupants.  The sustainability assessment states that the site is accessible with sustainable transport links. The site is a significant walk to, and from, the nearest (limited) shops, bus route or railway station. There are no footpaths to Liss and its services  Hedging surrounding the site can be removed. Individuals

 Opposition to giving permanence to Half Acre. Was an understanding that it would only be temporary, no indication that this should change. (Cllr Budden)  Noise, rubbish, disturbance from animals impact on use of adjoining footpath. (Cllr Budden)  Current assessment did not include all possible potential sites. (Cllr Budden)

525 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD76: Itchen Abbas House, Itchen Abbas There were a total of 9 representations on this policy. A summary of the main issues raised is set out below.

National Agencies No comments received Borough, City, County and District Councils

 Hampshire CC support criterion 1e) and request that development provide pedestrian links to adjacent Footpath 34, and resurface the latter to Countryside Service Design Standards to support green travel and mitigate for increase wear and tear. (HCC)

Parish and Town Councils

 The proposed allocation is unlikely to be delivered within 0-5 years and will not fully meet the identified need for affordable housing in the parish (17 applications on the waiting list). Adjacent sites (SHLAA refs WI063 and WI064) should also be allocated, the PC disagrees with the negative SHLAA landscape assessment on these sites. However, the Plan is considered to be sound and compliant. (Itchen Valley PC) Other organisations

 Propose deletion of the site due to unclear landscape impacts and the low rating of the village in the SFA, and its replacement with allocation of land south of Barlavington Way, Midhurst. (ICS Estates)  Evidence base supporting the allocations is insufficient. Ecosystem services approach does not seem to have fed into site selection, but was retrofitted afterwards. Site allocations should be reassessed, including with on-the-ground ecological to ensure existing biodiversity value is properly considered. Inconsistent approach to biodiversity between the different allocations. All allocation policies (not supporting text) should include a requirement for up- to-date ecological information and conservation and enhancement of biodiversity. Allocations containing ecosystem services symbols should contain a caveat in the policy to ensure that enhancements to natural capital are not limited to those requirements listed specifically in the policy. (Wildlife Trusts)  Object to the allocation due to the value of the garden as setting for one of the village’s older and more interesting houses; lack of pavement to the site; precedent for further development of nearby open areas; lack of mains drainage and proximity to River Itchen; quantum of recent development in the village, combined with limited local services. (Upper Itchen Valley Society). Individuals

 Development should include provision of a footway connecting development to the main footway along the B3047, and/or to the disused railway footpath to the N. (HCC Cllr)  Would support extension of settlement boundary on the west side of Itchen Abbas (HCC Cllr)  Owners of part of the site do not agree to the proposed development.

526 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Owners of the current access to the site have not agreed to the proposed development; instead they propose their own land (adjacent, to the north) for development with the same number of dwellings.  Object to the proposed allocation due previous dismissal of appeal on the site; due to extension of the settlement into the countryside; also due to proximity to the river Itchen, in combination with lack of mains drainage, with potential risk of sewer overflow into the river.  Propose that the SDLP should set a number for the village as a whole, without identifying sites, and that number of dwellings to come forward through the planning application process.

527 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD77: Castelmer Fruit Farm, Kingston near Lewes There were a total of 15 representations on this policy. A summary of the main issues raised is set out below.

National Agencies and utility providers Historic England: support the requirement for an archaeological survey, but request additional wording to explain that important archaeological remains or other historic features are retained in situ where possible or, where not possible, recorded for deposition within a public archive. Borough, City, County and District Councils No comments received. Parish and Town Councils Kingston Parish Council consider the allocation unsound for the following reasons:

 The consultation with parishes has been limited and flawed and there is no clarity with regards to site selection;  Lack of necessary infrastructure to support the proposal;  The site was not included as part of the Site Allocations Highway Assessment and there are road safety and traffic issues including insufficient visibility regarding the junction with Ashcombe Lane;  The proposal may require changes to the road layout, removal of trees and possibly street lighting which would change the character of the village;  There should be no possibility of a road link or extending the development in the future to Spring Barn Farm;  While there is general support for limited development of appropriate housing, this needs to be realistically priced and generally aimed at buyers on mid and lower range incomes;  There should be further scrutiny and analysis on deliverability regarding the issues identified;  Proposals should also include consideration of the need to manage traffic flows on the C7 road, including encouraging use of the A26 as the main link between Newhaven and Lewes, providing proper visitor car parking facilities and urgent improvements to the existing footpath connecting Cranedown and Spring Barn Farm, including upgrade to a cycle track. Other organisations DMH Stallard acting on behalf of the landowner supports the proposed allocation but has concerns over certain elements and requirements: including the requirement for site specific flood risk assessment; for the woodland to the north to be made publically accessible; to provide off-site links to existing Public Rights of Way; for an archaeological surve to be carried out and requests that the affordable housing requirement is only a target. Individuals

 Object to the proposal as the village has poor amenities and lacks infrastructure;  There are road safety, traffic issues and restrictions with visibility regarding the junction with Ashcombe Lane;  Traffic calming is needed to reduce the speed of traffic;  The electricity sub-station restricts the width of the entrance and the lane is unsuitable for refuse vehicles without widening which will impact on neighbouring properties;

528 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Access to the site may require the need for a mini roundabout with lighting which would harm the character of the village;  The allocation will result in the loss of a number of mature trees;  The inclusion of the site within the settlement boundary is at odds with the 2015 settlement boundary review;  Lack of appropriate community engagement and feedback;  Lack of proper evidence base;  No proper site selection process undertaken and little explanation why alternative sites are not suitable;  Land at Wellgreen Lane was the only site in Kingston that was assessed positively in the SHLAA; and there are greater number of uncertain effects are identified in the Sustainability Appraisal affecting the Castelmer site than the Wellgreen Lane site;  Development on this scale is not in keeping with the character of the village;  The development should be restricted to the area of the site currently occupied by existing buildings and should not include the land to the east;  It is no clear how the publically accessible land will be maintained and funded;  The allocation will have a significant detrimental impact upon the landscape and be visually dominant in views to the north and north east;  Do not believe truly affordable housing will be delivered;  No evidence that additional housing is needed in Kingston.  The proposal represents an expansion of backland development. Cllr V Ient (Lewes District Council)

529 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD78: The Pump House, Kingston Ridge, Kingston There were a total of 10 responses to this policy. A summary of the main issues raised is set out below.

Specific consultation bodies – national agencies and utility providers No comments received Specific consultation bodies – other local authorities No comments received Parish and Town Councils Kingston Parish Council made the following comments:

 Lack of consultation, not in compliance with National Policy Planning Framework.  A need for a permanent site for longer term use by the wider gypsy/traveller community has not been proven.  Concern that the allocation is larger than necessary for one permanent pitch. This leaves the possibility of the number of pitches being increased in the future.  It is not clear from the draft Plan whether the landowner is supportive of the proposal.  The plan should include consideration of the following infrastructure requirements: • Increasing levels of traffic on the C324 which passes through Kingston and links to the A27 • Lack of a proper car park for visitors to the village, the local school and the National Park which is a concern • The provision of well-maintained footpaths.  If a permanent site is to be designated, a much smaller area of land should be allocated Other organisations and individuals

 Strongly support allocation of this site, which is occupied by Gypsy Travellers with long connections to the area, who are in need of further pitches for their extended family. (Heine Planning)  Object to allocation, suggest it should be removed. (Various individuals)  Not included in earlier consultations, not a clear or transparent process. (Various individuals)  Not clear where the caravan should be sited. (Individual)  Site access is unnecessarily large. (Various individuals)  Not to date received the consent of the land owner to the proposal for a permanent pitch. (Various individuals)  There are open views to the site from The Ridge and surrounding hills. It is unclear why it is necessary for so much land to be allocated opposite Downsmead and in front of the Pump House. (Various individuals)  The word ‘Gypsy’ or ‘Traveller’ is not mentioned on any part the planning application relating to the site. The site should not be named as a Gypsy & Traveller site. (Various individuals)

530 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 There were specific family circumstances as to why the current planning consent was temporary, and there is no reason why this should change – no demonstrable need for a permanent site. (Individual)  All should have same rights, but Gypsies and Travellers are granted special privileges. (Individual)  Gypsy and Traveller pitch is inconsistent with surrounding bricks and mortars homes. (Individual)  Caravan access is restricted into Pump House. (Individual)  Proper permanent sites need to be provided in the SDNP to give residents a choice. (Individual)  Why is the site being considered when it was omitted from 2012 assessment. (Individual)  Include need for ecological assessment within policy (Sussex Wildlife Trust / Hampshire & Isle of Wight Wildlife Trust).  Support allocation. Gypsy & Traveller family with long connections to local area. (Individual)

531 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD79: Land at Old Malling Farm, Lewes There were a total of 12 representations on this policy. A summary of the main issues raised is set out below.

National agencies Environment Agency: Consider policy is not as effective as it could be at managing flood risk, and request amendments to criterion 5(f) to explicitly state residential development should be located in Flood Zone 1 only. Pleased to see inclusion of criteria 5(g) and 5(h), although note nothing related to flood compensation storage, or restricting development in Flood Zone 3b to only Essential Infrastructure or Water Compatible development, and suggest additional text is added to part 5 of the policy to resolve. Comments reflect the Level 1 Update and Level 2 SFRA Final Report. Historic England: Welcome and supports the policy as part of the positive strategy for the conservation and enjoyment, and a clear strategy for enhancing the historic environment. However, Historic England would prefer to see reference to Heritage Impact Assessment or Archaeological Assessment or both, with important archaeological remains or other historic features retained in situ wherever possible, or, where not possible, recorded for deposition within a public archive. Southern Water: Assessment reveals that additional local water and sewerage infrastructure would be required to accommodate the proposed development (involving making a connection to the water and sewerage networks at the nearest points of adequate capacity). Request that the need for additional infrastructure at specific sites is recognised within the policy. Borough, City, County and District Councils No comments received Parish and Town Councils

 Design Brief should be landscape and ecosystem services led, and include a Green Infrastructure Strategy and site Masterplan, informed by suitable evidence. (Lewes Town Council) Other organisations

 Support principle of allocation, but object to the reduction in housing numbers from ‘approximately 240 dwellings’ to ‘between 220-240 dwellings’ and to the inclusion of criteria 5(c) and 5(k). The former is objected to, as it is outside of the site boundary and not within the owner’s control, whilst the latter is considered to be wholly unjustified and was previously rejected during the examination of the Lewes and SDNPA Joint Core Strategy. It is also considered that the supporting text should reference explicitly the Inspector’s comments on the site, in respect of the landscape impact and housing need. (Luken Beck, on behalf of the landowners of Old Malling Farm)  Allocation is inconsistent with landscape-led principle emphasised by Local Plan (Friends of Lewes and South Downs Society)  Highly visible from several viewpoints and serves as a valuable tongue of Green Infrastructure, linking Lewes with the open countryside of the Ouse Valley, which contributed to the decision to include the town within the National Park boundary. (Friends of Lewes and South Downs Society)

532 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Object to policy unless convincing landscape reasons can be given to say otherwise. Acknowledge inclusion of site within the SDNPA and Lewes Joint Core Strategy, but that Plan and the Inspector’s reasoning for including the allocation was housing led. (Friends of Lewes)  Object to policy unless it can be demonstrated there are insufficient brownfield sites to meet Lewes Town housing needs. (South Downs Society)

Individuals

 Concern regarding the impact of potential public access to areas of the floodplain  No reassurance regarding the preservation of privacy of residents at Old Malling Farm, which will be dramatically impacted by the allocation, or the conservation of the historical site.  Object to the principle of the allocation, as the original allocation within the JCS was housing need led, whereas the South Downs Local Plan is landscape led. There are sufficient brownfield sites to address the housing need. (various individuals and Cllr Vic Ient, Lewes DC)  Concern regarding the impact on heritage assets (in particular archaeology)  Object as site currently provided important green finger and would result of loss of agricultural land. Preference for continuing farming of the land. (various individuals and Cllr Vic Ient, Lewes DC)  Would like site to focus on affordable rent, rather than shared ownership (Cllr Joanna Carter, Lewes DC)  Presumption in favour of planting native trees, hedgerow and wildflowers (Cllr Joanna Carter, Lewes DC)  More emphasis needed on sustainability and climate resilience within design (Cllr Joanna Carter, Lewes DC)  Appropriate investment in infrastructure required, including sustainable transport links connecting to Lewes and beyond, creation of community and employment space (on or off- site) and facilities for teenagers/young people. The provision of a cycle route along the railway cut would be welcomed (Cllr Joanna Carter, Lewes DC)

533 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD80: Malling Brooks, Lewes There were a total of 3 representations on this policy. A summary of the main issues raised is set out below.

National agencies Environment Agency: Criterion 1(e): Should include greater flexibility, rather than referring to the FRA for the current planning permission. That may not be suitable for a new scheme. Amend as follows: ‘A comprehensive approach to flood risk management will be adopted and development will be undertaken in accordance with the recommendations of an agreed Flood Risk Assessment’.

Historic England: Welcome and support the description of the historic environment on site, and the requirement in the supporting text for an archaeological survey, as part of the positive strategy for the historic environment as per NPPF. However, to provide appropriate protection for heritage assets, the requirement for an archaeological survey should be included in the policy itself, along with a requirement for important archaeological remains or other historic features to be retained in situ wherever possible, or, where not possible, recorded for deposition within a public archive. Borough, City, County and District Councils

 No comments received Parish and Town Councils

 No comments received Other organisations

 Unclear why all roofs should be green roofs, would support some being used for solar thermal / photovoltaic generation. (Lewes District Green Party)  The current permission on site is for large corporate warehouses for high rent; this does not replace the type of employment space being lost from North Street, i.e. low cost, flexible multi-use warehouses housing social enterprises, start-ups, light industry and creative businesses. This is reflected in low take up of the new space by North Street businesses. Policy should direct the construction of space that more directly replaces that being lost. (Lewes District Green Party) Individuals

 No comments received

534 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD81: West Sussex County Council Depot and former Brickworks site, Midhurst There were a total of 15 representations on this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Would prefer to see reference to Heritage Impact Assessment or Archaeological Assessment or both, with important archaeological remains or other historic features retained in situ wherever possible, or, where not possible, recorded for deposition within a public archive. Southern Water: Assessment reveals that there is underground water supply infrastructure within the site that would require an easement, and may affect the site layout or require diversion. Additional local sewerage infrastructure would be required to accommodate the proposed development (involving making a connection to the sewerage networks at the nearest points of adequate capacity). Request that the need for additional infrastructure at specific sites is recognised within the policy, and a policy requirement for future access for maintenance and upsizing purposes.

Borough, City, County and District Councils

 Support part (e) regarding the household recycling facility (HRF), however it should clarify that it is the ‘waste disposal’ authority who will need to approve retention or relocation. To accord with Policy SD43, (e) should also state “of at least equivalent standard”. Supporting text should recognise the HRF as an important community facility for Midhurst. (West Sussex County Council)

Parish and Town Councils

 Policy should require employment uses specifically rather than ‘complementary uses’, in addition to residential which is supported. These should take form of a small development of 6-12 industrial units to accommodate local caterers, craftsmen and other service providers. Policy should be far more positive about retention and possible expansion of the HRF to accept inert waste, to tackle fly-tipping (future and current). Site boundary should be adjusted to include whole of brickworks site. (Midhurst TC)  HRF provides important local facility to a wide catchment area; should redevelopment proceed, a relocated HRF must be relocated and open before the existing facility is closed, and be at least equal in terms of facilities and capacity. (Cocking PC)

Other organisations

 The concept plan makes assumptions about the form of development that are unreasonable without a detailed planning and design exercise and consultation with the landowners, and should be removed from SD81. Policy should refer to ’90 or more dwellings’ as the number being delivered by the site. (Cowdray Estate Office, West Sussex County Council and Cowdray Estate)

535 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 A historic Flood Risk Assessment has been prepared for the southern part of the site; this and the Strategic Flood Risk Assessment (SFRA) concludes no historic flooding within the site area. Reference to risk of surface water flooding should be removed. (West Sussex County Council and Cowdray Estate)  Proposed allocation should be deleted and land south of Barlavington Way instead allocated, as the latter scores better against the SDNPA’s sustainability objectives. (ICS Estates Ltd.)  Brickworks site might be more suited to retail use. Local re-siting of HRF important. Development would provide better buffer to Midhurst Common. Compulsory purchase of low-grade commercial units in Station Road should be considered. There is a case for higher than normal affordable housing provision. (The Midhurst Society)

Individuals

 Concern over potential loss of HRF. Policy should require retention of the HRF or relocation within the Midhurst area. (several individuals)  Access to the site should be from Station Road not Bepton Road.  Development would lead to increased noise and pollution on Bepton Road which is a few feet from the rear boundaries of properties in Heathfield Park.

536 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD82: Holmbush Caravan Park, Midhurst There were a total of 6 representations on this policy. A summary of the main issues raised is set out below.

National agencies Environment Agency: Currently policy is unsound as it is not sufficiently effective in managing flood risk. Policy should require all development to be located in Flood Zone 1, and require flood compensation storage in relation to any ground raising or built development in fluvial Flood Zone 3 (including allowance for future climate change). Southern Water: Assessment reveals that there is underground water supply infrastructure within the site that would require an easement, and may affect the site layout or require diversion. Additional local sewerage infrastructure would be required to accommodate the proposed development (involving making a connection to the sewerage networks at the nearest points of adequate capacity). Request that the need for additional infrastructure at specific sites is recognised within the policy, and a policy requirement for future access for maintenance and upsizing purposes.

Borough, City, County and District Councils No comments received.

Parish and Town Councils

 The Authority is to be commended on their approach to this site. (Midhurst TC)

Other organisations

 Previous planning permission for 89 dwellings was never progressed due to numerous site technical constraints, especially flooding constraints (much of site is in Flood Zone 3). Allocation should be deleted and land south of Barlavington Way instead allocated. (ICS Estates Ltd.)  Well-designed residential development welcomes provided wildlife is sensitively relocated, a case can be made for a higher than normal level of affordable housing. Due to blind bend on The Fairway and concern over traffic level, a full traffic impact assessment is also required. The site could accommodate a supermarket which, due to the topography, would not be visually intrusive. (The Midhurst Society)

Individuals No comments received.

537 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD89: Land at The Fairway, Midhurst There were a total of 4 representations on this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Welcomes and supports criterion 1 b) of Policy SD83 as part of the positive strategy for the conservation and enjoyment, and a clear strategy for enhancing, the historic environment as required by paragraphs 126 and 157 of the National Planning Policy Framework.

Borough, City, County and District Councils No comments received.

Parish and Town Councils No comments received.

Other organisations

 This section of The Fairway is narrow and on-street parking causes a hazard to passing traffic. The entrance to the Holmbush Caravan Park site is opposite. Removal of existing car parking facilities should be resisted. (The Midhurst Society)

Individuals

 The proposed site provides car parking for existing flats at Brisbane, Adelaide & Perth Houses, including for visitors. There are already too few car parking spaces allocated for existing residents, leading to overspill parking on The Fairway which is a busy and dangerous section of road, with an increase in traffic expected if Holmbush Caravan Park is developed. The Plan suggests removal of green space which is regularly used by residents. (2 individuals)  Views from existing flats will be severely altered and screening lost, due to extension of car parking and potential removal of shrubs/garden, which would be an invasion of privacy and impact on wildlife.

538 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD84 Land at Lamberts Lane There were a total of 7 representations on this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Welcomes and supports criterion 1 b) of Policy SD84 as part of the positive strategy for the conservation and enjoyment, and a clear strategy for enhancing, the historic environment as required by paragraphs 126 and 157 of the National Planning Policy Framework. Would prefer to see reference to Heritage Impact Assessment or Archaeological Assessment or both, with important archaeological remains or other historic features retained in situ wherever possible, or, where not possible, recorded for deposition within a public archive. Southern Water: Additional local sewerage infrastructure would be required to accommodate the proposed development (involving making a connection to the sewerage networks at the nearest points of adequate capacity). Request that the need for additional infrastructure at specific sites is recognised within the policy.

Borough, City, County and District Councils

 Support, subject to satisfactory Road Safety Audits being carried out prior to the Local Plan Examination. (West Sussex County Council)

Parish and Town Councils No comments received. Other organisations

 Support. Opportunity should be taken to establish improved pedestrian access to open countryside, connecting with permissive and statutory rights of way across Cowdray Estate and National Trust lands. (South Downs Society)  Site should be reassessed to ensure that the existing biodiversity value has been properly considered. Policy should be reworded to ensure a consistent approach to assessments and net gains, with all allocations including a requirement for up-to-date ecological information and conservation and enhancement of biodiversity. (Sussex/Hampshire Wildlife Trust)  Impact on heavy traffic on North Street, and additional parking pressures on Lamberts Lane, must be resolved before units are permitted. An alternative use of a small park or arboretum would be a useful local amenity. No proposal should be permitted unless a non- motorised vehicle route is reinstated, to replace footpath to Whip Hill when playing fields were developed. (The Midhurst Society)

Individuals No comments received.

539 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD85 There were a total of 3 representations on this policy. A summary of the main issues raised is set out below.

National agencies No comments received. Borough, City, County and District Councils No comments received.

Parish and Town Councils No comments received.

Other organisations

 Support allocation, which is available, sustainably located and achievable. (Metis Homes)  Support allocation. opportunity should be taken to establish improved pedestrian access to open countryside, connecting with permissive and statutory rights of way across Cowdray Estate and National Trust lands.  Impact on heavy traffic on North Street, and additional parking pressures on Lamberts Lane, must be resolved before units are permitted. An alternative use of a small park or arboretum would be a useful local amenity. No proposal should be permitted unless a non- motorised vehicle route is reinstated, to replace footpath to Whip Hill when playing fields were developed. (The Midhurst Society)

Individuals No comments received.

540 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD86: Offham Barns, North of Offham Filling Station, The Street, Offham There were 2 responses to this policy. A summary of the main issues raised is set out below.

Specific consultation bodies – national agencies and utility providers

 No comments received Specific consultation bodies – other local authorities

 No comments received Parish and Town Councils

 No comments received Other organisations and individuals

 Inconsistencies amongst the allocations in terms of biodiversity requirements. Reassess site to ensure that existing biodiversity value has been considered. Up-to-date ecological information should be set out in the supporting text. (Sussex and Hampshire Wildlife Trusts)  Support allocation, further pitches needed for extended family. Gypsy & Traveller family with long connections to local area. (Heine Planning)

541 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD87: Land at Church Lane, Pyecombe There were a total of 2 representations on this policy. A summary of the main issues raised is set out below.

National Agencies

 No comments received. Borough, City, County and District Councils

 No comments received. Parish and Town Councils

 No comments received. Other organisations

 The land within the northern part of the allocated site which is yet to be developed could accommodate a further 5 dwellings. This should be reflected in policy SD87 (and policy SD26 with the allocation increased to at least 14 dwellings; especially given that in the Mid Sussex Local Plan it was allocated for 20 dwellings. (DMH Stallard LLP)  Consider that there are sustainability and deliverability issues with the proposed allocation and that the site at Barlavington Way, Midhurst which performs better in sustainability terms should be allocated instead. (ICS Estates Ltd.) Individuals No comments received.

542 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD99: Development Principles There were a total of 19 representations on this policy. A summary of the main issues raised is set out below.

National agencies Natural England: The accompanying text to the policy states that the site is located 290 metres from the Wealden Heath Special Protection Area. Natural England would advise a check on this as we believe this should be referring to East Hampshire Hangers SAC and not Wealden Heaths SPA . East Hampshire Hangers SAC is the nearest European site to Ketchers field and Ketchers field falls within the 5km zone of Wealden Heaths Phase II SPA.

Borough, City, County and District Councils

 Selborne Footpath 504 runs along the site’s access road. Welcome point 1.c) and 2.a) to protect and enhance the right of way. (Hampshire CC)

Parish and Town Councils

 Minor wording and policy changes suggested regarding protection of the stream to the north, the Right of Way, access to recreation ground, indigenous species planting, and grammatical correction. (Selborne PC)

Other organisations

 The proposed allocation of Land at Park Lane, Droxford should be deleted and the land south of Barlavington Way, Midhurst should be allocated for development instead. (ICS Estates Ltd.)  The proposed allocation of the Ketchers Field site at Selborne is unsound and flawed and should be withdrawn, because there is no agreed means of vehicular access and the possible alternative means of access through the adjacent Ketchers Field is outside the control of the site owners and cannot be relied on. (Newton Valance Farm)  The development of the Land at Ketchers Field is unsustainable (due to remoteness from existing village services) and undeliverable (due to constrained access), likely to result in a bland and urbanising form of development which would conflict with the Statutory Duties of the National Park. The alternative site Under the Hill is more sustainable and would offer substantial community benefits, and should instead be allocated. (Village Green Investments)

Individuals

 Support allocation. (several individuals)  Welcome incorporation of village design statement, Village Plan and local landscape character assessment. Concern over traffic levels.  The land in question is on the periphery and would put less mobile people out of reach of the village shops etc.

543 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 The new homes should be built within Passivhaus guidelines.  Unsuitable for development as further development would have an adverse impact on the existing households.

544 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD89: Land at Pulens Lane, Sheet There were a total of 78 responses to this policy. A summary of the main issues raised is set out below.

To note: Within Sheet, the site is also knowns as Stocklands. Specific consultation bodies – national agencies and utility providers Environment Agency suggest policy wording be strengthened to refer to 20m buffer strip and flood compensation storage. Historic England seek requirement for Heritage Impact Assessment / Archaeological assessment in policy. Specific consultation bodies – other local authorities Hampshire County Council support a new footpath across the site linking to Petersfield footpath 502. Parish and Town Councils

Sheet Parish Council consider SD89 is unsound because: o Beyond existing settlement boundary o Follows the bank of the River Rother, vulnerable to pollution and banks easily degraded. o Adjoining woodland is a SINC, consider the meadow of equal importance o Site and access at risk of surface water flooding. Environmental impact of embankments not considered. o Otters recorded up-stream. o Invaluable buffer between existing homes and the River Rother which is significant local landscape importance. o Conflicts with purposes of National Park. o Increase car use, should be considered cumulatively with 80 homes on Penns Place, Petersfield. o Pulens Lane is overloaded with traffic, speeding, numerous residential exits, blind corners, poor or absent footpaths, and heavy use by pedestrian. No marked pedestrian crossings and no traffic calming measures. The presence of schools nearby accentuates the problems. Junction of Pulens Lane and the London Road, Durford Road and Heath Road congestion at peak periods of the day. o No account of the impact on infrastructure in conjunction with allocations in Petersfield. o Reduces distinct village identity. o Site previously subject to an independent Inspectors report and rejected. Rogate Parish Council offered no comments on this policy. Petersfield Parish Council consider that Pulens Lane is already a busy route and that will increase if the allocations in the Petersfield NPP come forward. Concerns about the impact on the Rother and also the Rotherlands nature reserve. Infrastructure and CIL should benefit Petersfield Town. Other organisations and individuals Landowners

545 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues Support for the allocation and the development brief. Believe site is deliverable and will work with the SDNPA to achieve this. Request that site layout pays particular attention to existing properties and the sensitivity of the River Rother corridor.

 Allocation is inconsistent with Policies SD1, SD3, SD9, SD17, SD25  Allocation is inconsistent with the refusal of a scheme on this site in 2016.  Support allocation however alterations recommended relating to terminology and the need to allow for proper masterplanning through the Development Brief and Planning Application processes.  Unclear how the position of the settlement boundary has been determined with no apparent connection with the settlement boundary methodology. Settlement boundary should be redrawn.  Description of allocation as mixed-use is incorrect, it is a residential scheme with open space / natural areas provided. Term ‘open-space’ can be misinterpreted as park or play area.  Objection / complaint over allocation, consider it should be deleted from plan (various individuals)  Allocation of site for housing rejected in EHDC Local Plan in 1995 for environmental and traffic reasons, and the erosion of visual quality of river landscape. Development would damage hydrology, disrupt springs. (various individuals)  Application for 5 homes on site recently refused for environmental / ecology reasons, contrary to policy. (various individuals)  Allocation contrary to NPPF and policies within the Submission South Downs Local Plan including SD3 Major Development as not demonstrated that it is in public interest. (various individuals)  Allocation follows banks of River Rother. Development is contrary to first purpose of National Park and could risk pollution of the river (like Tilmore Brook). Sandy river bank is vulnerable and will be eroded by increased use (children / dogs). Increasing access to river will damage flora and fauna. Lead to littering (various individuals)  Adjoining woodland is a SINC, buffer significantly reduced, increase disturbance and damage. Damage ancient and wet woodland. (various individuals)  The meadow should be classified as a SINC (various individuals)  Harm to biodiversity including bats, otters (recorded up stream)  Sheet is already contributing houses. Allocated 21 homes by 2025, 18 under construction. 32 further homes will take total to 50 in the village. (various individuals)  Cumulative impact of 82 homes to be built on nearby Penns Field. Traffic issues already significant. Increase pollution. Increased risk of accidents, risk to safety of pedestrians. Increased traffic, road used as cut through. Junction improvements needed on the London Road junction, issues already exist. Local roads not suitable for emergency vehicles. School close by. Pulens Lane narrow, congested, poor visibility. Regular speeding. Site access rated as poor in Highways Assessment Report (March 2017). Close proximity to schools. (various individuals)  No obvious access to site, needs demolition of house on Pulens Lane. Current entrance is narrow, single file traffic. Site not deliverable and is therefore inconsistent with the NPPF. (various individuals)  Reduce size of allocation to 5/6 homes.  Cumulative impact. Merge Sheet with Petersfield. Loss of village character.  No increase in infrastructure in local area to accommodate needs of the development, in particular schools and surgeries. (various individuals)

546 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Site at risk of flooding, including drainage ditch, requires major work on river environment. Risk will increase with climate change. Development will impact on natural water movements. Surface water run-off damages roads and driveways. (various individuals)  Harms landscape character. (various individuals)  Conflicts with Objective 8 of the Local Plan – to protect and provide for the social and economic wellbeing of National Park communities supporting local facilities.  Consider land south of Barlavington Way, Midhurst performs better in sustainability terms and should be allocated instead of Pulens Way.  Suggest allocate some of plots for self-build  Allocate some of site for allotments 

547 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD90: Land at Loppers Ash, South Harting There were a total of 47 representations on this policy. A summary of the main issues raised is set out below.

National Agencies

 No comments received Borough, City, County and District Councils

 No comments received Parish and Town Councils

 Delete the proposed allocation and replace with the brownfield site proposed by Harting PC. (Harting PC)  Not legally compliant: there has been no consultation on the 60% increase in the site, (which was also not proposed in the SHLAA), as per Reg 18. The Gunning Principles (2.1-2.3) have been ignored. (Harting PC)  The PC reluctantly supported the previous version of the site subject to landscape and traffic concerns being adequately addressed and the number reduced to 6. (Harting PC)

 The area of the site has been increased by 60% without consultation. Its development will not respect the traditional layout of a typical village edge but will encroach well into an arable field. It will be highly visible from the South Downs Way. The site is on a single-track historic rural road, the traffic on which would at least double thus impacting on the recreational value of this much-used pedestrian route to the Downs. (Harting PC)  By contrast the brownfield site proposed by Harting PC would have no impact on the wider landscape, and would provide at least as many homes as SD90 and SD91 combined. (Harting PC) Other organisations

 Not aware of any sentiment in favour of new housing in the village. Any suggestion that new housing might include genuinely affordable units is met with scepticism born of experience. (Harting Society)  The proposal would have an adverse impact on views of and from the South Downs. (Harting Society)  No effective consultation on the justification for the increase in the site. The proposal to ‘bulge out’ the site away from the lane seems particularly out of character and would create a mini-estate whose only access to a proper road is via an ancient single-track lane with banks and no passing places. (Harting Society)  Propose deletion of the site due to clear adverse impacts on landscape and the low rating of the village in the SFA, and its replacement with allocation of land south of Barlavington Way, Midhurst. (ICS Estates)  Evidence base supporting the allocations is insufficient. Ecosystem services approach does not seem to have fed into site selection, but was retrofitted afterwards. Site allocations should be reassessed, including with on-the-ground ecological to ensure existing biodiversity value is properly considered. Inconsistent approach to biodiversity between the different allocations. All allocation policies (not supporting text) should include a requirement for up- to-date ecological information and conservation and enhancement of biodiversity. Allocations containing ecosystem services symbols should contain a caveat in the policy to

548 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues ensure that enhancements to natural capital are not limited to those requirements listed specifically in the policy. (Wildlife Trusts)

Individuals Procedural issues

 Site was supported at Preferred Options stage subject to concerns being addressed; this has not happened (CDC councillor)  No justification provided for increasing the area of the site from Preferred Options. Lack of consultation on this extended site means it fails to meet legal requirements (Gunning/Sedley principles). NPA unresponsive to HPC concerns raised through consultation (various individuals including CDC councillor)  Site is in conflict with Purpose 1 and the NPA’s Duty to communities (CDC councillor) Landscape issues

 ref. appeal refusal APP/Y9507/D/16/3145623 for a shed in garden adjacent to the site, on landscape grounds. (CDC councillor)  Mentions need to protect views of the South Downs, but not from the South Downs- site would be highly visible from popular Harting Hill and a wide stretch of the South Downs Way and would degrade visual integrity, identity and scenic quality from that viewpoint- The view across the site from the Downs encompasses natural beauty beyond the site, increasing the impact of the proposals. (various individuals including CDC councillor)  Site provides expansive views of the South Downs across farmland for NP users. Development would harm these views, create intrusion, and detract from character by introducing urbanising elements. Not justified, positively prepared or consistent with SD4 (various individuals)  Proposals would degrade the visual integrity, identify and scenic quality of the east side of the village.  Development would be denser than that in the surrounding area.  If the enlarged (eastern) area of the site is used for building or car parking, the landscape would be further degraded. (various individuals)  Achieving visibility at the New Lane/Elsted Road junction would require removal of a large area of bank, with significant adverse landscape impact.  Views from PROW from the village will be impacted.  The SA states the site has ‘uncertain’ landscape and cultural heritage impacts. its allocation is therefore not landscape led and contradicts the first purpose of the NP  Dwellings cannot be built on the site without a negative impact on the landscape, therefore the allocation is not led by landscape capacity. (CDC councillor Green space

 A small area of agricultural land within the site is clearly nonsensical (CDC councillor)  the parish already has allotments (CDC councillor)  there is local green space close to the site, including Harting Down (CDC councillor)  the proposed green space would not fully mitigate landscape harm; only a minimal development on the site is possible without landscape harm.  Need more precise layout details, including of the on-site green space, to assess the impact on views. Failure to do this earlier breached the Gunning Principles. (CDC councillor)

549 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues Streetscape

 Site conflicts with Policy SD21 on historic rural roads. Would increase traffic movements on New Lane by more than 10% (number of dwellings on the lane would be doubled) and would fail to conserve or enhance the ecological, landscape or recreational value of the lane. (CDC councillor)  The impact of creating the entrance and necessary splays will have an unacceptable impact on this historic rural road and hollow way which is little used by agricultural vehicles due to its width, hence very quiet.. (CDC councillor)  New Lane is the only remaining single track lane in the village, very quiet, pretty and well used for recreation. (various individuals)  New lane is historically a cow herding lane and of significant importance in the history of the village and locality Highways

 8 new driveways onto New Lane may cause problems  New Lane/Elsted Road junction has limited visibility, exacerbated by parking; increased development would increase risk to users. (various individuals)  New Lane is the only safe route to Harting Down for non-motorised users; increased motor traffic, with at least 3 new access points, would cause safety and accessibility concerns. (various individuals)  New Lane is too narrow for additional traffic  Danger to South Acre caused by increased traffic and increased car parking. (various individuals)  How can parking be accommodated within a form of development that continued the pattern of development found to north and south. (CDC councillor)  Approach from South Acre into New Lane is hazardous.  Proposal may result on parking on the Midhurst Road / South Acre. Residents of Loppers Ash already park on the Midhurst Road, this would be exacerbated and make the New Lane entrance more dangerous (various individuals)  Propose highways assessment Affordability

 Due to the attractive views from the site, whatever the style of property, the dwellings built will be too expensive for local working residents. Owners likely to be commuters or second home owners- will not address the needs of the local community.  Market housing will not address the needs of the local community. The community is currently unbalanced in favour of wealthy residents and second home owners- affordable housing needed to balance this.  The development does not propose enough affordable homes. In its current format, all it does is accumulate wealth for the landowner. Any development should be for affordable housing schemes. Drainage

 New Lane suffers from surface water flooding, development would cause further surface runoff. (various individuals)  Concerns over capacity of drainage system to support additional dwellings. (various individuals)

550 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues Stability

 South Acre residents have had subsidence issues due to clay soil; consider carefully. (various individuals) Residential amenity:

 The proposals will have a huge impact on neighbouring amenity Heritage:

 There is a Roman Villa in the area and artefacts are still being found in surrounding gardens. Agriculture:

 Proposal would cause loss of good agricultural land (various individuals)  Propose agricultural assessment Proposed criteria

 Decrease number of properties  Height limitation  Increase parking spaces.

 Biodiversity: Will have adverse impact on natural habitat.  Settlement boundary- should not allocate sites outside the settlement boundary  Sustainability: SA should not score the impact on accessibility as ‘likely positive’ but as ‘uncertain’; the site is some distance by foot from most facilities and services, along an increasingly busy road with hardly any pavements (CDC councillor)  Infrastructure: Concerns over impact on schools, buses and parking.  No further new housing needed in South Harting due to recent Smithfield development.  Fully supportive of policy criteria (site landowner)  Proposals appears to be based on meeting targets rather than needs, which contradicts the Local plan objectives.  It will be easy in future to extend the cul-de-sac and encroach further into the field.  Views to the Downs from existing houses will be poorer  Proposals would lead to further requests to develop at the southern end of the Lane, which would be a disaster.

551 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD91: Land North of the Forge, South Harting There were a total of 28 representations on this policy. A summary of the main issues raised is set out below.

National Agencies Historic England: The allocation of this site raises potential concerns for Historic England given its relationship to the South Harting Conservation Area. Historic England wonders if it is actually possible for any development on this sensitive site to preserve, let alone enhance, the setting of the Conservation Area. However, they must assume that criterion (a) requiring such preservation and enhancement will be rigorously adhered to and they accept that, if so, it provides adequate protection for the Conservation Area. Welcome and support descriptions of the historic environment, and requirement for development to be supported by a heritage impact assessment, as part of the positive strategy for the conservation and enjoyment, and a clear strategy for enhancing the historic environment. However, this requirement should be in the policy itself rather than supporting text.

Borough, City, County and District Councils

 No comments received Parish and Town Councils

 Proposal would not constitute sustainable development  Delete the proposed allocation and replace with the brownfield site proposed by Harting PC. (Harting PC)  Not legally compliant: there has been no consultation on the site, as per Reg 18. The Gunning Principles (2.1-2.3) have been ignored. (Harting PC)  The site would be 10m deeper than adjacent Conservation Area properties.  Paragraphs 9.209 and 9.210 ignore the evidence from the SDNPA’s Landscape Architect and Conservation Officer, in responding to previous planning applications on the site, who both said that any development on the site would cause harm to the landscape and conservation area respectively. Therefore it is not possible for any development on this site to conserve or enhance views from publicly accessible areas or the setting of the conservation area.  The site should not be allocated if its landscape impact is uncertain (as per Sustainability AppraisaL)  The site’s density is at least twice that of any other rural allocation in the Plan, and twice the Chichester District Council benchmark, and the dwellings per metre of site frontage is from 2.5 to three times that in the adjacent conservation area.  Following the development of the Forge site across the road, also within the setting of the CA and listed buildings, further development would have a negative cumulative effect.  Development would close off the only entrance to the field behind that is practical to use for farm machinery. There are two other entrances but one is mnot viable due to parked vehciles and the tightness of the turn off the Lane, the other is via a very deep, steep and narrow hollow-way with extremely poor sightlines. Diverting farm vehicles onto thioe lanes would harm historic rural roads in contravention of Policy SD21.  The Forge development opposite contained the required number of on-site parking spaces but still generates off-site parking; such parking causes problems around the village; need to consider cumulative impact from this development.

552 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Surface water flooding adjacent to the site is generated by run-off from the site itself and the land beyond. Development may increase local flooding. It is hard to see how a SUDS system could be accommodated on the site itself, and cope with run-off from the field; drainage to the stream must not be an option given the status of the stream corridor as a rare habitat housing reptiles.  By contrast the brownfield site proposed by Harting PC would have no impact on the wider landscape, and would provide at least as many homes as SD90 and SD91 combined. (Harting PC) Other organisations

 Site is enclosed, and terraced/semi-detached cottages- similar density to dwellings to W and S- behind cottage gardens and low walls would blend readily with the street scene while being totally screened from surrounding countryside. Parking would be east of the cottages in a covered ‘farmyard’ area. Ample room would remain to the east for access to the field to the north. (Elizabeth Lawrence Ltd)  Not aware of any sentiment in favour of new housing in the village. Any suggestion that new housing might include genuinely affordable units is met with scepticism born of experience. (Harting Society)  No effective consultation on the justification for the allocation of the site. The adverse impacts of the site would be increased due to its elevated nature. (Harting Society)  Propose deletion of the site due to clear adverse impacts on landscape and the low rating of the village in the SFA, and its replacement with allocation of land south of Barlavington Way, Midhurst. (ICS Estates)  Evidence base supporting the allocations is insufficient. Ecosystem services approach does not seem to have fed into site selection, but was retrofitted afterwards. Site allocations should be reassessed, including with on-the-ground ecological to ensure existing biodiversity value is properly considered. Inconsistent approach to biodiversity between the different allocations. All allocation policies (not supporting text) should include a requirement for up- to-date ecological information and conservation and enhancement of biodiversity. Allocations containing ecosystem services symbols should contain a caveat in the policy to ensure that enhancements to natural capital are not limited to those requirements listed specifically in the policy. Need to include a requirement for enhancements to biodiversity, in the policy itself. (Wildlife Trusts)

Individuals General

 Propose no further housing development in South Harting due to recent Smithfield development, south of the proposed site.  Inadequate consideration has been given to the cumulative impacts of the two proposed developments in South Harting, in close proximity and near the foot of the Downs; and also to cumulative impact with the recent Forge development opposite (Various individuals)  The SDNPA refused permission for infill development on the edge of Petersfield the (SDNP/13/03649/OUT, Land West of 87 Sussex Road), with the appeal against that decision being dismissed.

Procedural issues

553 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Site was excluded by 2014 SHLAA and therefore 2015 Preferred Options Consultation; no previous consultation on the site; inclusion at this stage contradicts Gunning Principles (Various including CDC councillor)  No justification for adding the site since Preferred Options has been provided. (Gunning/Sedley principles). NPA unresponsive to HPC concerns raised through consultation (various individuals including CDC councillor)  Site is in conflict with Purpose 1 and the NPA’s Duty to communities (CDC councillor)

Landscape issues

 The allocation does not conform to the first purpose, vision or objectives of the SDNPA regarding landscape (various individuals)  No evidence has been provided that the site’s negative landscape impacts can be ameliorated. The site is not consistent with an approach to allocations based on landscape capacity; it must be assumed to indicate an approach to allocations led by housing targets. (CDC councillor)  Steeply rising land. Development would damage views eastwards along Elsted Road. (Various individuals)  Development would damage views from the Downs.  Site is particularly important due to arable land coming down to the roadside; this cannot be protected or enhanced by development.  Recent housing built across the road; housing on this site would create a ‘tunnel effect’, damaging the present rural character of the lane. (various individuals)  Because of the height of the site, development there would dominate the dwellings across the road, creating an urban character.  The land is a significant open agricultural space on the east of the village. The topography of the land is visually pleasing. Housing will cut into the natural slope. (Various individuals)  Para 9.211: need to consider all views, as well as the setting, not just views eastwards.  Site previously rejected for landscape reasons by SDNPA and prior to that by Chichester District Council- SDNPA landscape architect and conservation officer objected that any development on the site would close significant views to open countryside and harm the conservation area. (Various individuals)  This gap is not only an eloquent survival of the direct connectivity of pre-industrial settlements to their agricultural hinterlands, but it also contains the narrow end of a plot of unploughed damp meadow of a kind that is exceedingly rare on the fertile and highly farmed Upper Greensand geology.

Highways

 There is no footway connecting the village centre to the site and none can be created- detrimental impact on CA and overburdened infrastructure. (CDC councillor)  Construction would block the main entrance to more than 100 acres of arable land accessed by large equipment. There are two alternative access points to this land but both are on historic rural roads vulnerable to extra unsuitable traffic; the extra traffic on North Lane would be dangerous for users of the village shop. North Lane is already congested with heavy traffic (various individuals)  Neither of the alternative access points to the field are wide enough (given continuous on street parking, the narrow historic lanes they are on) for the modern agricultural vehicles which currently work on the field. (Various individuals)

554 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Traffic levels in the village have increased dramatically since construction of the Hindhead Tunnel, this would be worsened by development of this site.  Impossible to accurately predict number of vehicles on the site. Parking off site by residents is likely, causing inconvenience on surrounding streets and obstructing traffic on Elsted Road (various individuals)  Adding another entrance onto Elsted Road will make it dangerous (Various individuals)  Cannot leave to chance the risk of overflow parking on the street, to the detriment of the CA. Affordability

 The development does not propose enough affordable homes. In its current format, all it does is accumulate wealth for the landowner. Any development should be for affordable housing schemes. Drainage

 The road is subject to flooding due to runoff from the field, situation would be exacerbated by development (which would involve earth removal and concreting, and the creation of a ‘cliff face’. (Various individuals)  The proposal does not address surface water flooding risks  Drainage to the nearby stream would be environmentally wrong as it is a headwater of the River Rother used for drinking water. Heritage:

 The allocation does not conform to the first purpose, vision or objectives of the SDNPA regarding landscape (various individuals)  The site has already been rejected for planning applications by the SDNPA on grounds of impact upon Conservation area and surrounding landscape (Various individuals)

 The number of dwellings proposed cannot conserve and enhance the site, which currently makes a positive contribution to the Conservation Area. The effect on landscape and the CA is noted in the SA as ‘uncertain’ and given the density of housing, plus the need for car parking, the preservation and enhancement of the CA is unachievable, therefore unsound.  The village’s historical character is agricultural; this site will close the one remaining agricultural gap in the village centre removing views to open land from the conservation area. (Various individuals)

 The plan attempts to justify 5-6 properties and, because there actually is not space enough to do so within a plot depth comparable to those to west and east, the rear plot boundary has been pushed backwards by ten metres compared to the plots in the Conservation Area. This would be even more intrusive on the local landscape than would be a continuation of the historical linear development. (various individuals)

 The site should not be allocated by a National Park with a landscape-led plan, given that the Sustainability Appraisal finds the effects on landscape and cultural heritage to be ‘uncertain’

Density:

555 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 The site has the second highest density of any proposed LP allocation, twice the density used as standard by CDC, whose experience is that such densities outside urban environments cause problems. This density is inappropriate in a rural setting. (Various individuals)  The requirement to design ‘to a high standard’ is unachievable given the proposed density and provision of necessary car parking on site.  The number of dwellings the site can accommodate has been exaggerated so as to meet the threshold to be an allocation (5 dwellings) Dark Night Skies

 The site is adjacent to the main Dark Night Sky core zone, and would add to the light pollution visible from the village and from the Downs. Biodiversity:

 The adjacent area contains much wildlife which would be put at risk by development- an ecologically sensitive damp meadow and a habitat for reptiles. (Various individuals)  The impact of extensive new impermeable footings on the ecology of the adjacent damp meadow seems not to have been considered.

Infrastructure:

 Concerns over impact on schools, buses and parking. Alternative proposals:

 Propose no more than 2 dwellings, to be built at low level, parallel and adjacent to the Elsted Road, with a suitable footpath between the houses and the road. Land to the North of the proposed housing to be excavated to a lower level to facilitate appropriate access and parking for the new dwellings.

 Propose alternative brownfield site in Nyewood (address not specified) (Various individuals)

556 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD92: Stedham Sawmill There were a total of 15 responses to this policy. A summary of the main issues raised is set out below.

Specific consultation bodies – national agencies and utility providers Historic England: The need for a heritage statement should be in the policy not the supporting text to give it more weight. Natural England: Concern due to the close proximity of Iping Common SSSI which is a nationally protected heathland habitat of importance for heathland bird species including the ground nesting Nightjar. Ground nesting birds are vulnerable to disturbance from dog walking and cat predation. It is highly likely that the allocation will lead to an increase in recreational activity on the SSSI. Consideration must also given to any hydrological impacts (water quality/quantity). The SDNPA should provide evidence showing how this impact can be mitigated; however, NE are concerned that this may not be possible. NE seek evidence as to why alternative sites cannot be used and would advise against the allocation of this site. If alternative sites cannot be used and the allocation goes ahead then they ask that a clause is included to state that development will not be permitted unless it can demonstrate that it will not have a deleterious impact on the interest features of the adjacent SSSI. Southern Water: Additional local sewerage infrastructure would be required to accommodate the proposed development, allocation policy should require that the developer provides a connection at the nearest point of adequate capacity in the sewerage network Specific consultation bodies – other local authorities No comments received Parish and Town Councils Stedham with Iping Parish Council made the following key points:

 They expressed concerns about the site allocation in 2016 & 17. They continue to object and seek the removal of site so it can be addressed through their NDP. There has been a lack of consultation and not at a stage at which changes can be properly made.  Evidence base errors: Settlement Facilities Assessment is incorrect in terms of public transport accessibility; site was rejected in SHLAA 2014 but is now described as PDL and offering potential for heathland regeneration; and, ELR conclusions changed from ‘continue use’ to ‘consider alternative uses’.  Development does not relate to traditional settlement pattern for Stedham. Limited connectivity with village. Site will not integrate.  Significantly more than the 6 homes needed as identified by CDC.  Density too high; noise, traffic and access issue; trees not sufficiently buffered; Saxon shrine found near site access; impact on dark skies and vulnerable species; possible surface water flood risk on lower part of site and it adjoins public rights of way.

557 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Loss of employment on eastern side of site, opportunity for expansion in accordance with permissions lost. Site should be identified in SD25.  Impact on Stedham Common. Other organisations

 One individual sent in the a copy of the Stedham and Iping Parish Council response (see above)  Land south of Barlavington Way performs better against sustainability criteria and should be allocated instead (ICS Estates LTD)  NDP survey said residents wanted to protect employment land (Individual)  Not sustainable (South Downs Society)  Increase traffic, increased greenhouse gasses, limited bus service (Various individuals, South Downs Society)  Disconnected from village (South Downs Society)  The A272 verge joining the access road is designated as a Notable Road Verge for its invertebrate interest. This should be protected. (Sussex / Hampshire Wildlife Trust)  Noise generated by noise / pollution etc should not compromise homes. (The Midhurst Society)

Individuals

 Opposite Iping Common SSSI, within SSSI Impact Risk Zone and adjacent to deciduous woodland BAP priority habitat., in SA should be scored as likely adverse or adverse (Individual)  Loss of local businesses and jobs, not mitigated by allocation of part of site for B1. A permission has not been built, so can't guarantee existing businesses will have alternative accommodation. (Various individuals)  No potential for heathland regeneration if B1 uses to be relocated onto that part of the site. (Individual)  Limited public transport  No mention of dark night skies (Individual)  Village grew around R Rother, not the A272. Separated from road by fields and woodland. Will harm setting, limited connectivity with village, damage historic landscape setting of village. (Various individuals, South Downs Society)  CDC identify need for 6 homes, no need for private housing. (Various individuals)  Plan is site led, not landscape led (Individual)  No consideration of alternative sites in Stedham, rejected in SHLAA (South Downs Society, Individual)  Lack of consultation (Individual) HMPC made the following comments on behalf of the landowners:

 Site suitable for residential development to meet OAN, employment uses have proven to be unattractive. Object to requirement for mixed used development.  Evidence contains some errors and the Local Plan has failed to take into account adequately the OAN and has applied the methodology for meeting OAN erroneously. The South Downs has the ability and capacity to accommodate further housing.  The plan will not deliver sufficient affordable housing.

558 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 The site is PDL, in a sustainable location, and deliverable. It is identified in the SHLAA as having potential for 30 and the Employment Land Review recommends reallocating the site.  Protected species are limited to those that use woodland edges.  Site has been actively marketed for employment uses.  Viability will effect quality of development.  Housing will support local school.  Suggest allocating for 40 homes which would provide affordable housing.  NDP consultation shows support for development of the site.

559 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD93 Land South of Church Road, Steep There were a total of 7 representations on this policy. A summary of the main issues raised is set out below.

National agencies Historic England: Historic England would prefer to see reference to Heritage Impact Assessment or Archaeological Assessment or both, with important archaeological remains or other historic features retained in situ wherever possible, or, where not possible, recorded for deposition within a public archive.

Borough, City, County and District Councils No comments received.

Parish and Town Councils

 Steep Parish Council has made the following comments: o Incorporation of the site into the settlement boundary is welcomed, which will make possible a number of alternative futures for the village. o The site has long been recognised as one of the better potential alternatives for modest development in Steep. o There is also a proposal to include a parcel of land south of the village hall car park to be considered in conjunction with the allocation site. o The potential of 8 to 12 units seems reasonable, however the precise number should wait completion of detailed architectural and landscaping work, and public consultation.

Other organisations

 Supportive of the Plan but not able to comment on the appropriateness of 8-12 dwellings since detailed surveys have not been completed. (Steep In Need Charity)  Site should be reassessed to ensure that the existing biodiversity value has been properly considered. Policy should be reworded to ensure a consistent approach to assessments and net gains, with all allocations including a requirement for up-to-date ecological information and conservation and enhancement of biodiversity. (Sussex/Hampshire Wildlife Trust)  The proposed allocation of land south of Church Road, Steep should be deleted and the land south of Barlavington Way, Midhurst should be allocated for development instead. (ICS Estates Ltd.)  Allocation of site for 8-12 dwellings is entirely inappropriate and unjustified. There has been no previous public consultation. Site is currently protected as Open Space/Village Green – Saved Policy R4 of the East Hampshire Local Plan Second Review was not removed on adoption of the East Hampshire Joint Core Strategy. The Steep Parish Plan (2012) made clear the wish for this site to be for community benefit – e.g. sale of local produce, visitor

560 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues centre, car parking, allotments, an orchard, village shop, village green, leaving as it is – only one reference is made in the Parish Plan to housing. (Save Our Village Green)

Individuals

 The site was donated in trust for the benefit of residents for growing fruit/vegetables etc. Up to 12 houses on this small site would not be in keeping with the size of houses on Church Lane.

561 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD94 Land at Ramsdean Road, Stroud There were a total of 7 responses to this policy. A summary of the main issues raised is set out below.

Specific consultation bodies – national agencies and utility providers Historic England welcomes the policies in the wider plan in relation to Heritage Impact Assessment and Archaeology Assessment but would prefer that criteria were added to each site allocation policy. Southern Water note that there is currently sufficient capacity in the water and sewerage networks to accommodate the development but that an easement is required which should inform the site layout. Specific consultation bodies – other local authorities Hampshire County Council supports the pedestrian and cycle access criteria and the pedestrian link to Stroud Footpath 703. Parish and Town Councils

Stroud Parish Council support the allocation and raise the following comments  Support for the ecosystem services policy  Request for early and better engagement with local communities  Query the reduction in the settlement boundary on the eastern side of the Parish Other organisations and individuals

 Support for the allocation and the additional housing to support the existing settlement and rural economy (Hall and Woodhouse Ltd)  Support for the allocation but request that the policy is amended as the current description of the site is inaccurate and the ability to provide pedestrian and cycle links would be outside of the allocated site and not in control of the applicant (CALA Homes (Thames) Ltd (Craig Burden)).  Objection to the inclusion of the site as the site scores poorly in the SDNPA Settlement Facilities Assessment Report and a LVIA has not been carried out. The site should be deleted and Barlavington Road, Midhurst should be included instead as a more sustainable option.

562 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD95: Land South of Heather Close, West Ashling There were a total of 4 responses to this policy. A summary of the main issues raised is set out below.

National agencies Southern Water: Additional local sewerage infrastructure will be needed in the form of a connection to the nearest point of adequate capacity. This requirement needs to be included within the policy. Borough, City, County and District Councils No comments received Parish and Town Councils No comments received Other organisations

 Land south of Barlavington Way, Midhurst has been subject to a detailed LVIA, land south of Heather Close has not. It is also in a more sustainable community than the site at West Ashling. (ICS Estates LTD)  Inconsistencies amongst the allocations in terms of biodiversity requirements. Reassess site to ensure that existing biodiversity value has been considered. Up-to-date ecological information should be required through the policy along with enhancements to biodiversity on the site. (Sussex and Hampshire Wildlife Trusts)  Support (The Chichester Society)

563 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy SD96 Land at Long Priors, West Meon There were a total of 15 representations on this policy. A summary of the main issues raised is set out below.

National agencies No comments received.

Borough, City, County and District Councils

 Welcome parts 1(c) and 2(a) of policy which seeks to secure a publicly accessible footpath link from the development to the nearby West Meon Footpath 8. (Hampshire County Council)

Parish and Town Councils

 West Meon Parish Council has made the following comments: o Object on access grounds. Proposal will result in an increase in traffic and transport particularly along Church Road. o Object to extension of the built form – there will be a potentially harmful visual impact on longer views which is contrary to the Village Design Statement. o Attention is drawn to the protection of existing public rights of way. o There are historical and potential flood risks of the site. It is also susceptible to surface water. Request that measures should be put in place to ensure that development protects the integrity of Long Priors with respect to flooding.

Other organisations

 Support allocation – relates well to existing settlement pattern, is sustainably located for local shops and services (in both West Meon and Petersfield & Winchester), and links to public footpath network. (Metis Homes Ltd)  Site should be reassessed to ensure that the existing biodiversity value has been properly considered. Policy should be reworded to ensure a consistent approach to assessments and net gains, with all allocations including a requirement for up-to-date ecological information and conservation and enhancement of biodiversity. (Sussex/Hampshire Wildlife Trust)

Individuals

 Object to site as it will affect access to existing garages, there is bad lighting in the area, and concern over sewerage capacity.  Will affect on views from existing properties and from the public footpath.  Road is already over-used, lorries are not able to turn/often blocked by emergency vehicles, limited road width, there are no pavements, dangerous for school children crossing the road, parking pressures.  The school is full.

564 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Contrary to the Village Design Statement.  Would lead to more dependence on the private vehicle, and vehicular emissions, for transport contrary to NPPF. There is little local employment and only a limited bus service.  Site is located wholly in Groundwater Protection Zone 2 and within a groundwater Flood Alert Area (as advised by Environment Agency). The West Meon Specific Action Plan identifies flood risk for groundwater in West Meon as ‘High’. Therefore allocation is not justified.  There are other more appropriate sites to fill the local housing need which have less impact on the environment, landscape, child pedestrian safety and groundwater risk.  There are alternative opportunities for development through windfall sites,  Water resources in the area are already horrendous.  Development will create extra noise.  Loss of wildlife e.g. owls and bats driven away.  More light pollution will be lost due to light pollution.  Development will create hardship for people that have paid a lot of money for a quiet village life with views. Storeys Meadow should be extended instead as it impacts on fewer people.

565 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Monitoring and Implementation Framework There were a total of 3 representations on this section. A summary of the main issues raised is set out below.

National agencies No comments received

Borough, City, County and District Councils

 Amend Figure 10.2 , section relating to policy SD10. The first target should be amended from ‘no more than 30 new dwellings’ to ‘no more than approximately 43 new dwellings’, to reflect the latest evidence and emerging Wealden Heaths Phase II Supplementary Planning Document. (East Hampshire District Council)

Parish and Town Councils

 The NPA needs more resources of its own for enforcement to ensure the policies are being upheld in practice, especially with regard to destruction of trees and hedgerows in advance of planning applications being submitted. Partner district councils, currently relied on for enforcement, do not share the SDNPA’s priorities. (Owslebury PC)  The Plan is often over-cautious, defensive, lacking in authority, tentative and uninspiring. Are any actions proposed if policy SD33 is not being achieved? (Colemore and Priors Dean PC)

Other organisations

 No comments received

Individuals

 No comments received.

566 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Appendix 2: Local Plan Policies Superseded by the South Downs Local Plan There were a total of 5 representations on this appendix. A summary of the main issues raised is set out below.

National agencies No comments received Borough, City, County and District Councils

 Omits policy RT2 from the Winchester District Local Plan Review (2006) (Winchester City Council)  Cross check with Appendix. 4 of EHDC’s Housing and Employment Allocations Plan. (East Hampshire District Council)  East Hampshire 2006 Second Review Saved Policies E1, GS3, GS4, R2, R3 were replaced by the East Hampshire Joint Core Strategy. Saved Policy E1 is misnamed. (East Hampshire District Council)  Please confirm status of East Hampshire 2006 Second Review Saved Policies C14, T8, T13, IB5, LC1 and U12. Recommend mentioning all Second Review saved policies, including those not relevant to the National Park. (East Hampshire District Council)  East Hampshire Joint Core Strategy: Policy CP32 has been omitted. Unclear why policy CSWB1 has been included. (East Hampshire District Council)

Parish and Town Councils

 Request that Wealden 1998 Local Plan Saved Policy VB7: Old Willingdon Road and Western Downlands Housing Policy Area should continue to be saved, since it supports the Village Design Statement and is relevant to SDLP policies SD4, SD5 and SD25. (East Dean and Friston Parish Council) Other organisations

 No comments received. Individuals

 Fully support all retained policies from 2003 Lewes District Local Plan, except policy LW9 Lewes Battlefield, which is not currently effective; planning applications in the area give little or no regard to the Battlefield designation or consultations with Historic England. Propose change to require all applications within the site to include consultation with Historic England, and no permission which would affect the Battlefield’s landscape, setting or archaeological integrity.

567 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Glossary There was 1 representation on this policy. A summary of the main issues raised is set out below.

National agencies No comments Borough, City, County and District Councils No comments Parish and Town Councils Colemore and Priors Dean PC:

 Gypsies and Travellers: delete ‘or permanently’ (out of date); misspelt ‘dependants’  Habitat Regulations Asssessment: should be ‘Habitats ‘  Manege: ‘menage’ not acceptable alternative spelling.  National Nature Reserves- Duplicate definitions  Non-retail town centre uses: revise wording and punctuation. Why not less intensive speort/recreation uses as well?  Parish Plans: inconsistent with para 1.41, which says they may be material considerations  Public Rights of Way: could add that rights may be subject to Traffic Regualtion Orders  Right to Acquire- delete second use of ‘population’  Special Area of Conservation- Duplicate definitions

Other organisations No comments

Individuals No comments

568 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Policy Map There were a total of 46 representations on this policy. A summary of the main issues raised is set out below.

National agencies No comments received Borough, City, County and District Councils East Hampshire District Council:

 Need to give consideration to settlement boundaries that currently overlap the National Park boundary at  Little Hyden Lane, Clanfield  Bowes Lane (Woodhouse Ashes Farm), Rowlands Castle  Fullers Road, Binsted  Upper Farringdon- Map should acknowledge the new allocation VL2 outside the National Park, which is now within the settlement boundary. Winchester City Council:

 Should provide inset maps showing settlement boundaries for Bishops Waltham, Swanmore and Wickham, where those boundaries extend into the National Park. Parish and Town Councils

 Support map for their settlement (Petersfield TC)  No comment; development unlikely to occur in the area of the parish within the National Park (Whitehill TC)  Support proposed settlement boundary for Hambledon (Hambledon PC)  Remove both allocations in South Harting and withdraw proposed settlement boundary from them (Harting Parish Council)  Remove settlement boundary for Owslebury, which is not needed in principle, and divides neighbouring properties and cuts through individual properties. (Owslebury PC)  Retain land at Audiburn Stables in the settlement boundary (development potential); mapping out of date, conduct new survey and review application of 10 metre principle accordingly; revise boundary in the area of the Pump House, inconsistent with the allocation map (Kingston-near-Lewes PC)  Query why the road surface of Station Road, Elsted has been mapped as a Local Nature Conservation Designation (Elsted and Treyford PC)  The draft NDP for Rogate proposes an alternative boundary for that village- when will this boundary be incorporated into the Local Plan? (Rogate PC) Other organisations Local Green Space

 Remove land at Borough Hill House, Petersfield, from the G8 NDP Local Green Space designation. Believe its inclusion results from a mapping error. (WYG)  Delete Tide Mills, Seaford as a Local Green Space designation (Port of Newhaven)

569 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues Settlement boundary amendments

 Object to removal of settlement boundary from all gardens along Summerdown Lane, East Dean, in particular no. 28; current boundary natural and logical.  Boundary for Stroud should include Seven Stars PH and its plot; the land has settlement boundary on three sides of it; contains built development and a key community facility; boundary methodology approach to community facilities illogical; should take a settlement specific approach to drawing boundaries; settlement boundaries should include the built form of a settlement and closely associated infill land. (Hall & Woodhouse Ltd) Local Wildlife Site

 Remove Racecouse Hill Local Nature Conservation site from the Lewes map, as ill - conceived and impractical. Propose including Landport Bottom SNCI in its place. (N J Stokes Architect) Other

 Widespread brown stippling representing mineral safeguarding areas makes the maps difficult to read (Chichester Society)  There is no proposals map for the area around Sompting, therefore the application of the NPPF to land west of Steepdown Road, Sompting, is uncertain. (Thakeham Homes Ltd)

Individuals Support (Strongly) support the settlement boundary for Selborne (Various respondents) Support the reduction of the settlement boundary around the eastern edges of Greatham

Principle of settlement boundary  Reinstate deleted boundary for Fulking, and then extend it to include commercial site at Lower Kents and permanent Gypsy sites at Market Gardens and the Coniferes, since these sites contribute to the social and economic vitality of Fulking.

Settlement boundary changes  Boundary for Buriton should include ‘Windyridge’, Bones Lane. General tendency of reducing settlement boundaries will have impact on windfall delivery, a high rate of which is relied on in the housing supply. Risk assessment on this should have been carried out. Exclusion of Windyridge is inconsistent with the boundary review methodology- the house is not large or set back from the road, the garden does not stretch away from the rest of the settlement.  Boundary for South Harting should exclude land north the stream behind Rooks Cottage: this is an orchard so should be excluded according to the boundary methodology  Village Envelope for Clapham should include ‘Shutters’ and ‘Merrygarden (Waterford House)’: properties to their north and south are included in the envelope, they are older than the properties to their south, and they have received planning permissions in the past which demonstrates they are in the village envelope.  Village Envelope for Clapham should include the whole plot of Gosling Croft Business Centre, not just the built up area.  Boundary for Chawton should include large ‘garden’ area to the west of ‘Glencairn’, Winchester Road. NPPF para 28 and 55 mean that settlement boundaries should be defined

570 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues flexibly. The land is well bounded by roads, hedgerows and a bund; is not an important open or landscape gap that contributes to the setting of the village; and development on the site (especially single storey) would have minimal or negligible impact on the village’s character, Development would be necessary to protect the facilities in the village.  Boundary for Kingston-near-Lewes should exclude the proposed allocation at Castlemer Fruit Farm (various respondents)  Boundary for Kingston-near-Lewes based on out-of-date map, does not show extension to ‘Slade’ which would require the boundary to be pushed back. In addition, boundary should not be extended at the more prominent east side of the village and reduced at the less prominent west.  Boundary for Kingston-near-Lewes: Retain land at Audiburn Stables in the settlement boundary (development potential); mapping out of date, conduct new survey and review application of 10 metre principle accordingly; revise boundary in the area of the Pump House, which is too large.  Methodology has been applied inconsistently in Selborne, with the garden of Jasmine Cottage, Gracious Street, being excluded, while the neighbouring garden and the new build next to Seale Cottage are included. (Various respondents)  Boundary for South Harting: Delete allocation sites SD90 and SD91 and remove them from the boundary.

 Boundary for Stroud based on out-of-date map, does not show extension to 54 Winchester Road which would require the boundary to be pushed back. However, would prefer boundary to be retained as per East Hants Local Plan, to allow for house to be rebuilt further from the road.  Boundary for Owslebury should probably follow the village envelope; requires revision.  Boundary for Owslebury is irrational and incompatible with what exists on the ground today; e.g. excludes houses built in 1961 and 1964, and also the 700 year old church. Disagree with policy of drawing boundaries through gardens, except in the most extreme cases. Propose alternative boundary.  Boundary amendment at Alma, West Meon, contradicts the principle that minor isolated bites should not be taken out of otherwise strong and straight settlement edges.  Boundary for Greatham: Object to its extension across ten houses at the western end of the village. This area is intimately connected with the countryside and development there would harm the open character of the village and conservation area. Also, object to the extension of the boundary across the school and its playing fields, and the proposed allocation at Liss Forest Nurseries.

Other  Question mark concerning the map of Selborne  SD9 designations should be properly considered, not simply carried across to the Local Plan. Unclear why land west of Lewes, south-east of the Old Racecourse, has been designated as such.  Designated battlefields must be plotted on the policies map with their actual boundaries, not just marked by a symbol.

571 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

Sustainability Appraisal / Strategic Environment Assessment There were a total of 22 responses to this policy. A summary of the main issues raised is set out below.

National Agencies

 No comments received Borough, City, Council and District Councils

 No comments received Parish and Town Councils

 Cheriton Parish Council – allocation SD63 Hinton Marsh is not in line with social, environmental and economic considerations and therefore the purpose of the SA has not been met. The site is some distance from Cheriton village centre, close proximity to source of River Itchen SAC, lack of pedestrian footpath, no lighting, infrequent public transport, poor vehicular access. 12-15 homes is an increase on that assessed as part of the consideration of the reasonable alternatives. Reliance on planning applications to demonstrate purposes and duty are being met is inappropriate.  Harting Parish Council - assessment is overly simplistic. The housing, vitality of communities and local economy are interdependent objectives and act as proxies for one another. The allocations are not driven by a landscape led plan. SA should preferentially assess sites that have no, or very limited, landscape impact but is instead driven by a predetermined list of settlements chosen because they should be allowed an element of growth. Many sites have an uncertain or potentially negative impact on landscape. The Sustainability Appraisal does not support the allocation of the sites in Harting.  Stedham Parish Council – scoring of public transport for Stedham is same as for Midhurst, therefore incorrect. Other organisations

 SD64: Land South of London Road - Challenge the landscape and biodiversity assessment of the site against sustainability criteria. More detail set out in summary of responses to SD64 (Barlavington Estate)  Add to Sustainability Appraisal Objectives - ‘Reducing the impact of individual vehicles and numbers of vehicles on the landscape quality (including the setting within which the landscape sits), tranquillity and safety of vulnerable groups within and around the National Park’. This would complement other objectives (Campaign for better Transport, East Sussex)  SD64: Land South of London Road – appraisal is flawed and therefore so is the plan which relies on it. It is simplistic, superficial, unhelpful. Inconsistent or incorrect assessment of the impact of site in the SA and the Major Development Assessment. The assessment fails to acknowledge the significant adverse effects and that they cannot be effectively mitigated. (Coldwaltham Meadow Conservation Group)  None of the options for Shoreham Cement Works have been tested in respect to viability and deliverability. The viability needs to take into account the investment required for a restoration scheme. (ECE Planning)

572 South Downs Local Plan: Pre-Submission Consultation (Sept – Nov 2017)

Summary of Issues

 Table 1.2 should include which of the four ecosystem services will be delivered by which sustainability objectives. (Forestry Commission)  Include Cookbridge in the list of settlements considered suitable for development. Reassess village through Settlement Facilities Assessment and SA. (Rydon Homes Ltd)  SD93 Land South of Church Road, Steep is inappropriate and unjustified as it has not been subject to consultation, it is allocated as open space / village green in East Hants Development Plan. The Parish Plan identifies it as an area for a more effective village centre. (Save our Village Green) Individuals

 Too much emphasis on housing, insufficient attention to landscape.  The impact on Coldwaltham as a whole has not been sufficiently considered.  The process is not transparent.  Doesn’t take into account impact on neighbouring landowners.  Query where is evidence to increase housing in Easebourne from 16-30 up to 50. How has a settlement with insufficient capacity for 20, become suitable for 50 homes.  Judging growth on sustainability means areas where housing is required to make them sustainable become even more remote and the sustainable areas become ever larger. That cannot be sensible.  Information required for the SA is not included.  Appraisal of site SD63 South of A272 Hinton Marsh is illogical and inaccurate particularly in relation to proximity and impact on River Itchen, landscape impact, cultural heritage, accessibility and climate change.  Definition of Gypsy and Traveller is incorrect.  The SA does not support the assertion that the Local Plan is landscape led: the majority of allocated sites have at best an 'uncertain' landscape impact. Many also have uncertain biodiversity and / or cultural heritage effects.  Allow small-scale development in settlements without a boundary, particularly on previously developed land.  Find better alternatives to current allocations.

573