Wednesday, 30. April 2008, 17:14:10
1.0 Qualifications and Experience
1.1 Qualifications, Experience and Involvement with the Proposed South Downs
National Park Designation Process
1.1.1 Qualifications
I have a First Class Honours Bachelor of Science Degree in Geography from the
University of Wales (1973).
I am a qualified Landscape Architect with a Diploma in Landscape Design from the
University of Manchester (1975).
I am a Fellow of the Landscape Institute.
I am an Honorary Professor at the University of Wales.
I am a Fellow of the Royal Geographical Society.
I am Senior Partner of LDA Design.
I have 32 years professional experience.
1.1.2 LDA Design
My practice is generally regarded as one of the foremost UK consultancies in the field
of protected landscapes, rural environments, masterplanning, sustainable development
and regeneration. Our capabilities also include landscape design, urban design,
environmental planning, architecture, ecology and environmental impact assessment.
LDA Design (formerly Landscape Design Associates) has been a consistent winner of
national awards for its work, notably at the Landscape Institute Awards. Within the
specific fields of landscape assessment, protected landscapes and rural work,
Landscape Institute Awards include:
• Cambridgeshire Landscape Guidelines (1993) (this was also winner of the first
President’s Award)
• Sussex Downs AONB Management Plan (1997)
• Cambridge Green Belt Study (2004)
• Northamptonshire Environmental Character Suite (2007)
• Forest of Dean District Landscape Supplementary Planning Document (2007)
• Our client the River Nene Regional Park CIC received a commendation for its
development of our Northamptonshire Green Infrastructure Strategy (2007)
1.1.3 Professional Experience
I lead LDA Design’s Rural and Protected Landscapes team. My expertise in this field
encompasses landscape character assessment, protected and rural landscapes
management, environmental planning, green infrastructure planning and a broad range
of matters concerned with biodiversity and sustainable development. I have given a
number of lectures on the subject of climate change, most recently at the 2007
Landscape Institute’s Annual Conference and at the Thames Gateway Forum. I have
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contributed to the Matthew Taylor MP Review on Sustainable Rural Communities
through the Town and Country Planning Association and am an advisor to CABE in its
preparation of Sustainable Cities guidance. I have published many papers and books
on the subject of ecological landscape approaches, and have lectured nationally and
internationally on a wide range of topics, from heritage coast management to
masterplanning, environmental impact assessment and sustainable development. My
work embraces equally the planning and design of new development and the
conservation of historic towns and landscapes. I work for government departments
and agencies and local authorities, most of the UK’s leading house building companies,
and many of the country’s major developers, renewable energy and leisure developers,
land owners and farmers. This range of experience gives me a broad perspective from
different economic sectors and the planning system.
I therefore bring to this Inquiry, not only expertise on protected landscapes, but also a
broad range of experience and expertise related to strategic planning, promotion of
strategic development land, sustainable development, masterplanning and new
development generally, EIA, urban regeneration and environmental planning.
I have prepared a number of landscape character assessments and guides in the
Countryside Commission’s/Countryside Agency’s National AONB Series, including:
• Dorset Coasts and Heaths AONB
• Malvern Hills AONB
• Cornish Coasts and Moors AONB
• Dedham Vale AONB
• Sussex Downs AONB (the published document was prepared for the Sussex
Downs Conservation Board)
I have also prepared integrated landscape character assessments and guidance for:
• East Hampshire AONB
• Causeway Coast AONB
All these projects involved extensive field studies, consultations with a wide range of
organisations and hands-on leadership and involvement.
I have prepared many landscape assessments and major rural planning projects at the
Regional, County and Local levels, including:
• The New National Forest Feasibility Study and Environmental Impact Assessment,
work which underpinned the development of the National Forest
• The Cornwall County Historic Landscape Assessment, in conjunction with the
Cornwall Archaeological Unit
• Cornwall County Landscape Character Assessment
• The Dorset County Landscape Character Assessment
• A strategic Landscape Character Assessment of Wales underpinning an
Environmental Strategy for the Welsh Development Agency and various partners
including Countryside Council for Wales
• Various landscape character assessments at a district level and many more local
landscape character assessments
I have led the development of a number of projects which have established new
methodologies, notably in integrating landscape and townscape character assessment,
and applying this process to complex strategic planning challenges. Projects include:
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• The Winchester Study – a comprehensive assessment of Winchester and its
Landscape Setting, to advise on the future development of the city
• The Gosport Integrated Landscape and Townscape Assessment
• The Cambridge Green Belt Study, to advise on the future shape of Cambridge,
capacity for major urban extensions and proposals for use of the Cambridge Green
Belt (presented at the Cambridgeshire Structure Plan EiP and accepted in large
measure by the Panel).
Over the past two years, I have led a team working for the Countryside Agency and the
Commission for Architecture and the Built Environment preparing a strategic
environmental vision for the Thames Gateway, Europe’s largest regeneration project. I
have also contributed to the Practice’s work on a number of nationally significant Green
Infrastructure Strategies, notably the planning of the Green Grids within the Thames
Gateway and the development of an environmental infrastructure within
Northamptonshire (work which was recognised in two Landscape Institute Awards in
2007).
I have also had an involvement in the New Forest National Park Public Inquiry, through
evidence given on behalf of the New Forest District Council and The New Forest
Committee.
1.2 Involvement with the South Downs and the Proposed National Park
Designation Process
1.2.1 I have been involved with the proposed South Downs National Park for many years,
and led the consultancy landscape work leading up to (but excluding), the PSDNP
Public Inquiry, on behalf of various organisations promoting the concept. Specifically:
I led the consultancy landscape input on the:
• Business Plan for the Sussex Downs Conservation Board
• Sussex Downs AONB Landscape Character Assessment – both the technical
document and also the published ‘glossy’
• East Hampshire AONB Integrated Landscape Character Assessment
• Draft Management Plan for the South Downs commissioned by Hampshire County
Council, the Countryside Agency and the AONB Management Teams
• A Vision for the South Downs, for Hampshire County Council, Sussex Downs
Conservation Board and the Countryside Agency
• South Downs National Park Area of Search contract for the Countryside Agency
• South Downs National Park Draft Boundary Setting contract for the Countryside
Agency
• Various technical papers produced in 2002 including the implications of splitting
parishes, assessing landscapes for designation, transitional areas and treatment of
the foreshore.
1.2.2 In addition to these substantive pieces of work, I was involved with many consultation
exercises, and organised, chaired and spoke at a major Countryside Agency
conference on the proposed National Park held in Chichester in January 2001, at which
I put forward consultation proposals for the National Park. Throughout, I advised the
Countryside Agency on the interpretation of the 1949 and 1995 Acts, as supplemented
by Countryside Agency policy developments and other influences on the National Park
boundary setting process.
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1.2.3 As LDA Design’s/Landscape Design Associates’ leader of these projects, I was actively
involved at both the policy level and in detail. I have travelled extensively throughout the
South Downs and was personally involved in all the major decisions at the Area of
Search stage and had a close involvement (as lead Partner) in overseeing all the
detailed draft boundary setting work.
1.3 Team
1.3.1 In carrying out the original Area of Search and Draft Boundary work for the Countryside
Agency, I was assisted by Fiona Fyfe and Alison Farmer. Fiona Fyfe BSc(Hons) MA MLI
has assisted me in reviewing our earlier work and she has also contributed to the
analysis of documents which underpin my evidence. Fiona Fyfe helped write both the
Area of Search report and the subsequent Draft Boundary report, and she was involved
in organising the conference in Chichester in January 2001 at which the Area of Search
study was presented. She carried out a substantial amount of fieldwork (landscape
assessment and draft boundary drawing) and prepared (with me) a series of technical
papers on the proposed national park boundary including The Implications of Splitting
Parishes with a National Park Boundary and Assessing Landscapes for Designation.
1.3.2 Alison Farmer worked closely with me throughout the boundary setting process. She is
now working independently and has been engaged by Natural England to give
evidence at this reopened Inquiry.
1.3.3 The evidence I bring on behalf of the South Downs Campaign is, therefore, from a
position as one of the key advisors to the Countryside Agency on the broad extent
(Area of Search) and Draft Boundary for the National Park. Specifically, at an early
stage in the Area of Search contract, I was personally closely involved in debating and
advising on whether the National Park should be restricted only to an area of high
chalk, or whether it should be more extensive in scale, potentially extending to areas such as the Western Weald
2.0 Background and Scope of Evidence
2.1 Background to Commission
I have been commissioned as an expert witness by the South Downs Campaign to
prepare this proof of evidence for the re-opened Public Inquiry into the Proposed South
Downs National Park (PSDNP).
The principal aim of my evidence is to set out the case for why the area of land known
as the “Western Weald” should be included within the PSDNP boundary. This builds on
my earlier work on the PSDNP which was undertaken in commissions for the
Countryside Agency concerned with the Area of Search and Draft Boundary for the
PSDNP, and a series of associated specialist studies. I was the lead partner for LDA
Design (formerly known as Landscape Design Associates prior to our name change and
conversion from a Partnership to a LLP in 2003) for this work and as such was the lead
landscape professional on boundary setting matters employed by the Countryside
Agency. This work took place over a number of years, during which time I became
familiar with the South Downs as a whole and with the many issues connected with the
proposed National Park and how its boundary should be defined. I also consulted with
many organisations as part of the process.
I therefore welcome this opportunity to review the work that we did at that time, to see if
it has stood the test of time, and also to provide additional evidence. Given the
important developments in government policy since that work was done, and since the
Inquiry closed, I hope that my knowledge of these matters will be of value to the
resumed Inquiry.
Natural England, formerly the Countryside Agency, has maintained its position of
support for inclusion of the Western Weald within the PSDNP. I agree with Natural
England and note that this also accords with my own recommendations given to them
in two key reports:
• Proposed South Downs National Park: Report on Area of Search for the National
Park Boundary (March 2001),
• Proposed South Downs National Park Draft Boundary Recommendations (July
2001)
Natural England is represented at this Inquiry and has its own expert witness.
The South Downs Campaign (SDC) is an independent organisation representing the
views of some over 140 national, regional and local interest groups, as described in
Inquiry Document #1147/0/1. The SDC broadly supports Natural England’s views on
matters related to the inclusion of the Western Weald within the PSDNP but, as an
independent organisation, wishes to be free to make its own case, drawing on its local
and other knowledge. In November 2007 the South Downs Campaign commissioned
me as their expert witness to present evidence at the reopened Inquiry.
2.2 Scope of Evidence
My evidence draws on five primary strands of evidence:
1. My original work carried out for the Countryside Agency, and recorded in the
following reports:
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• South Downs National Park: Area of Search for a National Park Boundary, March
2001 (CD 36)
• South Downs National Park: Draft Boundary Recommendations ,July 2001 (CD
31)
• Proceedings from the Countryside Agency Seminar on the Proposed South
Downs National Park, Chichester, Jan 2001 (CD 37)
• CA National Parks Designation Team, Marine Areas Research Report, March
2002 (CD 48)
• Inclusion of Sussex Wealden Landscapes in the South Downs National Park
Boundary. Summary Statement, March 2002 (CD 49)
• Finest Countryside Implementation Team: Splitting of Parishes Report, October
2002 (CD 50)
• Finest countryside Implementation Team: Proposed South Downs National park:
Defining the Boundary in areas of Transitional Landscape, October 2002 (CD 51)
2. The local knowledge and further research work carried out by the South
Downs Campaign and its members. This includes advice from national
organisations such as the Council for National Parks. Whilst drawing on this
information, I would emphasise that I have applied my own professional judgement,
that the views expressed in this Proof of Evidence are my own and that the South
Downs Campaign, as my client, supports the views I express in this Proof of
Evidence.
3. Analysis of a range of information which has accumulated as a result of the
PSDNP Inquiry process. This includes the Landscape Assessor’s report, evidence
presented by various witnesses and associated Inquiry documents, as well as
decisions made in relation to the New Forest National Park and new legal and policy
influences and other matters relevant to National Park boundary setting.
4. New Evidence: Since the adjournment of the Inquiry (23rd March 2005) and the
submission of the SDNP Inspector’s report (31st March 2006), new evidence has
been published which bears significantly on the PSDNP. These include the Draft
South East Plan (March 2006), which thus could not have had a bearing on the
PSDNP Inspector’s Report and was not, to my knowledge, even in an earlier draft
form, discussed at the Inquiry.
5. Government planning policy and guidance. A number of key government
planning guidance documents emphasise the importance of integrated transport and
land use planning at both the regional and local levels. It is clear from the general
thrust of these documents, and government policy generally, that the integration of
transportation planning with land use and other aspects of planning is central to the
government’s objective of achieving sustainable forms of development and, more
recently, its response to climate change. I am not aware of any government or
planning guidance that says its planning and transportation policies do not apply to
the planning of a new National Park. Of course this planning context does not
override the primary legislative context of the PSDNP set by the designation criteria,
but it is without question of significance. The government is bound to take into
account the high level objective of achieving sustainable development, as reflected in
its Planning Policy Statements, “Securing the Future”, the UK Government
Sustainable Development Strategy (March 2005) and Section 39 of the Planning and
Compulsory Purchase Act (2004).
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PPS 1 was published in January 2005, during the Inquiry. The climate change
supplement to PPS 1 was published in December 2007.
I am conscious that as the Inspector has already made an initial recommendation in his
first report (CD #3) to exclude the area known as the Western Weald from the PSDNP,
he will no doubt only reconsider the matter if appropriate new evidence is presented.
The material contained in this proof of evidence is, I believe, sufficient to warrant
reconsideration of that recommendation.
The scope of my evidence relates entirely to the Western Weald. (drawing number
2629/1.) An extract from the South Downs Integrated Landscape Character
Assessment (December 2005) covering the Western Weald is shown on drawing
number 2629/2. Having re-examined the issues concerning the Western Weald, I reach
the conclusion that this area should be included within the PSDNP. My professional
judgement thus accords with the strongly held views of the South Downs Campaign,
the position of Natural England, Hampshire County Council, my original
recommendations for the Countryside Agency and popular support throughout the area
and nationally, as described by the South Downs Campaign in Inquiry Document
#1147/0/2.
2.3 My Original Recommendations
I would emphasise that my original recommendations to the Countryside Agency
on the broad extent of the National Park, including the specific inclusion of the
Western Weald, were entirely based on my own professional analysis and
judgement. I was not asked by the Countryside Agency, or anyone else, to
support any particular type or extent of National Park. The matter was open from
the outset. I had no axes to grind or political pressures to bow to. Whilst
consulting very widely throughout the boundary-setting process, and receiving
advice from statutory and non-statutory stakeholders and consultees, my
professional recommendations were always independent and based on thorough
analysis of the legal and policy basis for National Parks and of the South Downs
itself. Having reviewed my original conclusions on inclusion of the Western
Weald within the PSDNP, I see no reason to change my original
recommendations and, in fact, the additional material set out in this proof adds
further weight to the case for the Western Weald to be included within the
PSDNP.
In summary, these original conclusions and recommendations were as follows:
1) The Western Weald meets the Natural Beauty Criterion for inclusion in the
National Park.
The Western Weald landscapes are of outstanding Natural Beauty and have a strong
sense of place. Their landscape quality is demonstrated through their designation as
AONB. They are typically comprised of an attractive mosaic of oak/birch woodland,
heathland, hedgerows and small -medium sized fields. The intimate scale of the
landscape is enhanced by the topography, which forms a series of sometimes dramatic
Greensand ridges and rich clay valleys.
The scale and enclosure of the landscape, and the absence of extensive or significant
detractors, creates a strong sense of tranquillity and remoteness, which in turn create a
sense of wilderness.
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The landscape quality of the northern part of the Western Weald, and my judgement
that it meets the Natural Beauty criterion, is also acknowledged by the Landscape
Assessor, who states:
2.38 Turning to the land lying to the north of the Rother Valley, I consider that … the
‘North Wooded Ridges’ landscape type is of outstanding natural beauty,
Although he goes on to state:
this area is also isolated by the ‘Sandy Arable Farmland’ from the extensive tract of
qualifying land of chalk downland, which lies to the south and west.
On these grounds he concludes: (not on Natural Beauty grounds)
the ‘North Wooded Ridges’ (and the part of the Low Weald contained within) should
be excluded from the proposed National Park. (Annex B, CD#3)
I address the Landscape Assessor’s judgement quoted above regarding the “Sandy
Arable Farmland” in section 8.5 of my evidence.
2) The Western Weald meets the Recreational Criterion for inclusion in the
National Park.
The vast majority of the Western Weald contains a medium density of public rights of
way, equivalent to many other parts of the PSDNP (on the chalk, for example). The
Sussex Border Path and the Hangers Way also run through the area (see drawing
1384LP/R9 in CD 36). Drawing 1384LP/R8 of the same document illustrates the
extensive areas of common land in the area (a much greater density than on the chalk)
and also the numerous National Trust estates. There are also five historic parks and
gardens within the area. The wooded and heathland land cover which is prevalent
within the Western Weald gives it a marked wilderness quality, and the areas of steep
ridges add drama and physical recreational challenge. The diverse habitats support a
great diversity of wildlife and thus further recreational opportunity.
Given these factors, drawing on the high landscape quality of the area, I concluded that
the area offers an outstanding open air recreational experience, enabling people to “get
away from it all”, and that the Western Weald meets the recreation criterion for inclusion
in the National Park.
3) It is “especially desirable” to include the Western Weald within the National
Park.
Once I had concluded that the Western Weald meets the Natural Beauty and
Recreation criteria, I then considered the area in the light of the “especially desirable”
test. Including within the National Park areas with diversity of character, ranging from
the open chalk scarp to the woodlands of the Western Weald, for example, would
create a greater range of opportunities for appreciation of landscape and for variety of
recreation. The Western Weald areas of the National Park would provide for more
diverse requirements in terms of the type of recreational experience, and also absorb
some of the recreational impact which would otherwise (in the chalk-only model for the
PSDNP) be concentrated on the chalk landscapes. The Western Weald has a higher
recreational capacity than the chalk downland as it is more robust, and less susceptible
to trampling and erosion. It complements the chalk in terms of the type of recreational
opportunities it offers. The top of the chalk scarp, for example, offers exposure and
BACKGROUND AND SCOPE OF EVIDENCE
drama, the wooded slopes and smaller scaled fields of the Western Weald offer greater
shelter and enclosure and a different character of landscape.
I consider that inclusion of the Western Weald would create a National Park more suited
to the contemporary and likely future demands of the 21st Century. I demonstrate later
that it would enable more sustainable forms of access and movement, and would
deliver more opportunities to a wider range of people. On these key government policy
grounds, a PSDNP which includes the Western Weald is more “especially desirable”
than one where the Western Weald is excluded.
2.4 Legal Clarification (NERC and Meyrick)
Since completion of the Area of Search Report and Draft Boundary Recommendations,
the Meyrick Case High Court and Court of Appeal judgements have led to clarification in
the NERC Act in terms of the definition of “Natural Beauty”.
Section 99 of the Natural Environment and Rural Communities (NERC) Act 2006 reads
as follows:
99 Natural Beauty in the Countryside
The fact that an area in England or Wales consists of or includesland
used for agriculture or woodlands,
land used as a park, or
any other area whose flora, fauna or physiographical features are partly the product of
human intervention in the landscape,
does not prevent it from being treated, for the purposes of any enactment (whenever
passed), as being an area of natural beauty (or outstanding natural beauty).
Section 59 (2A) (b) of the NERC Act (2006) reads as follows:
59: Criteria for Designating National Parks
When considering opportunities for open-air recreation, Natural England may take into
account the extent to which it is possible to promote opportunities for the
understanding and enjoyment of an area’s special qualities by the public.
This revised wording has given useful clarification on the definition of natural beauty,
and the potential for opportunities for open-air recreation, but is still fully compatible
with the tests described in sections 5.3 and 5.4 of the Area of Search report. Indeed,
the amendments to the NERC Act have reinforced the way in which the designation
criteria were applied during the early stages of the PSDNP designation process.
Further detail on the implications of the Meyrick Case and changes to the NERC Act is
provided in Natural England Proof of Evidence, ref #1330/1/1, and the South Downs
Campaign Proof of Evidence ref. #1147/1/1.
2.5 Defining Natural Beauty
There has been some reference at the Inquiry as to how natural beauty is defined and
tested, and whether National Parks and AONBs possess different types of natural
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beauty. I have carefully considered the various arguments presented to the Inquiry so
far, and would like to make the following response.
Clearly, landscapes can be naturally beautiful for different reasons. This variety of natural
beauty occurs both within and between existing UK protected landscapes (National
Parks and AONBs).
There is no legal or practical reason why a single National Park or AONB cannot
encompass a variety of types of natural beauty. Section 5.4 of my evidence
demonstrates existing examples of National Parks which contain landscapes which are
naturally beautiful in different ways. Sections 59 and 99 of the NERC Act (2006) refer
simply to “natural beauty”, and thus leave open the potential for different types of
natural beauty within a single National Park.
In addition to the great variety of natural beauty within the UK’s protected landscapes,
there is also great variety between them. For example, the wildness and wilderness of
the North Pennines AONB contributes significantly to its natural beauty. These
landscapes are in marked contrast to the pastoral areas of the New Forest National
Park, and the rich pastoral landscapes of Dedham Vale AONB, where their natural
beauty is a result of a combination of cultural and natural qualities, with a less strong
emphasis on wilderness qualities.
The primary legislation (1949 National Parks and Access to the Countryside Act and
2006 NERC Act) makes no distinction between the natural beauty found within National
Parks and the natural beauty found within AONBs.
The best practice guidelines on landscape assessment (Landscape Character
Assessment: Guidance for England and Scotland Countryside Agency and Scottish
Natural Heritage (2002) CD 57) reflects this legal consistency, and makes no distinction
between the assessment of natural beauty for AONB designation or for National Park
designation. Paragraph 7.21 states:
Natural Beauty: …. is the term that has been used in defining AONBs and National
Parks in England.
Section 7.4 of my evidence provides more detail on the set of landscape criteria
presented in CD57 which contribute to the consideration of natural beauty.
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3.0 Overview and Summary of Evidence
The essence of my evidence revolves around three themes:
1. The Landscape Assessor has wrongly advised the Inspector in a number of
significant aspects and, therefore, the Inspector’s initial report reaches unsound
conclusions with regard to the Western Weald.
2. There are significant amounts of new evidence, including the South East Plan and
the Climate Change Supplement to PPS1, which have been published or have
emerged since the publication of the Inspector’s interim report. This needs to be
taken into account. It is my view that insufficient weight has been given to the way
the PSDNP will operate in the context of the larger planning picture in South East
England. The Inspector may feel, as I do, that this is material to the Inquiry and will
lead him to change his views with regard to the Western Weald.
3. The South Downs Campaign has new evidence to submit. My own Proof of
Evidence forms part of this new evidence.
My evidence is structured in response to the following questions and issues, each of
which occupy a new section.
Section 4: Review of Advice and Evidence Used by the Inspector
This section notes the reliance of the Inspector’s conclusions on the Landscape
Assessor’s report and discusses significant procedural matters related to the latter.
Section 5: Does there need to be a single ‘core character’ to a National Park?
There is nothing in the legislative framework for National Park designation which gives
any requirement for there to be a single or core character to a National Park.
On the contrary a National Park may well “contain almost every kind of natural scenery”,
as Hobhouse stated in 1947 (ref CD 74 Appendix A p.89). The premise that the South
Downs has to have a ‘core character’ is false.
Section 6: Is there a clearly defined area called ‘The South Downs’? Is ‘The South
Downs’ restricted to the chalk? I agree with the Inspector that the non-chalk
landscapes should not be excluded from the PSDNP simply to more accurately reflect a
name (the ‘South Downs’).
My evidence supporting inclusion of the Western Weald within the PSDNP does not rely
to any degree on demonstrating linkages between the Wealden and the chalk
landscapes, though I acknowledge they exist. The term “South Downs” can embrace a
variety of landscapes, including the chalk and the Western Weald, which function well
together to create a sustainable, diverse and beautiful National Park.
Section 7: Does the Western Weald meet the criteria for National Park Designation?
It appears that the Landscape Assessor, the Inspector and I agree that the majority of
the Western Weald (the area known as the North Wooded Ridges, Heathland Mosaic,
River Rother Floodplain landscape types) meets the natural beauty criterion for inclusion
in the National Park.
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I also consider the area to meet the recreation criterion. The Western Weald contains
extensive wilderness areas of woodland and heathland, has a good network of paths,
and ample open access land in the form of extensive areas of common land.
The Landscape Assessor and the Inspector are of the opinion that certain areas of the
Western Weald (the Sandy Arable Farmland and the “A3 corridor” including Petersfield)
do not meet the designation criteria. I believe their conclusions are based on errors of
fact and of interpretation.
Section 8: Do Petersfield and the Lower Rother Valley meet National Park designation
criteria?
Having reviewed my previous judgments and revisited the areas concerned, I conclude
that these areas are appropriate for inclusion within the South Downs National Park on
the basis of the designation criteria.
Section 9: Has sufficient weight been given to the role that the proposed South Downs
National Park would play in the planning of South-East England?
A key consideration in the designation of the PSDNP is its “position in regard to centres
of population”.
Sustainable transport and social inclusion are fundamental to the Government’s broader
policy objectives, and I place the PSNDP in this broader planning context.
In doing so, I conclude that it is “especially desirable” to include the Western Weald
within the PSDNP.
Section 10: Critique of the Landscape Assessor’s Report
I defend the Area of Search Study (CD 36) against the criticisms of the Landscape
Assessor. The research was undertaken using an appropriate, consistent, thorough and
defendable methodology. Our approach followed the brief we were given by the
Countryside Agency. I remain confident in the results.
However, I strongly question the methodology and transparency of the Landscape
Assessor’s report, and the judgements he made. I therefore question the weight that
can be attached to it. This is of particular concern given the Inspector’s reliance on the
Landscape Assessor’s report in reaching his own conclusions.
Section 11: Conclusions and Recommendations
REVIEW OF ADVICE AND EVIDENCE USED BY THE
INSPECTOR
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4.0 Review of Advice and Evidence Used by the Inspector
4.1 Reliance of the Inspector on the Landscape Assessor’s Report
It is clear that the Inspector has relied to a significant extent on the Landscape
Assessor’s Report, as demonstrated in the following extracts from the Inspector’s
Report (CD#3). The emphasis is my own.
1.7 For obvious reasons my conclusions draw upon the reports prepared by the
Landscape Assessor – Mr Nigel Buchan. His main report forms annex A of my
report(s). Amongst other things his report examines in detail the arguments raised by
objectors regarding the satisfaction or otherwise of the statutory criteria. Although my
report covers much of the same ground, and therefore overlaps the Assessor’s
report, I have resisted the temptation to summarise or otherwise rehearse the detailed
material contained in his report. Mr Buchan also prepared a separate report at my
request – this forms annex 2 to my report. This report considers the landscape of the
A3 corridor and the Rother Valley. These are places where my site inspections and
my reading of the background documentation led me to the view that for some
additional scrutiny would be helpful. (CD#3)
2.5 It is also important to confirm at the outset that my conclusions regarding the
way the Agency approached the designation process have been informed by the
reports prepared by the Landscape Assessor, Mr Nigel Buchan. He attended all of the
“in-principle” and “chalk-only” inquiry sessions and has had access to all of the
relevant inquiry material. His reports form Annex A and B to my report. While my
conclusions make frequent references to his reports in the interests of brevity I do not
quote extensively from them. (CD#3)
2.29 As mentioned previously, in his report the Landscape Assessor argues that
characteristic natural beauty should be assessed in deciding whether land should be
included in the National Park. The key characteristics or elements of the chalk
downland identified in paragraph 6.94 of his report and listed on page 125 of CD56,
are not those found in the Weald and other nearby non-chalk landscapes. These
areas may have characteristic natural beauty but this is decidedly different from the
characteristic natural beauty of the chalk hills. In the Assessor’s opinion only the chalk
downland areas have the distinctive and characteristic natural beauty appropriate for
the PSDNP. (CD#3)
2.53 It will be evident from the preceding paragraphs that, like the Landscape
Assessor, I harbour serious reservations regarding the inclusion of extensive nonchalk
landscapes in the PSDNP on the strength of unifying links to the core chalk hills.
Even if I had concluded that the unifying links were individually or cumulatively
sufficiently strong to effectively link these tracts to the core area, the land in question
would still need to satisfy the statutory criteria. As mentioned elsewhere, I am not
convinced that they do. (CD#3)
Section 7: Section E- Inspector’s note p.76: In my earlier comments in the section on
the “Inclusion of non-chalk landscapes” – see section 1 - I expressed the view that
the National Park should be more closely focussed on the core chalk landscapes. If
that recommendation is accepted a wholesale review of the boundary from section E
through to section H is required. In part this recommendation took account of the
Assessor’s conclusion that neither the A3 corridor nor the Rother Valley to the east of
Petersfield satisfies the designation criteria. (CD#3)
REVIEW OF ADVICE AND EVIDENCE USED BY THE
INSPECTOR
2629P/RT/FF 14
4.2 The Landscape Assessor
In my view, the Landscape Assessor’s Report contains a number of significant
weaknesses and areas of fundamental and material concern. In reopening the Inquiry, I
suggest that these concerns should be fully reviewed by the Inspector, as they have
never, as far as I am aware, been subject to expert or any other scrutiny.
If my concerns are accepted by the Inspector, I would suggest that there may be
grounds for the Inspector changing his preliminary recommendations regarding the
Western Weald.
4.3 The Landscape Assessor’s Report: Procedural Matters
I understand that the Landscape Assessor’s report was not submitted until after the
close of the Inquiry, I am therefore concerned that it was not subjected to public
scrutiny and consultation. I believe this to be a matter of fundamental procedural
concern in terms of reliability of the advice being given to the Inspector, and thus the
Inspector’s conclusions.
I therefore welcome this opportunity for the Landscape Assessor’s Report to be fully
considered at the reopened Inquiry.
I am also led to understand that the Landscape Assessor did not attend all sessions of
the Inquiry. If this was the case, I would submit that it may not have been possible for
him to have based his advice on a complete understanding of the facts as presented as oral and examined evidence.
DOES THERE NEED TO BE A SINGLE ‘CORE
CHARACTER’ TO A NATIONAL PARK?
2629P/RT/FF 15
5.0 Does there need to be a single ‘core character’ to a National Park?
5.1 Introduction
It appears to me that one of the fundamental mistakes of the Landscape Assessor was
to assume that National Parks need to have “an individual, distinctive and coherent
identity” which amounts, in the way he interprets this, to what I shall call a “core
character”. He then jumps to the idea that the “core character” of the South Downs are
the chalk landscapes and that, therefore, the Western Weald must be excluded.
I refer to paragraph 6.31 of the Landscape Assessor’s report (Annex A, CD#3), which
states (my emphasis):
6.31 It is clear from the evidence that the circumstances of Dartmoor, the New Forest
and “South Downs” are different in many respects. Despite this, I consider that the
findings of the Dartmoor and New Forest Inquiries confirm the need for National Parks
to have an individual, distinctive and coherent identity. In the case of the proposed
National Park, I interpret distinctive “South Downs” character to correspond with
those that have typical chalk downland landscape characteristics.
This is an assumption which the Landscape Assessor has made. It has no sound basis
in either legislation or in practice, and represents a misunderstanding of both the
National Park designation criteria and the landscape evidence within existing National
Parks in England and Wales.
This issue is fundamental to the whole question of whether or not the Western Weald
should be included in the PSDNP. The Landscape Assessor states that National Parks
need to have “an individual, distinctive and coherent identity”. He draws his evidence
from circumstances in the Dartmoor and New Forest National Park designation
processes. This position is supported by Moira Hankinson on behalf of West Sussex
County Council (ref1881/2698/1/11).
Analysis of the legislative background, the Dartmooor and New Forest Inquiries and
existing National Parks clearly indicates to me that National Parks do not need to
display the individual, distinctive and coherent identity, assumed by the Landscape
Assessor. The Landscape Assessor’s assumption is unfounded. Therefore, his
following statement that I interpret distinctive “South Downs” character to correspond
with those that have typical chalk downland landscape characteristics is irrelevant (See
SDC Proof The Demise of the Concept of ‘Characteristic Natural Beauty’, Inquiry
Document No: #1147/1/2).
The Landscape Assessor’s view is picked up by the Inspector in his Report, as the
following paragraphs demonstrate:
2.27 …Hobhouse may have seen merit in variety but like the Assessor I interpret the
remark as a reference to variety between National Parks not within them. As the
Assessor notes, variety of countryside character is generally not a characteristic of
English National Parks. (CD#3)
2.29 As mentioned previously, in his report the Landscape Assessor argues that
characteristic natural beauty should be assessed in deciding whether land should be
included in the National Park. The key characteristics or elements of the chalk
downland identified in paragraph 6.94 of his report and listed on page 125 of CD56,
are not those found in the Weald and other nearby non-chalk landscapes. These
DOES THERE NEED TO BE A SINGLE ‘CORE
CHARACTER’ TO A NATIONAL PARK?
2629P/RT/FF 16
areas may have characteristic natural beauty but this is decidedly different from the
characteristic natural beauty of the chalk hills. In the Assessor’s opinion only the chalk
downland areas have the distinctive and characteristic natural beauty appropriate for
the PSDNP. (CD#3)
In my view, the Dartmoor and New Forest findings do not confirm a ‘core character’
precedent applying to the South Downs, and I set out the detailed reasons for this
below. I believe the Inspector has been misled in this regard by the Landscape
Assessor’s advice. Similarly, I believe the Landscape Assessor has misled the
Inspector in asserting (para 6.31of Landscape Assessor’s Report) that the South
Downs corresponds to the chalk downland landscapes only. It does not in my view,
and this is the subject of Section 6 of my evidence.
5.2 Legislative Background
The Evidence of Dr Val Kirby (on behalf of Natural England) regarding the NERC Act (ref.
#1330/1/1) sets out the legislative position that the National Park designation criteria
relate to Natural Beauty only; not “characteristic natural beauty” as described by the
Landscape Assessor. The South Downs Campaign also make this point in para 3.2.9
of their Evidence on the Implications of the NERC Act 2006 and Meyrick Judgements
for South Downs National Park (Inquiry Document #1147/1/1). I agree.
The reference in the Dower Report “in which…characteristic landscape beauty is strictly
preserved” (para 4, Dower report 1945, CD73) is set in the context of National Park
purposes following designation. It does not refer to the criteria for designation, and was
not used in the 1949 legislation.
5.3 Recent National Park Public Inquiries
The Dartmoor Public Inquiry was purely a boundary review of an existing National Park
which had its own particular characteristics. It was site specific, as acknowledged by
the Dartmoor Inquiry Inspector at the time:
[The] critical test for boundary making in this case was whether the landscape was of
both Dartmoor character and national quality.” (paragraph 2.22, Dartmoor Report CD
68) (emphasis added).
The Dartmoor Inquiry had a limited remit, to adjust the boundary to a National Park, the
extent of which had already been defined (“Dartmoor character and national quality”).
From my knowledge of Dartmoor, it does have a single, dominant character, although
there is variety within it. It was right that any boundary review would adjust that National
Park to retain this dominant character. But that was Dartmoor. Other National Parks
are different. Others have greater variety of landscape character. The Dartmoor case
does not mean that all National Parks, or the new PSDNP, should have a single
dominant character in the way I believe Dartmoor does (see #1147/1/2).
There is therefore no case for applying the Dartmoor situation to the designation of a
new South Downs National Park. There is no legislative backing to the Landscape
Assessor’s claims regarding the need for National Parks to have an “individual,
characteristic and coherent identity”. Nor is there any valid precedent to be taken from
the recent Public Inquiries relating to the Dartmoor and New Forest National Parks.
They have their own special landscape characteristics, as the South Downs has its.
DOES THERE NEED TO BE A SINGLE ‘CORE
CHARACTER’ TO A NATIONAL PARK?
2629P/RT/FF 17
5.4 Case Studies Demonstrating the Variety within Existing National Parks
I now turn to a number of case studies from existing English and Welsh National Parks
to demonstrate the variety of landscape character which exists within them, and which
was part of the original vision for National Parks in this country, as presented by
Hobhouse, Dower, et.al.
The Landscape Assessor states in that:
6.110 Although Hobhouse refers to there being “merit in variety”, it is clear from the
context of the remark that he was seeking variety between National Parks, not within
each one. (Annex A CD#3)
I disagree with this interpretation. There is much evidence to suggest that variety within
National Parks was the original aim, as explained in the South Downs Campaign’s core
document on the Landscape of National Parks CD 217. The following extract from this
document illustrates my point:
2.6 The support for including areas of high landscape quality rather than one uniform
character or geology can be seen from the list of suggestions provided by Dower and
Hobhouse themselves. Both considered that distinct but complementing
characteristics could be brought together in the geographical unit of a National Park.
Dower brings together the Peak District and Dovedale, Exmoor and the North Devon
Coast, the Black Mountains and Brecon Beacons. (CD 217)
This is consistent with my own view of the PSDNP as “a rich assemblage of classic
Lowland English landscapes” (ref: Area of Search Report CD 36 Section 7.7).
This variety within National Parks can be demonstrated through the following examples:
5.4.1 Snowdonia
Hobhouse, in his “Appreciations of Proposed National Parks” proposes a much larger
area for Snowdonia (which he calls the North Wales National Park) than that originally
proposed which “will contain almost every kind of natural scenery”.
Today’s Snowdonia National Park covers a very similar extent to Hobhouse’s “North
Wales National Park”. It covers not only the Snowdon Massif, but also the separate
mountain blocks of Glyderau, Rhinogau and Arenigs, Carneddau and Cadair Idris. The
mountain blocks are separated by lower valleys and/or estuaries. The western side of
Snowdonia National Park includes the coastal plain between the mountains and the
sea, and has a far more settled character. The distinct variety of underlying geology is
demonstrated in the geology map in Appendix A.
Snowdonia National Park thus contains areas of distinctly different landscape character,
as described in CD217, Annex A, Section 14)
5.4.2 Pembrokeshire Coast
Hobhouse, in his “Appreciations of Proposed National Parks” expands Pembrokeshire
to encompass the inland Preseli Hills for their “distinct and satisfying character” as well
as the coast.
The Pembrokeshire Coast National Park is unusual in that it contains four “islands” of
National Park which are not connected. The National Park encompasses the dramatic
Pembrokeshire coastline, which itself contains very varied geology, as well as theDOES THERE NEED TO BE A SINGLE ‘CORE
CHARACTER’ TO A NATIONAL PARK?
2629P/RT/FF 18
distinctive Preseli Hills inland to the north east. It also encompasses the inland, lowland
landscape of the Daugleddau Estuary. These areas are shown on the geology map
provided in Appendix A.
The variety of landscapes within the Pembrokeshire Coast National Park is described in
detail in CD 217 Annex A, Section 13.
5.4.3 Brecon Beacons
Hobhouse, in his “Appreciations of Proposed National Parks” chooses a wide variety of
landscapes for the Brecon Beacons, from the Brecon Beacons themselves, the Black
Mountains (“A separate, quite different yet no less attractive area”) and the intervening
Usk valley and limestone scenery to the south, this being “essentially the National Park
for South Wales”. This geological diversity can be seen on the geology map provided in
Appendix A.
These four areas are all visible today as areas of highly differing character within the
National Park, as described in CD 217 Annex A section 4.
5.4.4 Peak District
The Peak District contains substantial areas of three national-level Landscape Character
Areas (LCAs): The Dark Peak LCA, the White Peak LCA and the South-west Peak LCA.
The very edges of the National Park extend into a further three LCAs. A geology map of
the Peak District and The National Park boundaries in relation to the LCAs are shown in
Appendix A.
The three main LCAs within the Peak District are very different in character. The
contrast between the White Peak and the Dark Peak is particularly striking, reflecting
fundamentally different geology. In his “Appreciations of Proposed National Parks”,
Hobhouse comments that the Peak will be “enhanced by the contrast between the two
chief components of its scenery”. Indeed, the areas suggested by Dower in 1945 as the
first 10 National Parks include “The Peak District and Dovedale”: This is a clear and very
early acknowledgement of the landscape variety within the single National Park. It is
described in detail in CD 217 Annex A section 12.
5.5 Conclusion
Both the Landscape Assessor and Moira Hankinson (on behalf of West Sussex County
Council and Chichester District Council), have, in my view, been fundamentally misled
by the Dartmoor and New Forest boundary decisions (Ref. Proof reference no.
1881/2698/1/10, August 2004). On the basis of the boundaries as finally decided, both
these National Parks have, from my knowledge of them, strong ‘core characters’. They
extend this to the South Downs, using the ‘precedent’ argument, and conclude the
PSDNP should also have a single core character – the chalk. But there are other
National Parks with no single core character. The examples given above display far
greater diversity than Dartmoor or the New Forest.
Neither legislation, Natural England policies, Public Inquiry precedent nor case studies
require a new National Park in England or Wales to have an ‘individual, distinctive and
coherent identity’, a ‘core character’ or a ‘single character’.
The Landscape Assessor is therefore incorrect in his conclusion that:
2.39 I also find that the ‘Heathland Mosaic’ and ‘North Wooded Ridges’ landscape
types are not of ‘South Downs’ character and should not be included with the chalk
DOES THERE NEED TO BE A SINGLE ‘CORE
CHARACTER’ TO A NATIONAL PARK?
2629Pdownland in the proposed National Park. I consider that the ‘Heathland Mosaic’ and
the land lying to the north of the ‘Scarp Footslopes’ have insufficient unifying links with
the chalk downland to warrant their inclusion. (Annex B CD#3).
It is therefore not correct that a new National Park should be of a single core character.
This false assumption should not be allowed to prejudice the designation of a National
Park in the South Downs which has the potential to include a rich diversity of landscape character and recreational opportunity.
IS THERE A CLEARLY DEFINED AREA CALLED ‘THE
SOUTH DOWNS’? IS ‘THE SOUTH DOWNS’
RESTRICTED TO THE CHALK?
2629P/RT/FF 20
6.0 Is there a clearly defined area called ‘The South Downs’? Is ‘The South
Downs’ restricted to the chalk?
6.1 Introduction
My evidence in this section follows closely on the matters of principle discussed in
section 5. It also relates to the question of whether there is a landscape entity called
“The South Downs”, whether “The South Downs” can be accurately and clearly defined
and, if it can, whether it is restricted to the ‘core chalk’ or not.
It seems reasonable to me that a proposed South Downs National Park should broadly
encompass an area which is recognised as “The South Downs”, but need not
necessarily be strictly limited to it (even if it could be precisely defined) provided that the
statutory tests are met and the bounded area ‘works well’ in practical terms and meets
other considerations such as those of sustainability and social inclusiveness. We are
not, implicitly, being asked to consider designating a National Park which could run
westwards into Dorset or northwards into the North Downs. This is stretching the
concept of a South Downs National Park too far. So, the PSDNP needs to relate in
some easily understandable way to something called, in broad and common sense
terms, “The South Downs”.
The Inspector states that:
2.11 The non-chalk landscapes within the PSDNP lie to the south and more especially
to the north of them. It seems to me that by including these landscapes the Agency
has defined a possible South Downs National Park that is different to the common
perception of the area having that name. However, I am not convinced that this is of
itself a significant problem and it certainly does not warrant the exclusion of the nonchalk
landscapes (or the chalk landscapes that lie outside the South Downs) simply to
more accurately reflect its title. (CD#3) (My emphasis)
I agree.
6.2 National Park Titles and Definitions
It should be noted that the names applying to all designated landscapes in England are
“only names” – they rarely, if ever, in themselves precisely define the place.
This applies to the South Downs. The term has been loosely applied to an area of
chalk, Wealden and other landscapes in this part of England, but there is nothing in the
name which can clearly be used to limit the PSDNP to the chalk only. To my
knowledge, the “South Downs” has never previously been defined by a precise line on a
map. The designation of the PSDNP provides the first opportunity to define its extent.
There are many historical examples which demonstrate that the name for a National
Park is only a shorthand. For example, the Peak District was originally proposed by
Dower in 1945 as “The Peak District and Dovedale National Park”; The Brecon Beacons
was originally proposed as “The Black Mountains and Brecon Beacons National Park”
and Exmoor was originally proposed as “the Exmoor and North Devon Coast National
Park”. (ref. map extract from 1945 Dower Report, reproduced in CD 217 Annex D). All
these names have been shortened in order to be workable and convenient.
My views on this matter appear to be in line with the Inspector’s Report, para. 2.12
(CD#3).
IS THERE A CLEARLY DEFINED AREA CALLED ‘THE
SOUTH DOWNS’? IS ‘THE SOUTH DOWNS’
RESTRICTED TO THE CHALK?
2629P/RT/FF 21
6.3 The Concept of “links”
Whilst not present at the first part of the South Downs Inquiry, I am advised that there
was a fairly lengthy discussion about the concept of “links” between the chalk and the
Wealden landscapes. The implication was that if there was an accepted case for the
chalk landscapes being included within the National Park a special argument had to be
made for the inclusion of the Western Weald, i.e. there had to be demonstrably clear
“links” between the Western Weald and the chalk landscapes to justify inclusion of the
former, rather than it being accepted that the case is equally strong for inclusion in both
the Western Weald and the chalk within the PSDNP.
If this latter position is accepted, there is no need to argue a case for ‘linkage’. The
discussion on ‘linkage’ is therefore a red herring. My evidence on behalf of inclusion of
the Western Weald within the PSDNP does not rely to any degree on demonstrating
linkages, although I do believe there are very strong linkages between the chalk and
Wealden landscapes and that these are of interest in helping us understand the special
character of the South Downs and thus of the National Park.
6.4 Alternative Models for the Proposed South Downs National Park
At the Area of Search stage of the designation process, I and my team, with the then
Countryside Agency, carefully considered different models for the PSDNP, covering
options of very narrow areas of high chalk through to much larger and more diverse
areas. Our conclusions were largely supported by the then Countryside Agency, and
they now form the basis of the PSDNP. The essence of what constituted “The South
Downs” was the subject of much debate and consultation with a wide number of local
organisations. If there had been widespread and clear opposition to the inclusion of the
Western Weald within the PSDNP from these many consultees at that time, we would
have given serious consideration to recommending the exclusion of the Western Weald
from the PSDNP, on the grounds that it lay outside what could reasonably be
encompassed within the “South Downs”. I read no such opposition through the
consultation process and was confident, at that time, as I am now, that the term “South
Downs” can embrace a variety of landscapes, including the chalk and the Western
Weald, but that this broad interpretation should not go beyond reasonable bounds.
In doing so, I consider that, in our advice, we fulfilled the “especially desirable” point.
We did not advise that the PSDNP should extend unreasonably into areas which were
clearly not “South Downs”, i.e. the Surrey Hills or the High Weald, or into Pevensey
Levels to the east (though we did carefully assess each of these options within the
Project Steering Group). There are also pragmatic reasons why the South Downs
National Park should not impinge into additional administrative areas, such as extending
across the Surrey border.
For the last 40 years or so, the chalk and Wealden landscapes within the Sussex
Downs and East Hampshire AONBs have been successfully managed as a single unit,
to the benefit of both landscapes, and also to the benefit of recreational users and local
residents. It seems to me to be both logical and correct to acknowledge the way in
which the chalk and Wealden landscapes combine and complement each other to form
the South Downs, and to include both within the South Downs National Park.
6.5 Conclusion
It is neither appropriate nor helpful to let a name (the ‘South Downs’), which does not in
any event apply to a precise area of land, define a National Park which ‘doesn’t work’
IS THERE A CLEARLY DEFINED AREA CALLED ‘THE
SOUTH DOWNS’? IS ‘THE SOUTH DOWNS’
RESTRICTED TO THE CHALK?
2629P as well as it could in practical, sustainability, recreational or administrative terms. As
explained in the previous section, a National Park does not need to be of a single core
character. There is therefore no need to limit the proposed South Downs National Park
to the chalk. The case for including the Western Weald within the PSDNP is strong in its
own right, and does not depend on “links” with the chalk area. This National Park
designation presents the opportunity to define what is known as “the South Downs”.DOES THE WESTERN WEALD MEET THE CRITERIA FOR
NATIONAL PARK DESIGNATION?
2629P/RT/FF 23
7.0 Does the Western Weald meet the criteria for National Park
Designation?
7.1 Introduction
Appendix B shows landscape character areas within the Western Weald, as shown in
the Landscape Assessment of the Sussex Downs AONB (1995) (CD 182). The North
Wooded Ridges landscape type, the Heathland Mosaic Landscape Type and the
Rother Floodplain landscape type shown on the plan are all considered by the
Landscape Assessor to be of outstanding natural beauty, and therefore to meet the
natural beauty criterion.
7.2 Meeting the Natural Beauty Criterion
There appears to be agreement between the Landscape Assessor, the Inspector and
ourselves that the majority of the Western Weald meets the natural beauty criterion for
inclusion in the National Park. The Inspector describes the northern part of the Western
Weald as undoubtedly high quality land (para 2.25, CD#3)
The Landscape Assessor also considered the majority of the area to be of Outstanding
Natural Beauty and therefore to meet the Natural Beauty criterion:
2.38 Turning to the land lying to the north of the Rother Valley, I consider that…
the ‘North Wooded Ridges’ landscape type is of outstanding natural beauty. (Annex
B CD#3)
With regard to the “Heathland Mosaic” Landscape Character Type, he comments:
2.26 Despite some adverse development and dense planting of conifers in parts, I
consider that this landscape generally retains a strong “sense of place” and is of high
quality. Numerous paths and tracks provide excellent access to a relatively wild and
remote landscape experience. I conclude that this landscape type is of outstanding
natural beauty. (Annex B CD#3)
He also concludes that the River Rother floodplain is of outstanding natural beauty:
2.24 The narrow alluvial floodplain of the River Rother has a very distinctive “Sense of
place”, derived from its enclosed, intimate and secluded character…Away from the
busy lanes and the A272 the landscape is tranquil and unspoilt, and the river itself is a
very distinctive feature, most visible from the ancient bridges. I conclude that the
River Rother floodplain is of outstanding natural beauty. (Annex B CD#3)
The Landscape Assessor does not comment specifically on the Low Weald Landscape
Character Area (Pockets of which are within the North Wooded Ridges Landscape
Character Area), although the Inspector makes the following observation:
7.184 On balance, and assuming of course that my recommendation in favour of a
more focussed National Park is not accepted, I consider that the visual links to the
Greensand ridges certainly justify the inclusion of those parts of the Low Weald that
are already within the PSDNP. (CD#3 - my emphasis)
DOES THE WESTERN WEALD MEET THE CRITERIA FOR
NATIONAL PARK DESIGNATION?
2629P/RT/FF 24
7.3 Meeting the Recreation Criterion
Neither the Landscape Assessor nor the Inspector are of the opinion that the Western
Weald generally meets the recreation criterion for inclusion in the National Park. I do not
accept this, and do not consider that they have sufficiently appreciated the variety and
quality of recreational opportunities, within an outstandingly beautiful and often wooded
landscape, which are available in the Western Weald. In summary, these recreational
opportunities are as follows:
• Extensive open access land (heaths and commons).
• Medium density of public rights of way including the Sussex Border Path and
Hangers Way.
• Numerous National Trust-managed estates.
• Historic Parks and Gardens within the area.
• Quiet country lanes proving a valuable resource for on-road cycling and horse-riding.
The landscape assessor does acknowledge that:
2.26 This [Heathland Mosaic] landscape generally retains a strong “sense of place”
and is of high quality. Numerous paths and tracks provide excellent access to a
relatively wild and remote landscape experience. (Annex B CD#3)
The Western Weald also contains excellent opportunities for a wider range of
recreational activities, such as participation in archaeological projects. Further examples
are given in South Downs Campaign proof #1147/7/1.
7.4 The Presence of Wilderness in the Western Weald
Given the prominence given by West Sussex County Council to this issue, I wish to
comment on the relevance of wilderness to the natural beauty criterion. I have already
mentioned in Section 2.5 that landscapes can be naturally beautiful for different reasons
– in some cases wilderness can contribute significantly to natural beauty, but in other
cases natural beauty can owe as much to cultural and natural qualities combined, and
the resulting landscapes may display a less strong emphasis on wilderness qualities.
It should always be borne in mind that wilderness/ wildness is one of a series of criteria
which contribute to landscape value and thus to the suitability of landscapes to
designation. The Landscape Character Assessment Guidance for England and
Scotland (2002) (CD57) states in section 7.22:
In considering Natural Beauty and amenity, and in any other situation which requires
that a landscape be identified as requiring special attention, judgements must be
based at least i
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