A School Too Far?

Recently, one of the most tranquil parts of the South Downs National Park has generated quite a lot of noise far beyond its boundaries.  Previously, St Cuthman’s, a special needs school for around 100 pupils that closed in 2004, was little known except amongst the local community.  However, all that changed a few weeks ago after a local councillor made racist comments to a national newspaper, for which he has since apologised, in relation to the Durand Academy’s proposals for the site.

On the one hand, it has created a vigorous debate, more centred on class inequalities and educational opportunities than the planning issues which should ultimately determine whether this site is developed or not.  However, on the other hand concerns about the environmental impact of the proposals have at long last started to be aired.

The Durand Academy’s aspiration, on the surface, has much to commend it – giving inner city teenagers a chance to excel in a different environment.  However, the concerns arise because of the choice of location for its weekday boarding school along with the size of its proposals.  At over 600 pupils, the proposed school would be six times bigger than what was previously there, with a considerable amount of new build, primarily six new 3-storey accomodation blocks and two new school buildings.

To start with, St Cuthman’s is located in the north-eastern corner of the parish of Stedham with Iping, close to Woolbeding and Redford parish.  This is one of the most tranquil and innaccessible parts of the South Downs National Park and is lightly populated.  It is close to the Woolbeding and Pound Common Site of Special Scientific Interest, and the National Trust which has significant landholdings in the area is concerned that this development would lead to a suburbanisation of the landscape.

The site is only accessible via narrow country lanes, unsuited to large coaches, HGV construction traffic and the on-going servicing of the site.  It is also far from a railway station, with poor access to the strategic road network.

There are also concerns about the impact on Wispers, a grade II listed building, and the walled garden which would have a refectory built in it.

Durand’s consultants claim to have searched far and wide for a suitable site, and that St Cuthman’s came out top by a considerable margin according to their criteria.  However, a closer look at their alternative sites report shows some rather bizarre scoring for St Cuthman’s.  To start with it scores 10 out of 10 on road access, yet is only accessible via small country lanes, while other properties closer to the motorway network scored lower.  The same is true for planning.  While it might be true that the site currently is allocated for educational uses, this is not a modest expansion, more like a new major development and as such it is innappropriate in a National Park.  Yet this does not seem to have been considered for St Cuthman’s, while planning difficulties for other sites were played up.

It is clear that this proposal will be a test of the South Downs National Park Authority’s (SDNPA) resolve to conserve and enhance the South Downs and the effectiveness of the Government’s National Policy Planning Framework to safeguard nationally designated landscapes.  Unlike the King Edward VII hospital redevelopment, where the SDNPA’s hands were tied by previous permissions from Chichester District Council, there is no precedent with this site, other than its previous use.  However, given the substantial nature of this proposal, it should be treated as a major new development.

No doubt there will be high level political pressure for this to be approved, but the SDNPA must stand firm and rise above the politics to put the National Park first.  Local people who, to date, have largely led the opposition to this development have set up a petition calling on the SDNPA to reject the proposals.  However, it is not just locals who will be following this proposal closely, but people right across the Park, not least the many who campaigned so vigorously to make this a National Park in the first place.

A snapshot in time

This week has seen the launch of the State of the National Park report.  Published by the South Downs National Park Authority it is an attempt to record everything that contributes to what makes the South Downs special.  It could be the landscape beauty, the health of our local wildlife, or the strength of community spirit and enterprise.  All of these things and more work together to create and shape the South Downs that we know and love today.

The Park’s special qualities were defined by the various communities with an interest in the Downs earlier in the year.  This report is the next logical step in the process in attempting to capture the health and robustness of these special qualities.  The stage after this, which has already begun, is to work up a Management Plan which starts to tackle some of the problems or deficiencies identified by this report.

While the report has been published, in some senses it is far from complete.  Within it there are numerous data gaps and requests for more information.  However, this does not undermine its validity, more highlights the issues and difficulties in collecting and monitoring data over such a large area and on a wide range of topics.  In time, it will be necessary to fill these voids and it may be that this information has already been captured by someone.  However, there may be instances where the Park Authority will need to invest in data collection or analysis.

In the meantime, the current report is well worth a read and no doubt will be an invaluable tool as time progresses.

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:

Email: SEAConsultation@communities.gsi.gov.uk

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

 

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.