Response from Arun Countryside Trust to call for evidence for Julian Glover’s Review of National Parks and AONBs
SUMMARY OF OUR PROPOSALS TO THE REVIEW
Proposal 1: The National Park system requires better integration and culture change to reduce the need for Judicial Reviews and to ensure countryside conservation /protection are seen as vital in combating climate change.
Proposal 2: Faced with escalating species and habitat loss and climate change, NPs and AONBs need to have a role and powers which more effectively influence behaviour by other government departments and their contractors, and by local authorities and communities.
Proposal 3: All public organisations should be required to ‘own’ the National Parks’ Purposes in their areas.
Proposal 4: As employment of ecologists by other Local Authorities has dwindled, it is vital that National Parks employ ecologists to inform and challenge their staff and Partners.
Proposal 5: National Parks should identify, survey, monitor and support the management of all areas which would meet SSSI criteria even if there is not a need to designate because of the ‘representativeness’ criterion.
Proposal 6: National Parks need to be given a clear mandate to conserve and enhance ‘green infrastructure’ linking National Parks to areas outside them – for instance, hedges, streams, belts of woodland, footpaths.
Proposal 7: National Parks could do more to support cultural heritage volunteer groups, including intangible cultural heritage, which can be more at risk than tangible. Facilities, resources and targeted continuing support with interventions when needed should contribute to sustaining cultural heritage in all forms.
Proposal 8: An improved web-based system is required for reporting vandalism to protected monuments and to archaeological sites.
Proposal 9: The reform of the current system of farm payments must recognise that without BPS, payment to farmers for sustaining or where necessary enhancing the environment for public benefit must become a profit source in its own right, and not merely a compensation for income foregone.
Proposal 10: National Parks should be given a remit and funding to work with local authorities and where appropriate national bodies, in order to promote Sustainable Transport solutions in their areas and environs.
Proposal 11: It would be helpful if there was a higher proportion of Secretary-of-State-appointed Members (7 at present) and if the process of appointing them could be easier, simpler and more transparent. There should be a minimum quota of active land managers. The nomination process for S-of-S-appointed Membership should include some democratic process.
Proposal 12: VED should be dedicated to ‘green’ initiatives which would counter the pollution and carbon emissions caused by road transport – such as funding a major programme of Sustainable Transport investment. The new road-building programme should be abandoned, at the very least in all schemes which impact on National Parks and AONBs.
Proposal 13: The boundary designation process should consider solely the criteria for National Park designation, and planning of transport or other major development should then be reshaped to as to have regard to the Purposes of National Park designation. This also applies to boundary changes.
Proposal 14: The process for designating boundaries of NPs, or for considering changes to designated boundaries, must be supported by an adequate budget for new ecological, archaeological and landscape connectivity survey work to inform the decision.
Part 1: Opening thoughts
- [recent picture, and ‘what makes National Parks and AONBs special to you’]:
(Photo supplied)
Laying the hedge along Public Footpath 342 at Binsted within the South Downs National Park, with the help of South Downs National Park rangers, Spring 2018. Photo credit: ACT/MAVES
The existence of National Parks, especially the South Downs National Park, makes me feel our most precious landscapes, countryside and wildlife are being protected and cared for. I particularly appreciate the way National Park Rangers help with countryside improvement projects promoted by local people, such as the hedge-laying project by MAVES, the executive committee of ACT, within the South Downs National Park at Binsted.
Yes, you can use my photo online or in the report.
- [What do you think works overall about the present system of National Parks and AONBs in England? Add any points that apply specifically only to National Parks or AONBs.]
Whether the system ‘works’ is being tested, because National Parks are under threat. The South Downs National Park took legal action to protect the National Park from damaging new road development on the A27 (the Arundel bypass), although the road scheme is supported by County and District Councils and MPs. This is an admirable example of a National Park trying to ensure a government-owned body (Highways England) respects the planning legislation intended to protect National Parks.
[What do you think does not work overall about the system and might be changed?]
More details of this problem illustrate the pressure the National Park is under. Current planning policy (NPPF Para 172) states that planning applications in designated areas should consider ‘the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way’. This legislation is not being respected in Nationally Significant Infrastructure Projects.
For instance, in the current A27 Arundel Bypass scheme, Highways England only presented three options, all of which damage the South Downs National Park. The May 2018 Preferred Route decision chose an option with a long stretch of new road through the National Park. Highways England did not sufficiently research options outside the National Park and has not shown that there are ‘exceptional circumstances’ (as required by the NPPF, same paragraph) justifying the decision. The South Downs National Park applied for a Judicial Review of the decision which was granted, but then withdrawn when Highways England decided on a another non-statutory consultation in spring 2019 on exactly the same three routes, but agreeing to give reasons why previously considered routes outside the National Park were not suitable .
The problem is not with the remit of National Parks, but with a structural failure to ensure that other government departments and government-owned organisations can and must think outside their silo – in the case of Highways England, outside the silo of a remit to build what roads they can – so as to ‘have regard to the purposes’ of the National Park. There is a case for legislation being strengthened so that other Government departments are not just supposed to 'have regard for' the purposes of the National Parks but must actively support NP principles and work together to do so.
Proposal 1: The National Park system requires better integration and culture change to reduce the need for Judicial Reviews as well as, importantly, in the spirit of seeing countryside conservation /protection as vital in combatting climate change.
Another general point: Designation of land as a National Park is equivalent to or higher than other designations such as an SSSI or Ancient Woodland. However this protection is not widely enough understood. For instance, the Arundel bypass scheme shows that Highways England thinks SSSIs and Ancient Woodland are important, but not the National Park. Education of the public and other government departments is needed.
Part 2: Views
- [What views do you have about the role NPs and AONBs play in nature conservation and biodiversity?]
The SDNP has promoted major initiatives, through its Partnership Management Plan, such as the South Downs Way Ahead Nature Improvement Area 2012-2015. This was a very effective DEFRA ‘pilot’ project. However, while the pilot project has contributed to balancing the SDNP biodiversity ‘ship’, both pilot and ship now find themselves overtaken by a major storm, with the news that we are facing a mass extinction of wildlife.
It is no longer acceptable, for example, that Highways England should act with a presumption that they can build a major new road through an exceptionally biodiverse area unless the South Downs National Park Authority prevents them.
Proposal 3: All public organisations should be required to ‘own’ the National Parks’ Purposes in their areas.
Proposal 4: As employment of ecologists by other Local Authorities has dwindled, it is vital that National Parks employ ecologists to inform and challenge their staff and Partners.
- [Could they do more to enhance our wildlife and support the recovery of our natural habitats?]
Yes.
An example is Binsted Woods, within the SDNP, at 100 ha the largest area of semi-natural woodland on the West Sussex coastal plain, and at risk from the current Arundel Bypass Preferred Route. The site was considered for SSSI status in the late 1980s but turned down as its ‘stand types’ were already represented.
Proposal 6: National Parks need to be given a clear mandate to conserve and enhance ‘green infrastructure’ linking National Parks to areas outside them – for instance, hedges, streams, belts of woodland, footpaths.
- [What views do you have about the role NPs and AONBs play in shaping landscape and beauty, and protecting cultural heritage?]
The SDNP has a strong ‘cultural heritage volunteer’ base of people who got involved in the LiDAR project ‘Secrets of the High Woods’, 2015-17, interpreting the results of the digital aerial mapping survey in the wooded areas of the National Park. Though the project has ended, these people continue to meet at the SDNP headquarters and have various new projects.
One successful aspect of the LiDAR project was that it uncovered a large amount of new potential cultural heritage ‘monuments’ (such as a prehistoric field system over most of the wooded area, only a small part of which was known before) and the true route of the Roman Road from Chichester to Arundel. The problem of caring for these monuments in the future (and also for those that were already known) is a difficult one.
This would have a cost in monitoring and responding, but would be good value for money because it would mobilise and utilise the free resource of volunteers (who include members of Archaeological Societies). They are ideally placed to keep an eye on archaeological sites which form part of our cultural heritage.
- [What views do you have about the role NPs and AONBs play in working with farmers and land managers and how might this change as the current system of farm payments is reformed?]
As I understand it, the farm payments from the EU are based largely on area, and may be replaced by a new system of farm payments based on conservation. This could be a change for the better. If the change happens, National Parks and AONBs will have an important part to play in helping landowners apply to the new system and helping to inspect and facilitate its effectiveness.
In ACT’s part of the SDNP, the Arun Adur Farm Cluster Group provide an effective mechanism for farmers to work together with the SDNP to coordinate their environmental work as a community.
Otherwise, many environmentally beneficial smaller farm businesses will cease at their core to be viable, and the National Parks’ environment and communities will suffer.
- [What views do you have about the role NPS and AONBs play in supporting and managing access and recreation?]
Keeping paths and gates in good condition, and improving the accessibility of information about the areas the paths pass through, are important activities which I think the SDNP is already putting into effect, either directly or in partnership with other local authorities. Access to the SDNP via public transport, instead of by car, could however be greatly improved.
For example, Ford Station south of Arundel could be an ideal access point to the relatively flat SDNP countryside around Arundel south of the A27, and the Arun river valley, for communities all along the south coast from Portsmouth to Brighton. But onward routes by foot and bike are poor to start with. You have to walk along busy Ford Road to get to the smaller lanes and footpaths of Tortington and Binsted and the river path along the Arun. A short new section of east-west public footpath north of the railway line, linking Ford Station with the north-south public footpaths from Binsted to Yapton, would improve access. Ford Station should have a sign ‘Gateway to the South Downs National Park’.
A dedicated cycle path alongside Ford Road (from Ford Station to Arundel) would also improve access to the National Park from Ford Station, as well as giving better access to the station for commuting for Arundel, Tortington, and villages nearby.
At present the A27 (Fontwell to Arundel) prevents easy access to the SDNP further north, except for the tunnel at Fontwell. Some right-of-way footpaths do cross the A27 between Fontwell and Arundel, but apart from signs indicating ‘Pedestrians crossing’ there is no reason for traffic to slow down, and it does not. These crossings are too dangerous to use unless walkers are prepared to take their life in their hands. Bridges across the A27 at Hundred House Copse (just east of the A27/B2132 junction) and at Hospital Hill (just west of Arundel) would greatly improve access to the rest of the SDNP and also help reduce car-dependency.
These infrastructure projects would need funding, but the SDNP could be instrumental in lobbying for such better access.
- [What views do you have about the way NP and AONB authorities affect people who live and work in their areas?]
National Park rangers in the SDNP, both volunteer and professional, are working well in community groups and help them connect with the countryside and learn new skills and understanding. An example is the hedge-laying project mentioned above (Question 6).
- [What views do you have about the role NP and AONB authorities play on housing and transport in their areas?]
Senior Planning Officers and those in charge of planning policy in the SDNPA have a flexible, strategic and creative view of the purposes of the National Park and apply it. More junior Planning Officers responding to individual applications are sometimes felt to show an excessively cautious and less understanding approach.
The SDNP Local Plan is taking a very positive approach to meeting housing need in predominantly small, well-designed developments that are integrated with existing settlements and redress the affordability balance.
Part 3: Current Ways of Working
- [What views do you have on the way they are governed individually at the moment? Is it effective and does it need to change? If so, how?]
The SDNPA has been criticised for being an ‘unelected quango’ and having a ‘democratic deficit’. This is false since National Parks are neither a quango, nor unelected. Most of a National Park’s ‘Members’ have been voted for as Local Authority councillors, but not in their capacity of an NP Member.
The SDNPA ensure that its Officers and Members are in dialogue with relevant regional and sectoral expertise by regular meetings with an Advisory Partnership Board. This mechanism is supported and to be recommended. We also support and recommend to other NPs a regular joined-up liaison of the leading Officers with, collectively, (a) the land managers (in our case the South Downs Land Managers association), and (b) the conservation organisations (in our case the South Downs Network, [of which the ACT is a member]).
- [What views do you have on whether they [NPs] work collectively at the moment, for instance to share goals, encourage interest and involvement by the public and other organisations?]
National Parks England is very successful and ACT warmly supports its current leadership.
- [What views do you have on their efforts to involve people from all parts of society, to encourage volunteering and to improve health and wellbeing?]
I agree and support this and think the SDNP is doing a good job and making progress.
- [What views do you have on the way they are funded and how this might change?]
National Parks (and other environmental structures such as the SSSI system) are scraping by on too little funding.
National Park actions deliver all sorts of benefits that do have positive economic consequences but are rarely counted (like better access, people taking more exercise and reduced NHS bills) – so that funding for National Parks is not a “cost”, it is an “investment”. This should be acknowledged in their funding.
Global warming is now an accepted fact, yet the UK government has just announced a £30bn road-building programme which will massively increase transport emissions. This is to be funded by setting aside Vehicle Excise Duty to this sole purpose.
- [What views do you have on the process of designation – which means the way boundaries are defined and changed?]
The boundary of the South Downs National Park at Arundel, Tortington and Binsted was affected by ongoing plans for an Arundel Bypass. This was a failure of process and failed to have regard to the Purposes of the National Park.
Arundel town, and part of the watermeadows, were first included, then excluded. Tortington Common was first included, then excluded (because of the proposed bypass route across it), then included again (when that bypass scheme was cancelled). Binsted and Tortington south of the woods (‘Walberton to the river Arun’) were stated in 2001 to meet the NP criteria.[1] But the draft boundary of 2002 was more restricted, and may have been influenced by the South Coast Multi Modal Study’s bypass research in 2002 (which studied a bypass route south of the woods).
The SDNP designation process was not sufficiently informed:
- In his 2006 decision defining the new NP boundary, the Inspector gave reasons why he did not include the whole of Binsted as many respondents were suggesting. He did not consider it to be ‘countryside of especial importance’.
Since that time, new research by MAVES (www.maves.org.uk) in 2015-18 has shown how important the countryside outside the wooded areas is to wildlife both at Binsted and at Tortington.For instance, 14 of the UK’s bat species have been found in the area, which puts it on a par with sites such as Ebernoe Common (a National Nature Reserve) and the Mens (a Nature Reserve), and bats forage widely in the adjoining countryside.
- There have also been new historical discoveries at Binsted due to the SDNP’s LiDAR project – including the Binsted Hundred Moot Mound.[2] This discovery means that the landscape of Binsted can now be seen as an early mediaeval ‘landscape of governance’, including tracks leading to the Moot Mound and the steep valley next to it which would have provided acoustics enabling people to hear speakers.
- The Arun valley is part of a wildlife ‘corridor’ from north of the Downs to the sea, with an SAC to the north at Pulborough.
The boundary history, and the new MAVES research and the historical research, suggest there is a case for extending the boundary of the National Park at Binsted, Tortington, and Arundel.
- [What views do you have on whether areas should be given new designations? For instance, the creation of new National Parks or AONBs, or new types of designations for marine areas, urban landscapes or those near built-up areas?]
Designation is a vital planning tool and these are all good ideas. In terms of urban and peri-urban landscapes, a Sustainable Transport Development Area designation could be considered.
- [Are there lessons that might be learnt from the way designated landscapes work in other parts of the UK, or abroad?]
This is not something ACT has any special knowledge of.
Part 4. Closing thoughts
- [Do you think the terms currently used are the right ones? Would you suggest an alternative title for AONBs, for instance and if so what?]
The name AONB is easier to remember than three-letter acronyms such as LWS, LWA, SAC, SCA etc.
The term ‘National Park’ means a lot to people and should certainly not be changed.
- [The Review has been asked to consider how designated landscapes work with other designations such as National Trails, SSSIs, SACs, NNRs, and SPAs. Do you have any thoughts about how these relationships work and whether they could be improved?]
The system is rather opaque – for instance it is not clear what the difference is between a National Nature Reserve such as Ebernoe Common, and a Nature Reserve such as the Mens. SPAs are named ‘Special Protection Areas’ on the internet, but ‘Special Protected Areas’ in this questionnaire.
I know very little about SACs, NNRs or SPAs.
- [Any other points not covered above?]
The proposals suggested above are copied here for convenience.
Proposal 1: The National Park system req
uires better integration and culture change to reduce the need for Judicial Reviews as well as, importantly in the spirit of seeing countryside conservation /protection as vital in combatting climate change.
Proposal 2: Faced with escalating species and habitat loss and climate change, NPs and AONBs need to have a role and powers which more effectively influence behaviour by other government departments and their contractors, and by local authorities and communities.
Proposal 3: All public organisations should be required to ‘own’ the National Parks’ Purposes in their areas.
Proposal 4: As employment of ecologists by other Local Authorities has dwindled, it is vital that National Parks employ ecologists to inform and challenge their staff and Partners.
Proposal 5: National Parks should identify, survey, monitor and support the management of all areas which would meet SSSI criteria even if there is not a need to designate because of the ‘representativeness’ criterion.
Proposal 6: National Parks need to be given a clear mandate to conserve and enhance ‘green infrastructure’ linking National Parks to areas outside them – for instance, hedges, streams, belts of woodland, footpaths.
Proposal 7: National Parks could do more to support cultural heritage volunteer groups, including intangible cultural heritage, which can be more at risk than tangible. Facilities, resources and targeted continuing support with interventions when needed should contribute to sustaining cultural heritage in all forms.
Proposal 8: An improved web-based system is required for reporting vandalism to protected monuments and to archaeological sites.
Proposal 9: The reform of the current system of farm payments must recognise that without BPS, payment to farmers for sustaining or where necessary enhancing the environment for public benefit must become a profit source in its own right, and not merely a compensation for income foregone.
Proposal 10: National Parks should be given a remit and funding to work with local authorities and where appropriate national bodies, in order to promote Sustainable Transport solutions in their areas and environs.
Proposal 11: It would be helpful if there was a higher proportion of Secretary-of-State-appointed Members (7 at present) and if the process of appointing them could be easier, simpler and more transparent. There should be a minimum quota of active land managers. The nomination process for S-of-S-appointed Membership should include some democratic process.
Proposal 12: VED should be dedicated to ‘green’ initiatives which would counter the pollution and carbon emissions caused by road transport – such as funding a major programme of Sustainable Transport investment. The new road-building programme should be abandoned, at the very least in all schemes which impact on National Parks and AONBs.
Proposal 13: The boundary designation process should consider solely the criteria for National Park designation, and planning of transport or other major development should then be reshaped to as to have regard to the Purposes of National Park designation. This also applies to boundary changes.
Proposal 14: The process for designating boundaries of NPs, or for considering changes to designated boundaries, must be supported by an adequate budget for new ecological, archaeological and landscape connectivity survey work to inform the decision.
Completed by Camilla Lambert, Chair of Arun Countryside Trust
[1] By the Countryside Agency’s consultants, Landscape Design Associates, in 2001, in the ‘Coastal Lowlands’ category. Binsted Woods and Tortington Common – the wooded areas - were recommended for inclusion in the ‘Central Wooded Chalk Uplands’ category.
[2] Described in ‘Identifying the meeting place of Binsted Hundred near Arundel, West Sussex’, Sussex Archaeological Collections, Vol. 155, 2017.