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B&HCC Downland - Whole Estate Plan Consultation

(Submitted on behalf of The South Downs Society)

The Friends of the South Downs (The South Downs Society), welcomes the opportunity to “Have a Say” on the creation of a Whole Estate Plan (WEP) for the City Downland owned by the Council.

Our core business is campaigning and fundraising for the conservation and enhancement of the landscape of the South Downs National Park (SDNP) and its quiet enjoyment, recognising that these qualities can only be realised if the setting of the SDNP is also respected and protected. In particular we seek to ensure that the National Park purposes and duties are adhered to. These purposes are :

- to conserve and enhance the natural beauty, wildlife and cultural heritage; and.

- to promote opportunities for the understanding and enjoyment of the special qualities of the area by the public.

The Society is a “critical friend” to the South Downs National Park Authority and in recent years has provided it's vision, comments and suggestions towards the provision of the South Downs Partnership Management Plan and Local Plan. Given that the majority of the City Downland falls within the SDNP we would expect the WEP to deliver on the outcome from this work.

As with the Local Plan, the Society would expect the policies within the WEP to be landscape led. The chalk downland in the South Downs in and around Brighton is special and is made up of a patchwork of grassland, scrub and heath. Internationality this is rare with much having been lost over many years to arable farming and lack of management. The Society wishes to see that special importance is given in the WEP to managing and enhancing the chalk grassland. The Society would suggest an Estate wide strategy.

Whilst new or converted development will be managed through the planning process (having regard for the Local Plan), any new development will need to conserve the special landscape qualities of the City Downland. We seek to ensure that new developments are located in the most sustainable sites, with brownfield and low landscape value sites being put forward for development first. Good design contributing to a ‘sense of place’, using materials that reflect or enhance locally distinctive building styles, and making prudent use of natural resources are vital. We normally only support development which complements its setting, seeking to ensure its assimilation into the landscape. We will support development which responds to the effects of, and reduces its contribution to, climate change.

Given the geography, the biggest impact that development has on the landscape is outside the downland but where it abuts and/or close to the City boundary. The proximity of development within the City, including high density and tall buildings, adversely affects the enjoyment of the Downland and views in and out of the SDNP. Part One (adopted) and Part 2 of the City Plan also include new sites for possible housing within land designated “urban fringe” being right on the edge of the Downland. We feel that there is potential conflict here between the housing needs of the City and the protection and enhancement of the City Downland. Therefore, the Society believe that there is a good opportunity for the WEP to include provisions for landscaping projects which help protect or “soften” the harshness of the boundary between the urban and rural landscape.

Public enjoyment of the downland should be promoted in the WEP by improving accessibility and understanding. The potential of the downland as a learning resource can be realised through links with schools, colleges, young people and adults.

The WEP should also include the commitment by landowners, tenants etc. to both maintain and enhance the public rights of way. Access land should be maintained and sufficient access points should be included to increase accessibility for all.

We should be grateful if you would take the above comments into account when preparing the draft WEP.

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