Representation by South Downs National Park Authority (South Downs National Park Authority)
- Date submitted
- 10 March 2023
- Submitted by
- Non-statutory organisations
Approximately 62% of the proposed Scheme area falls within the South Downs National Park and the majority of the remaining Scheme area is within the setting of the National Park. In summary, the proposal requires land from with the National Park to construct new roads / links and associated drainage and other works, provide a site for the temporary construction compound and provide land for various proposed mitigation measures. As acknowledged in the application submission, without appropriate and adequate mitigation, the proposal will result in significant adverse harm to the National Park. The South Downs National Park Authority (the Authority) will participate in the examination process and will be making a detailed representation at the appropriate time. However, at this stage our main issues (and as raised with the applicant throughout the process) are as follows: • How the scheme meets the ‘major development’ tests. The National Policy Statement for National Networks (2014) paragraph 5.150 sets out the high level of protection afforded to National Parks and paragraph 5.151 the tests necessary to determine the ‘exceptional circumstances’ in which the public interest may be served by the proposed development. It is required, as part of this test, that any detrimental effects on the environment, landscape and recreational opportunities are assessed as well as the extent to which they could be moderated. • Whether the scheme clearly demonstrates the mitigation hierarchy through the evolution of the proposals to show that National Highways have sought to minimise the impact on the National Park and comply with their statutory duty (under Section 62 of the Environment Act 1995) to have regard to the National Park Purposes and duty. In addition, the Authority has identified four key priorities (each carrying equal weight), in terms of mitigating and compensating the direct impacts of this Scheme on the special qualities of the National Park. It continues to be our view that these priorities, set out below, should be used as the guiding framework for any Scheme proposal: • The landscape setting, this includes issues such as cutting into the Downland, land re-profiling, trees / woodland clearance and planting, and tranquillity (the landscape setting of this particular area featured prominently in the public inquiry into the designation of the National Park); • Water, particularly the quality and quantity impacts on the River Itchen Special Area of Conservation and Site of Special Scientific Interest, and Winnall Moors Nature Reserve; • Chalk grassland, including mitigation or compensation for areas directly impacted by the scheme, and • Access to and from the National Park from Winchester for walkers, cyclists and other users (preventing any further severance and improving access where possible). We are currently assessing the proposals and will wish to raise detailed points at the relevant stage. We are also willing to continue to work with National Highways to try to overcome our objection.