All at Sea

The Government recently announced that it was consulting on the designation of 31 Marine Conservation Zones (MCZs) in English and Welsh coastal waters.  Although many more areas have been suggested as MCZs, only these first 31 are being progressed at present.

In the south east, the MCZ of direct relevance to the South Downs National Park is Beachy Head West (numbered 34 on the MCZ map).  While it is good news that this MCZ is one of the first to be progressed, it is possibly one of the narrowest MCZs proposed.  Extending from Beachy Head westwards to 100m west of Brighton Marina, the recommended MCZ is only 1/4 of a nautical mile (about 500m) wide along its entire length.  In total the area covered by the designation is some 23.58 square kilometres.

Given that the current Voluntary Marine Conservation cialis 10mg Area that extends along the Sussex Heritage Coast is some 2km wide, the proposed MCZ might seem like a step backwards.  Indeed, the area concerned appears to have shrunk from what was first put forward.

Therefore there are concerns that the MCZ may not be able to fulfil the role it is supposed to do, being so tightly constrained.  The feeling is that it should be wide enough to cover the entire chalk shelf underneath the water.  In addition, it does not include the two tidal estuaries of the River Ouse and the River Cuckmere.  These are important for our threatened eels and impressive sea trout, the latter of which are amongst the largest in the country.  Including these estuaries in the MCZ would create a more ecologically coherant approach to marine conservation.

Anyone wishing to comment on the proposals can view the consultation document and respond by midnight on 31 March 2013.

Will Anyone Notice?

A couple of weeks ago, a consultation was quietly started on the Strategic Environmental Assessment (SEA) of the revocation of the South East Plan.  Enough to send most people off in a stupor before they’ve finished the headline!

Current Government policy is to simplify planning by stripping away regional governance and plans, and by the introduction of the National Planning Policy Framework (NPPF).  Therefore this is just another step along that path.  Given it is going to happen, does it matter?  Will it make any difference?

These are the questions that the SEA is looking to assess, to see whether the Plan should be revoked in total or whether particular policies should be kept in place, even if only temporarily.

The South Downs are in an odd position as when the South East Plan was written the area was not yet confirmed as a National Park and so did not have a proper policy as the New Forest did.  Instead it was covered by the policy on Areas of Outstanding Natural Beauty (AONB).  However, since the AONB policy no longer applies to the South Downs, it now being a National Park, it is harder to make a case that it would be any better or worse off with or without the South East Plan.

Where there might be concern about the loss of the South East Plan is in the New Forest and the remaining 9 AONBs in the South East.  Here the Plan was strong on the concept of ‘conserving and enhancing’ these landscapes and on ‘having regard to their setting’, the latter an important point picked out by the Inspector as justification for having regional policies on nationally important landscapes.

The critical test is whether these policies are covered by the NPPF.  This does indeed have policies on landscape and specific mention of National Parks and AONBs.  While it does talk of ‘conserving and enhancing’ and ‘protecting and enhancing’ ‘valued landscapes’ in paras 109 and 156, in para 115 when it talks of nationally important landscapes it only talks of ‘conserving’ them; ‘enhancement’ is not mentioned.  Therefore there is a certain ambiguity as to whether ‘enhancement’ of National Parks and AONBs still has the same priority under the NPPF as under the South East Plan.

In addition, there is no mention of the importance of the setting of nationally designated landscapes.  The only time setting is considered important is for heritage assets.  Therefore, this would suggest that the region’s nationally important landscapes would be worse off without the South East Plan.

While the SEA does pick up a minor policy difference between the mean low water mark and mean high water mark for AONBs, it is silent on these other issues.  This is of concern and hopefully people will respond to the consultation if only to make this point.  As to whether it will be noticed or not will depend on development pressures around the edges of our nationally important landscapes and the weight given to protecting the environment.  Only time will tell…

The consultation ends on Thursday 6 December, 2012.  You can send comments to:


Post: Environmental Assessment Team, Department of Communities and Local Government, Zone 1/J6, Eland House, Bressenden Place, London, SW1E 5DU


Rampion offshore windfarm consultation extended

The second round of public consultation on E.ON’s proposals for the Rampion offhsore windfarm started on Wednesday, 13 June.  After much lobbying, E.ON has conceded some ground in extending the consultation from 6 to 8 weeks, but not to 12 weeks as good practice would dictate and as called for by the South Downs Network.  This means the new consultation will now end on 8 August.

E.ON has also published its draft Environmental Statement, which is split into 32 sections.  This can be downloaded from E.ON’s website or is publicly accessible at the district council offices of Adur, Horsham, Mid-Sussex and Worthing and at Brighton & Hove City Council offices in Hove and at East Sussex County Council offices in Newhaven.  This means that people will now have a chance to properly examine the proposals and see on what basis decisions have been taken.

The South Downs Network will be closely looking at this evidence to ensure that E.ON has had proper regard to National Park purposes, both in regard to the cable route and the impact on the Heritage Coast.

Call for 12 week consultation on Rampion

The South Downs Network is calling for the next consultation phase on the Rampion windfarm proposal to be extended to 12 weeks to allow people sufficient time to analyse and respond to the Environmental Impact Assessment.  Currently it is due to start mid-May but will only run for 6 weeks.  The Network believes this is too short a timescale to allow proper democratic scrutiny.

In its response to the first consultation, the South Downs Network has welcomed the extensive awareness raising that E.ON has done during this period.  It has also welcomed the recognition that any cabling on land should be put underground.

However, the Network has been critical of the lack of information released about the development so far.  This has hindered people’s ability to make informed responses to the windfarm proposals: another reason why a 12 week period is needed for the second round of consultation.  The Network has also expressed concern about the landscape impact, particularly on the Heritage Coast, and the length of the cable route through the National Park.