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Sussex Wildlife Trust - B&HCC Downland

(Submitted on behalf of the Sussex Wildlife Trust)

Thank you for involving the Sussex Wildlife Trust (SWT) in your recent consultations on the creation of a new City Downland Estate Plan (CDEP). We have been pleased to see Brighton & Hove City Council (BHCC) expand the consultation process over the past few months and take on board comments from the public and other stakeholders.

Please note that SWT previously submitted some initial comments after the first consultation session which still have relevance. The comments were sent by email on 4.12.20. Additionally, we have completed the surveys for the four themes on the consultation portal. SWT do not believe that the system of ranking required by the consultation is beneficial in helping to inform a holistic plan. Many of the options are co- dependent and cross-cutting, for example, connecting natural habitats will protect the chalk aquifer and protecting the chalk aquifer should result in connecting natural habitats. However, despite this, we understand that this data will be used by BHCC and therefore felt it was important to submit a response in that format.

SWT is also a member of the Brighton Downs Alliance (BDA) and supports the overarching submission of Key Points and Principles made by the BDA on the consultation forum. This response goes into more detail about the areas of specific interest and concern to SWT as the county’s wildlife conservation charity and is made in our name only.

Policy Context

SWT understands that the CDEP is being created within the framework set out by various existing strategic plans, policy and guidance. In particular, the South Downs National Park Authority (SDNPA)’s Guidance Document, the SDNPA Partnership Management Plan, the South Downs Local Plan and the Brighton and Hove Corporate Plan; also, we trust, the City’s Climate Action Plan.

SWT strongly supports the commitment in the Corporate Plan to promote and protect biodiversity and the commitment to developing ‘a new city downland estate plan with the aim of promoting biodiversity, mitigating climate change and delivering health and social benefits for communities’. In addition to this, there is an expectation that the CDEP will also help to deliver the targets in the SDNPA Partnership Management Plan (PMP) in order to conserve and enhance the special qualities of the National Park and help achieve the Local Plan Vision for 2050.

It would be helpful for BHCC to consider which of the SDNPA’s Ten Ambitions for the next Five Years are most applicable to the downland estate. For example, SWT believe that the CDEP should make a significant contribution to Outcome 3: Habitats and Species and particularly to ‘To create, restore and improve areas of priority habitat to be more, bigger, better, and joined up at a landscape scale’. Another very relevant target under Outcome 1: Landscape & Natural Beauty is to ‘To maximise environmental, cultural and economic benefits of agri-environment and forestry schemes across the National Park’.

Further to this, given the position of the downland estate within The Living Coast Biosphere Region and BHCC’s position as one of the lead partners, SWT recommends that the objectives of The Living Coast are also applied in the CDEP:

  • Conserve and enhance nature
  • Support sustainable human development
  • Promote environmental awareness, knowledge, learning and engagement

Comments on the Four Key Themes Natural Systems

Restoration of biodiversity must be a key objective of the CDEP, with policy wording to ensure that any decisions made about activity within or impacting on the downland estate, enhances and restores biodiversity. Given the ecological emergency, acknowledged by BHCC, and the Government’s commitment to a policy of ‘net gain’ to biodiversity, it is not acceptable for activities within the estate to result in biodiversity losses. A fundamental priority for the CDEP must be to deliver landscape and ecosystem restoration and in particular, the internationally rare, priority habitat of species-rich chalk grassland, in line with PMP outcome 3.

Lowland calcareous grassland is one of the most iconic and diverse habitats within the South Downs. It is one of the most species-rich plant communities in north-western Europe with one square metre supporting up to 80 species of plans and mosses. Additionally, this habitat contains many species of principle importance.

Chalk grassland has suffered a significant decline, particularly in the last 70 years. It is estimated that, due to factors such as agricultural intensification, abandonment and urbanisation, approximately 90% of the original habitat has been lost and the SDNPA quotes only 4% remaining within the SDNP. BHCC have declared an ecological emergency and must recognise that it is its duty to ensure the recovery of this rare and special habitat.

SWT recommends that BHCC use the chalk grassland evidence base provided by the Brighton Downs Alliance to plan out and prioritise significant action on how the few areas of existing habitat can be conserved and selecting areas where there is opportunity for recovery. The CDEP should include targets for chalk grassland restoration and recovery and should identify policy positions and potential projects to achieve this, with a clear timescale, priorities, resources and partnership working.

SWT would also like it acknowledged that targeted scrub management will be required to restore chalk grassland. Whilst conservation grazing is certainly required and is fully supported, it cannot be seen as the only management technique needed. BHCC should urgently focus on those areas of chalk grassland within the estate that are starting to scrub up now, as they are most easily recovered and the most vulnerable.

SWT would support the introduction of pilot projects that look at more naturalistic grazing and restoration of natural processes. However, there should be focussed on areas of the estate that are not an immediate priority for chalk grassland restoration. This habitat is so fragile and at risk that any trials of alternative management techniques must be carried out with caution.

It is not clear if an ecosystems services analysis has been undertaken as stated in the SDNPA WEP guidance. However, SWT would support the creation of a natural capital account for the estate. We recommend that the Sussex Local Nature Partnership’s Natural Capital Investment Strategy is used as an evidence base for the CDEP, but particularly highlight the formal commitment to biodiversity within this Strategy which states that the natural capital approach will only be used where it delivers benefits for nature.

We understand that there is a pressure for the council to plant trees on the estate, however we strongly urge against this until it is clear how chalk grassland restoration will be prioritised and the open downland landscape conserved. Whilst SWT does acknowledge the benefit of trees, we strongly believe in the principle of the right tree in the right place and would advocate BHCC focussing on urban street trees, for it is in the city where multiple benefits for people, nature and climate change can be achieved.

We also note that the Estate does reach the sea at Rottingdean and therefore there should also be consideration of this coastal habitat and the Marine Conservation Zone within the plan.

Land Use and Management

It was stated in the CDEP stakeholder event that 78% of the Brighton estate within the National Park is currently farmland. We strongly advocate changing policy to maximise the environmental and cultural benefits of the agricultural landscape, not just economic. Clearly, working with existing and new farmers and land managers is fundamental to BHCC achieving its aims around the ecological and climate emergencies.

The CDEP should work towards requiring all farming on the estate to restore ecosystems through regenerative agriculture, low -carbon and nature-friendly farming techniques. We urge BHCC to work closely with experts in this field to quickly progress this approach and ensure that the estate smoothly transitions to the system of public money for public benefit to comply with government policy and its new grant-aided Environmental Land Management Schemes. In the interim, it is vital that the CDEP ensures that any leases or tenancies negotiated for the estate include a requirement for sustainable farming techniques that protect the chalk aquifer, protect and restore biodiversity and allow for public access. The lease templates could be redrawn to include standard requirements for all sites and further requirements that could be adapted considering the situation with input from relevant stakeholders.

There are many pre-existing partnerships that can help BHCC in this regard, including The Aquafer Partnership, the Brighton and Hove Food Partnership and the Living Coast Partnership. SWT particularly supports the Brighton and Hove Food Partnership’s request that BHCC should take in-house the next suitable farm tenancy for community management. This could act as a showcase locally and nationally for community-led climate and nature-friendly farming and would pioneer replication in the wider downland estate. We believe that local food production combined with local supply chains can help connect people to their food and the impact that producing it has on wildlife, both positively and negatively.

The way land is used and managed on the estate also has a huge impact on the chalk aquifer. We strongly advocate for policies and projects that protect ground water and improve its quality. We accept that much of the damage to the aquifer is from historic use, but given that the downland estate has been owned by BHCC for the past 100 years, it is the council’s responsibility to drive this change via the CDEP and partnership working.

Climate Change

SWT agrees that there is an urgent need for BHCC to take action on climate change and achieve its ambition of Net Zero emissions by 2030. The science used for calculating carbon sequestration and storage rates for different habitats is still emerging. Whilst we do have good data for woodland, it is not so robust yet for grassland habitats. However, we absolutely do know what the biodiversity value of chalk grassland is in terms of rarity, diversity and vulnerability. The CDEP must protect and restore the chalk grassland and potential chalk grassland within the estate as well as providing mandatory and measurable targets on reducing carbon emissions across the estate.

Permanent species rich grassland in good condition will still store significant amounts of carbon, especially when compared to grassland that is periodically ploughed or ‘improved’ using fertilizer. SWT believe that the main focus for climate change within the CDEP should be the urgent reduction of emissions and restoration of permanent grassland. It is not clear whether BHCC have considered the carbon emissions currently associated with the downland estate. SWT would estimate that some of the highest emissions on the estate would relate to agriculture inputs, soil erosion and transport. We believe that the CDEP can help to implement policies that reduce carbon emission, particularly through promoting regenerative agriculture, re-establishing local food and local supply chains, reducing motorised and improving non-motorised access to the downland. This must be done urgently given the climate emergency we are all facing.

We note that BHCC has committed to a Climate Action Plan (CAP). This should be the main driver for achieving vital action on climate change and should be urgently progressed. The CAP needs to align with the CDEP and there will likely be actions that achieve priorities from both plans. These actions need deliverable, measurable, time-specific and mandatory targets


The natural world is the foundation of our health, wellbeing and prosperity. The Brighton downland estate is a significant public resource. Evidence shows that a thriving, wildlife-rich environment benefits both physical and mental health. People with nature on their doorstep are more active, mentally resilient and have better all-round health.

SWT believe that the primary role for the estate is to deliver multiple public benefits in line with the purposes of the National Park and its special qualities. SWT would like to see improved public access to the downland and in particular more formal and informal access for schools. SWT has delivered the Brighton & Hove environmental education (BHee) project for the last 9 years and multiple community projects within the city. In our experience there is currently very little awareness of the vastness and richness of the downland estate in Brighton & Hove schools and communities, with many local children unaware of what is on their doorstep.

Many of our city’s schools, particularly in the centre, are ‘nature deprived’. The downland estate is vital to give children opportunities to experience and connect with nature and give a greater understand of the place they belong to. If we want to see positive environmental behaviour change, we need to provide children with these experiences to enjoy and understand their environment. BHCC own a multitude of assets that have the potential to be used as classroom facilities and public information venues. This is why it is vital that the CDEP needs full council approval and delivery rather than departmental ownership. That way the full potential of the estate and the council’s assets could be considered without the constraints of departmental objectives and budgets.

Our experience delivering wildlife workshops, Wild Beach and Forest Schools and Bike to Nature is that there is great appetite and need for environmental education and community action within the city.

However, there are currently barriers to the use of the downland estate for this purpose, in particular a lack of physical access, especially close to the city. Currently direct bus access to Stanmer Park, Devils Dyke and Ditchling Beacon is limited to peak summer and weekends – increasing transport links would encourage more schools out. Safer cycle routes would give confidence to schools embarking on Bike to Nature trips. The A27 in particular, acts as a significant barrier to access to the estate.

Public infrastructure such as access to toilets is also an issue and this is why gateway sites such as Stanmer Park are so valuable. Indeed Stanmer Park has been the hub for our successful Youth Rangers volunteering programme for many years. SWT was disappointed when BHCC did not allow more varied community use of Hollingbury Golf Course when the lease was up for renewal. This is another site that is ideally placed to act as an education hub and gateway to the downland estate for residents and visitors, with easy walking access from many of the City’s schools, and good public transport access for others. We do expect the community engagement process promised for this site to be initiated with urgency.

The ability to easily walk from downland to city to sea is not replicated in many other parts of the city and therefore Hollingbury Golf Course should be a place to illustrate the contrasting habitats of The Living Coast to schools, families and visitors. One place that this does work successfully is the Beacon Hub at Beacon Hill.

As well as the richness of the chalk-grassland, the existing pockets of woodland are very important for schools, allowing for Forest School experiences and child-centred exploration.

The status of the SDNP as an International Dark Sky Reserve should also inform the policies within the CDEP. Light pollution from the city does compromise these dark skies and impacts on nocturnal wildlife. We would advocate the CDEP delivering a reduction in light pollution.

Format and delivery of the CDEP

As this is an early stage of the consultation, there has not been much discussion of the format of the CDEP. However, SWT believe the CDEP must include both SMART targets and monitoring requirements to assess if these targets are being achieved. This monitoring needs to be properly resourced and there needs to be mechanisms for review and amendment if targets are slipping.

In order to help with the implementation and delivery of the CDEP, we advocate for a Downland Advisory Board made up of relevant experts to help the council review and make decisions effecting the estate. We also believe that responsibility for delivery needs to sit within the council and at a high level, so that officers from all relevant departments have a requirement to implement the policies and projects in the plan.

We urge BHCC to press ahead with the Asset Audit, as recommended by the SDNPA WEP guidance. It would be helpful to have the full evidence base for the CDEP summarised and in one publically accessible location.

Next Steps

SWT is very interested to see how all the varied input from this first round of consultation will be collated and used to inform the next stages. Due to many different routes for submitting comments, it is not clear how BHCC intend to analyse and communicate the consultation comments, but all the qualitative and quantitative input must be considered. SWT awaits the next stages of the consultation with interest and look forward to seeing how the comments we have made have been taken forward.

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