The South Downs was established as a National Park in 2010. The South Downs National Park Authority (SDNPA) became the local planning authority for the National Park in 2011. The National Park contains over 1,600km2 of England’s most iconic lowland landscapes stretching from Winchester in the west to Eastbourne in the east. The South Downs Local Plan is the first Local Plan to plan for the National Park as a single entity.
The South Downs Local Plan replaces 1,026 local plan policies inherited when the National Park was designated and joint core strategy policies prepared with adjoining authorities since designation. The 92 policies in the new plan simplify hugely the day to day work of the development management officers and of the South Downs National Park Partnership’s members.
Work began on the plan in 2013 and a first ‘Options consultation’ was published in 2014. This set out 55 issues, leading to options for the direction the Plan could take. Public comments were invited on both the issues and the options. A Preferred Options document followed in 2015 with draft policies on a full range of issues such as ecosystem services, landscape and housing allocations. Over two thousand sets of comments, sent in both by local people and people from across the country interested in the National Park, were received on this document . The Pre-Submission consultation took place in 2017, closely followed by the submission the following year.
The examination lasted for 15 months with hearings held in November and December 2018. The Main Modifications suggested by the Inspector were relatively modest in scale and were consulted on in 2019. The final Inspector’s report was received in June and the Plan was adopted a few weeks later.
The Local plan was developed by the South Downs National Park Authority (SDNPA), representing:
- 3 county councils
- 12 local authorities
- Winchester City Council
- East Hampshire District Council
- Chichester District Council
- Horsham District Council
- Arun District Council
- Worthing Borough Council
- Adur District Council
- Mid Sussex District Council
- Brighton and Hove City Council
- Lewes District Council
- Wealden District Council
- Eastbourne Borough Council
- 176 Town and Parish Councils across East Sussex, West Sussex and Hampshire
Other bodies were closely involved in the plan-making process in regard to specific areas of policies:
- South Downs Partnership - The South Downs Partnership is a platform of organisations spanning from different sectors, all with a stake in the future of the South Downs National Park;
- South Downs Land Managers - South Downs Land Managers is an independent association of farmers, foresters and landowners in the South Downs National Park. They were involved in formulating the policies on agriculture and forestry;
- National Farmers’ Union - The NFU is a representative body for agriculture and horticulture in England and Wales. It partnered with SDNPA and South Downs Land Managers to formulate the policies concerning agriculture and forestry.
Academics, including Dr. Alister Scott (Northumbria University), were consulted on how to incorporate ecosystem services and natural capital into the Local Plan.
A Local Plan Members Group was created to engage all Partnership members. It was consulted throughout the whole elaboration of the plan.
Members had a central role in elaborating and detailing the policies of the Local Plan, as they met monthly with officers at the Local Plan Members Group and then in public at Planning Committee where policies were debated and endorsed.
Who made it possible?
The Plan is being implemented and monitored through the collaboration with government bodies and the coordination with other local partnerships. The government bodies that are involved in implementing the plan are:
- Natural England - Assesses and monitors development proposals in specific sites, including Special Areas of Conservation and Special Protection Areas. Partners with SDNPA in the implementation and monitoring of several policies;
- Historic England - Provides evidence, guidance and tools for implementing and monitoring policies and assessing planning applications;
- Environment Agency - Provides the regulatory framework for flooding and hydropower;
- Highways England - Gives feedback on Transport Assessment (TA), Transport Statement (TS), and Travel Plan (TP)., and on change-of-use proposals;
- Marine Management Organisation - Assists with the implementation and monitoring of Development Management Policy concerning the Open Coast.
SDNPA also worked with the Solent Recreation Mitigation Partnership (SRMP) to ensure that all new residential development within the Solent Area will be required to mitigate any negative impacts. This mitigation can be provided through a financial contribution to the measures set out in the Solent Recreation Mitigation Strategy.
SDNPA also cooperated with three Local Enterprise Partnerships (LEPs), namely:
Stakeholder and community engagement
The policies in the Local Plan incorporate a number of Neighbourhood Plans and other community-led plans. Communities were encouraged and assisted in the preparation of Plans that were consistent with the vision of the South Downs Plan and that could form the building blocks of the latter.
Local Plan policies have been formulated in consultation with the local communities, and were built on the extensive engagement that was conducted in the wake of the Partnership Management Plan (2013) and the State of the Park Report (2012). Regular parish workshops to which all 176 parish councils across the National Park were invited were held to ensure the full involvement of all communities.
Four rounds of consultations were held between 2013 and 2018 on the Options for the plan, the Preferred Option document that included the bulk of the ecosystem approach, landscape and housing allocations, and on the Pre-Submission document.
Finally, a social media campaign, including the production and publishing of audio-visual material, was launched to inform the public of the vision and the scope of the Plan.
The South Downs Local Plan is centred on a vision of an ecosystem-driven plan.
It requires all planning applications submitted to the National Park Planning Authority to make a positive contribution to the ability of the natural environment to contribute goods and services. It puts in place a monitoring mechanism to assess such contributions based on cutting-edge edge academic research. This represents the first occurrence of a Local Plan integrating the ecosystem services approach in its framework, resulting in an emphasis on nature and in policies that are capacity-led and not target-driven.
The engagement of local stakeholders was a key aspect of the plan-making process. This involved an extensive consultation process and the participation of local actors and communities in implementing the plan. For example, the plan actively encourages the development of neighbourhood plans and has provisions to integrate them into the Local Plan.
A strong leadership by the Planning Authority allowed to mobilise the knowledge of the National Park’s officers and the experience of the Partnership’s members. The Planning Authority established a Local Plan Members Group to enable a close collaboration between stakeholders during plan-making. The Group was regularly consulted during the elaboration of the Plan. This led to the smooth approval of the plan, with only minor observations by the Planning Inspector.
Purposes and duties of National Park Authorities
The Local Plan’s goals are aligned with the Purposes and Duties of Natural Parks, as set out for England and Wales in the National Parks and Access to the Countryside Act (1949), and amended by the Environment Act (1995). According to those documents, two statutory purposes of the ‘National Park’ designation are:
- to conserve and enhance the natural beauty, wildlife and cultural heritage;
- to promote opportunities for the understanding and enjoyment of the special qualities of the area by the public.
In doing so, National Parks have a socio-economic duty to foster the social and economic well-being of the local communities within the Park. Moreover, being Local Planning Authorities, National Park Authorities are subjected to the duty to cooperate as formulated in the NPPF.
Section 66 of the 1995 Act and require Park Authorities to produce a National Park Management Plan for their area and to review it at least every five years, detailing their policies for managing the park according to their purposes and duties.
The South Downs National Park Partnership Management Plan
The South Downs National Park Partnership Management Plan (PMP), setting out an overarching strategy for the management of the Park, was adopted by the National Park Authority in 2013. It followed an extensive consultation and dialogue with many interested parties and groups. This document is the framework on which the Local Plan is built, according to the statutory requirements set out in the Planning and Compulsory Purchase Act (2004), and the guidance contained in the NPPF and the planning practice guidance.
Both the Park Management Plan and the Local Plan draw evidence from three main sources:
- The State of the South Downs National Park Report (2012), providing a baseline information against which the success of future action arising from the PMP could be measured. The facts set out in the report form a fundamental part of the Local Plan evidence base. This included studies such as Tranquillity Mapping, Dark Night Skies, Transport Assessments, Ecoserve mapping to know what ecosystem services are available and what are endangered;
- The special qualities of the South Downs (2011) to be preserved conserved and enhanced;
- The South Downs Integrated Landscape Character Assessment (2005) that orientated the focus on the preservation of the South Downs unique landscapes.
A Strategic Housing Land Availability Assessment was also led, with parameters relating to the landscape, such as views and impact upon the special qualities of the National Park. Statutory assessments such as Habitat Regulation Assessments and Sustainability Appraisals were also conducted, according to the provisions of the Strategic Environmental Assessment Directive (2001).
South Downs Local Plan
The South Downs Local Plan is the first Local Plan produced for the South Downs Park since its establishment in 2011. It sets out policies to manage the development in the National Park area until 2034.
The core policies of the Plan, that apply to all planning applications, seek to regulate development in a way that protects and promotes the natural beauty, wildlife and cultural heritage of the area while strengthening the ecosystem services.
The plan accommodates a medium level of growth dispersed across the towns and villages of the National Park, in order to sustain and support local communities without changing the special character of the area. It takes a strong approach on affordable housing, through provisions for affordable homes in developments of 4 dwellings and more.
The plan also sets out strategies and policies aiming at sustainable transport and growth, as well as at social and environmental sustainability.
It contains detailed strategies for two specific sites sites (Shoreham Cement Works in Upper Beeding and the North Street Quarter in Lewes) and the site allocation for development within the border of the Park, in accordance with the existing Town, Parish and Neighbourhood plans.
Finally, it details the targets and indicators for monitoring the implementation of the plan, as well as a contingency action plan to enact in case targets were not being met.
Over 50 Neighbourhood Plans were or are being prepared either following the impulse or in collaboration with the SDNPA. Specific provisions for aligning the Plan’s policies with lower-tier documents are present in the Local Plan.
The novelty of the ‘ecosystem approach’ and the delicate ecosystem of the area warranted the production of several technical advice notes and guidelines along with other Supplementary Planning Documents.
Review and monitoring
The Local Plan will be monitored regularly through the use of clear targets and indicators that are determined in the plan itself and monitored by the Authority or its partners. A yearly report is to be published by the Authority.
The Plan also fixes “trigger points”. These are threshold values for each indicator, that allow to flag policies that are failing to deliver their target, so that corrective actions - also detailed in the Plan - can be taken.
The main innovation of the Local Plan is its willingness to take up on the most recent research on ecosystem and enshrine it in its core policies. The ‘ecosystem services’ approach allows to consider nature as a set of goods and services that can be factored into decision-making. This approach is scalable, and can be applied to all aspects of planning, from development management and enforcement to strategic planning. The South Downs Local Plan demonstrates that all LPAs can benefit from cooperation with academia, and that strategic partnerships have the in-house resources to be at the forefront of the action for climate and ecology.
The South Downs Local Plan also shows how an upper-tier Authority can conciliate a strategic vision with the involvement of local communities, by supporting the drafting of community-level plans and using them as the building blocks for their strategy.