National Park Bid

Following the publication of its 2012 Designation Strategy, Natural England is carrying out a strategic review of the extent and diversity of existing Areas of Outstanding Natural Beauty (AONBs) and National Parks (NPs) to establish whether there is potential scope for future new designations.  The South Hams Society has submitted a bid for consideration.  It is reproduced below.


Extension of the South Devon AONB and re-designation as a National Park



A proposal by the South Hams Society

October 2013

 

 

Contents

Foreword

Introduction
The South Devon AONB

Re-designation and Natural England's Designation Strategy

The Effects of Development on the Ecology of the South Hams

The Boundary of the SDAONB and the Case for Extension

Recreation in the South Hams

Local Views on Re-designation

Development in the South Devon AONB

Eleven Case Histories of Poor Development in the SDAONB

Appendix 1 - J Peters: Who wants to live in a National Park?

Appendix 2 - Applications to South Hams District Council for substantial development in the rural South Hams in the period Feb 2011 - Oct 2012

Appendix 3 - NE Exeter letter of 24 November 2010 to SHDC


 

Foreword

This document has been assembled by the South Hams Society (SHS) from contributions by a number of its members at different dates. For this reason its structure is somewhat ad hoc, there are areas of repetition and while retaining their relevance some of the statements apply to past events. For this we apologize.

The South Hams is under intense development pressure and there is a strong feeling among many residents of the South Hams that the South Devon Area of Outstanding Natural Beauty (SDAONB) and the surrounding countryside is not being valued and protected as it deserves and should be. It seems clear to them that the AONB designation does not serve to protect the landscape, wild life and culture as it should.

Part of this problem is that Natural England (NE) and the SDAONB Unit do not police the designation adequately. There is no effective enforcement arm in Natural England and they do not appear to keep a watching brief on activities within the designation. To get a specific response on an individual case from NE we have to start from scratch each time each and this may be difficult in the timescales involved.

The SDAONB unit prefers to conduct events to entertain and educate rather than enter to enter controversial debates with the District Council or even alert Natural England. They do not have the resources to carry out the tasks they set themselves. The last Management Plan had 81 priorities thus effectively losing the urgency of those few which demand real priority if the natural beauty of the area is to be protected.

It is clear to us that despite National Parks and AONBs having equivalent legal protection, in practice National Park status is very much more effective in protecting the landscape and wild life. We make this proposal in the belief that extension of the AONB and re-designation as a National Park will be effective in protecting the natural environment we value so much.

Next Steps

We are aware of our limitations as an entirely voluntary organisation to expand and support this proposal for re-designation on our own. On the other hand our anxiety over the erosion of the South Hams landscape and wild life makes us prepared to devote what resources we have to pursue it.

Natural England has the resources and skills to investigate the proposal at a national level and we can harness local knowledge to supplement it. A collaboration between us could satisfactorily explore the case for re-designation. We suggest a meeting at your offices to discuss this would be the next move. We should add that recent discussions with our President, Jonathan Dimbleby, emphasised the need for a meeting with you.

Introduction

The Context

Both AONBs and NPs have two major purposes - firstly the conservation and enhancement of their natural beauty, wildlife and cultural heritage and secondly the promotion of opportunities for understanding and enjoyment of the area's special qualities by the public. They are both national resources, defined as having equivalent landscape status.

For example, when they were designated, in the 1950s and 60s, the Dartmoor NP was considered no more important scenically than the South Devon AONB - it was granted NP status because it was considered to be of greater recreational potential.  

NPs and AONBs differ in the way they are managed.  National Park Authorities (NPAs) are local authorities in their own right and have planning and development control functions and other executive powers. A Park is nationally funded to reflect these responsibilities and removes the local authority requirement for planning within the park boundary.

This confers co-ordinated planning control on the designated area rather than relying on several local authorities to commit to participating when many other pressures distract their attention. By contrast, there are very limited statutory duties imposed on local authorities containing an AONB apart from agreeing a management plan whose content may be so generalised that it has little practical effect on the action of the LPA.

The Government has acknowledged the findings of the UK National Ecosystems Assessment that the natural environment is an essential component of modern society with a value which is intrinsic. It has set objectives to improve the conservation of wild life in the UK. Both the 2010 Lawton report, 'Making Space for Nature' and the Government's 2011 Natural Environment White Paper commented on the loss of wild life and erosion of its habitats. They focused on the social benefits of the countryside and the need to reverse the loss of wild life and its habitats.

It is considered that this should be done by making existing sites larger and managing them better and enhancing their connectivity, i.e. by joining up wildlife habitats to create more coherent ecological networks which would help wildlife adapt better to a changing climate, increase the gene pool and so provide opportunities for isolated populations of threatened species to expand.  

NE which is responsible for the designation of areas of landscape and wildlife importance, including NPs and AONBs, has just published its 2012 Designations Strategy, with which it will take forward the recommendations of the 2010 Lawton report and the Government's 2011 Natural Environment White Paper. The Designations Strategy also reaffirms UK Government commitments made under the UN Biodiversity 2020 and the European Landscape Convention.

NE is carrying out a strategic review of the extent and diversity of existing AONBs and NPs to establish whether there is potential scope for future new designations. NE will develop a checklist to evaluate how future site and area designation proposals might achieve the aims of the strategy so that it can be used to filter and prioritise proposals from third parties for new designations of NPs and AONBs and boundary changes to existing designations.  

About half of the South Devon coastline is adjacent to a Marine Conservation Area. The coastline and Dartmoor are shown on the map 'Overview of Local Delivery Priorities' as already one of NE's 'Special Focus' areas, on which it will concentrate in order to achieve its biodiversity, landscape, access, engagement and other land management objectives.

So the proposal to re-designate the South Devon AONB as a National Park is consistent with Natural England's policies and is timely; when Natural England has decided on focus areas, is re-evaluating designations and their boundaries and has new objectives for preservation and expansion of wild life and its habitats.


 

The South Devon AONB

Problems

In comparison with many other AONBs that are in wilder places, the SDAONB is under two particular pressures.  Its natural beauty sits in a comparatively accessible landscape with a coast line which offers enormous recreational opportunities. These opportunities and the mild climate attract many visitors from throughout the UK and overseas - exceeding, the numbers that visit Dartmoor for example.

These are the assets used by the tourist industry which seeks to gain its income by placing facilities adjacent to them. These facilities generate traffic and require car parks all of which have an effect often on the most sensitive parts of the landscape.

The attractions also create the housing demand. Second home owners buy the high density housing in the centre of settlements previously occupied by local residents. People retiring from other places create an unlimited demand for low density housing on the periphery of towns and villages. In turn these generate high house prices which are quite out of the reach of most local people including those who carry out essential local services.  

SHDC has tried to secure affordable housing for locals by requiring these developers to include it in new estates of otherwise open market houses.  In practice the expected ratio of affordable to market is usually missed by a wide margin, so the total has to be raised, with the loss of ever more greenfield land.  Currently we see national house builders gaining permission to build low density estates of predominantly open market houses on greenfield sites on the perimeter of villages in the SDAONB.

House building targets for future years are presently being formulated. The growth in households up to 2031 has been forecast as between 4,000 and 16,000, but SHDC has let it be known that they believe the houses required to be between 10,000 and 15,000. At the densities used by developers, between 500 and 750 hectares of mostly greenfield sites would be required for these houses, much of it in the AONB.

The second difficulty facing SDAONB is that 84% of it is farmed, much of it intensively compared to traditional farming. Modern farming methods include the abandonment of the old stone buildings, which are often converted to residential use, and the construction of large agricultural buildings to house livestock and machinery.

On the other hand planning restrictions intended to conserve the landscape may put our farmers at a competitive disadvantage without the help and benefits of agro-environmental schemes such as Higher Level Stewardship which would be encouraged by a NPA.

Faced with such difficulties the LPA will lean toward local economic growth and over a period of time the natural qualities of any designated area it administers will inevitably be degraded. We see this happening in the South Hams every day.

Opportunities

Much of the coastal land is owned by the National Trust and is open access land which is traversed by the heavily used South West Coast Path. The Path in turn has frequent connections with the dense network of footpaths, bridle ways and green lanes in the South Hams and with the many lovely beaches which are such a source of pleasure and education to families with young children. The farms of the South Hams often have holiday lettings or operate Bed & Breakfast accommodation which again provide opportunities for recreation and education.

Four rivers rise in Dartmoor and flow through the South Hams to the sea. At present there is an undesignated gap of countryside between the boundary of the SDAONB and the Dartmoor National Park. There is an opportunity for creating an ecological network as suggested by Lawton by extending the boundary of the AONB along one or all of the river catchments to close this gap.

The rivers would then be protected from source to sea thus complementing the West Country Rivers bid to raise their water quality to Good Ecological Status as required by the EEC's Water Framework Directive.

We believe that a South Devon National Park Authority would be better able to deal with these conflicts and opportunities. With its special powers and funding, backed by national resources and expertise, and with a much stronger remit to protect the natural environment, it could provide more effective leadership, not just in conservation but also in resolving the special problems of, for instance, affordable housing and of sustainable farming in a designated landscape.  And recreational opportunity, instead of being an enemy of the natural environment, would enable its conservation.



Re-designation and Natural England's Designation Strategy

John Peter's article in the South Hams Society Bulletin (Appendix 1) first introduced the case for re-designating the South Devon Area of Outstanding Natural Beauty (SDAONB) as a National Park. The article provides a historical background to the SDAONB, suggests reasons why the designation should be changed to a National Park and its boundary extended along the river Avon watershed to provide links to Dartmoor National Park.

This article was written before publication of Natural England's Designation Strategy which asks for proposals from third parties. This section of the proposal considers what evidence is required to meet the Designation Strategy's criteria to change the SDAONB into a South Devon National Park(SDNP).

NE has a statutory duty to keep under review whether any land meets the NP designation criteria. The purposes of NPs are to 'conserve and enhance their natural beauty, wildlife and cultural heritage and to promote the understanding and enjoyment of their special qualities'1.

Policies in the Natural Environment White Paper and Biodiversity 2020 emphasize the need to reverse biodiversity loss and to do this by better management of larger sites, new designations and wildlife networks connecting sites together. River habitats are important in S Devon and water quality requires improvement to meet EEC standards. Lastly, the coastline is a dominating part of the SDAONB so other policies for marine conservation and shoreline management are also relevant 4. A SDNP can contribute to all these policies.

Our principal concern with the existing SDAONB is that built development and changing land use is damaging the beauty and natural environment of the landscape, its wildlife and its cultural heritage. More sensitive development control backed by greater expertise is badly needed and can be provided by a SDNP authority.

As the Area is used very extensively by visitors for recreation it has great potential for increasing the understanding and enjoyment of the public. This function can be increased by the extension proposed which lead the public into the inland areas as shown on the attached map. These are the purposes for which National Parks are designated.

UK Government Circular 2010 for English National Parks and the Broads has reinforced NP objectives. NE has identified the Dartmoor, Plymouth and the S Devon coast as focus areas where designation will be used  as a tool to create ecological networks. So the scene is set for designation as the South Devon National Park. The NE Designation Strategy sets the following principles for designation of new or amended sites.

Be underpinned by the best available evidence -
We must meet Natural England's 'Evidence Standards" - at present we have no exact information on these but we suppose that the evidence must be relevant to the designation and as far as possible from reliable sources such as other statutory bodies and NGOs.

Deliver NE's national and international commitments -
In addition to the national policies on natural environment above, the European Landscape Convention requires the conservation and improvement of landscapes formed by natural and human activity. The South Devon National Character Profile  (SDNCP) which includes references to land use and built development, provides the standards for compliance with the Landscape Convention. Water quality in the Avon  and other rivers if the designation is extended as below can be addressed. A SDNP local authority can help deliver both national and international commitments.

Whenever possible enhance connectivity -
There are 4 rivers rising in Dartmoor whose estuaries are in the SDAONB. A wildlife corridor can be provided by extending the designated area over a river watershed to the boundary of Dartmoor. The Avon extension would be less than one mile to reach the Park boundary and protect the river and its wildlife from source to sea. It would complement the West Country Rivers Trust bid to raise the water quality to Good Ecological Status. The SDNCP notes the traditional agricultural links between S Devon and Dartmoor.

Operate at a sufficient scale to facilitate coherence -
At present the AONB is funded by three Local Authorities. Funding by Government of one Park Authority would focus action to protect and enhance the landscape and wildlife and its habitats.

Facilitate resilience in the face of climate change and other impacts -
The major impact on the SDAONB is development particularly large housing estates and  large agricultural buildings for livestock and machinery which have often been sited in prominent places. Less damaging sites have not been considered. We have a list of 60 such planning applications in 14 months, none of which have been referred to the AONB Unit which is not a statutory consultee. The link with Dartmoor will ease migration to higher, cooler places where vulnerable species may be able to survive climate change.

Wherever possible encourage stakeholder and community engagement -
The community in the SDAONB is very conscious of the need to protect and enhance the Area. There have been many complaints about the lack of protection currently  provided and many parish councils feel that their comments do not have any effect. A more responsive planning authority would be welcomed by many. It may be possible to recruit the support of local MPs, wildlife organisations and prominent members of the community.

Increase public understanding and enjoyment of the natural environment -

The South West Coastal Path runs along the entire length of the SDAONB which is used by numerous walkers throughout the year. Its recreational value must be at least the equal of Dartmoor. The network of footpaths and bridleways in the Area is extensive and well used 5 and extensions along the rivers would provide the opportunity to add to them. There are numerous beaches accessible from the coast path providing safe bathing and rock pools for families with small children.

Take a holistic approach so that revised boundaries take account of existing designations -
The Heritage Coast and the Undeveloped Coast run along very nearly the whole length of the AONB and extends into 3 Marine Conservation Zones proposed along the S Devon coast. Both designations and Shoreline Management would benefit from the expertise, co-ordinated policies and control expected of a National Park.


In fulfilling all of the above, take an ecosystem approach -
The proposal for a SDNP complement the existing Dartmoor NP and an extension along the river watersheds would bring a new level of integration which can be used for public recreation and tempers the effects of climate change. Most importantly the extension would provide wildlife corridors between S Devon and Dartmoor to improve the robustness of wild life habitats and thus increase the gene pool available.

The area covered by the SDAONB has considerable geological and topological diversity including cliffs, plateaux, deep combes with streams and woodland and estuaries with beaches. The diversity supports a wide range of wildlife and makes it very attractive to visitors. In the past National Parks have often been in wilderness areas where the impact of development is small. These areas provide robust exercise and recreational facilities for teen-aged children and adults. But they are not so suitable for families with small children whose need for smaller scale safe environments is just as important. It is this environment that much of the South Hams can provide.

However the same area has a higher population and generates a demand for  development which unless carefully planned becomes a major threat to the natural environment.  The South Devon AONB is such a case. A South Devon National Park with dedicated planning processes could do much to preserve and enhance a landscape of great beauty and recreational value for both residents and visitors.


 

The Effects of Development on the Ecology of the South Hams

South Hams Society does not have concrete evidence of the changes that have taken place to the ecology of the AONB but our Vice Chairman - John Peters used to be the Assistant Warden to Ian Mercer at the Field Studies Council, Slapton Centre.  He has examined your own National Character Area Assessment 151 for South Devon and notes the following points:
The recreational opportunities suggested in your report are not the responsibility of the AONB unit nor is it a criterion of AONB status to improve recreational opportunities, rather this is for a National Park and is good reason for re-scheduling this AONB.  The first statutory criterion of AONBs and National Parks are said to be of equivalent value. The major addition to be gained from re-designation lies in the second statutory criterion, understanding and enjoyment of the area's special value. It is the nature of this recreation potential that is so unique to this area which is both well endowed with public footpaths because of the patchwork of small fields, green lanes and viewpoints as well as having 97 km of one of the most picturesque and valued coastlines. Over 60 km of this is in the hands of the National Trust and listed as open access land.
 Your comments on recreation say:-
An extensive network of public rights of way, which includes the South West Coast Path National Trail, several regional trails and parts of the National Cycle Network, provides a valuable recreation resource. Further recreational opportunities are offered by open access land around most headlands and along much of the coastal corridor, and access to beaches. The maritime environment and estuarine systems provide considerable opportunity for water sports and fishing. The many historic towns and villages provide other leisure and recreation opportunities including access to local food, culture and heritage .The area has become a market leader in green tourism. The award-winning South Hams Green Tourism Business Scheme has 69 accredited businesses in the AONB improving their own environmental performance.
Your opportunities section goes on to say:

Maintain and improve the quality of recreational assets, including the South West Coast Path National Trail and other quiet recreational routes along rivers and coast by supporting opportunities to connect and link with new multi-user routes, urban green spaces extending from built-up areas and sustainable transport schemes, particularly in areas closet where people live, to give more opportunities to more people to access the natural environment.

Support proposals in the Devon, Plymouth and Torbay Rights of Way Improvement Plans and in the Plymouth area and Torbay Green Infrastructure Delivery Plans. Support Green Tourism initiatives. Water-borne recreation in the rias and estuaries and along the coast can provide close access to natural environment assets, both biodiversity and geodiversity, reducing the need for land-based infrastructure and vehicle movements. Balancing an increasing demand for water based leisure with any potential resulting disturbance should be given careful consideration.

What other AONBs do not have, is a plethora of boating and yachting havens, a famous surfing beach and estuaries which attract large numbers of tourists from far afield.  Our tourism figures greatly exceed those of Dartmoor and unfortunately result in house values far above the national norms.  AONB visitor spend is estimated at £105M/annum on 2003 data arising from 5M visitor days.  These figures do not include the contribution of the boating fraternity. Defra's own figure for tourism in Devon in Charting Progress 2 suggests 80% of the 3.5 million/annum tourists go to the coast - not Dartmoor!

So far as the landscape and biodiversity are concerned your report 151 is written on the basis of the present status of the area.  We consider that the area has already deteriorated and that the AONB status has failed to protect such areas as the Slapton Ley from eutrophication due to changed agricultural practises.  The Gara river that feeds the Ley has had areas of lowland heath at Moreleigh obliterated by farm intensification.  Traditional grazing for meat and milk production have given way to increased arable with drastic hedge and bank removal, for example, potato crops on the steep sided valleys found in the Avon catchment.

Recent research in the Avon estuary has shown how the eutrophication of the river has initiated high production rates of blue green algae in the estuary blanketing the salt marshes and shutting out light. This has initiated rapid erosion of the marsh of the tidal zone.  AONB status has been entirely unable to control the agricultural land management which has been aimed at restoring the habitat of the Cirl Bunting without any holistic overview that a National Park would bring.

These data are most unlikely to be limited in their implications to just the Avon catchment. We would wish to see some boundary changes incorporated in order to bring Lawton principles to bear on our 4 river catchments, all of which rise in Dartmoor NPand suffer from a lack of protection before entering the AONB. Recently the South West Rivers Trust has successfully bid for £370K from the EA to spend on river improvement of 3 of these.

Roadside verges were alive with orchids in the early 60s and despite some recent improvements they are but a sad example of what used to be common. We consider that Devon county roads have not been managed to adequately reflect the AONB needs. Despite this the area still contains a comparatively high hedgerow density which might be protected by NP designation.

The local authorities have agreed an AONB Management Plan but not then ensured that it is adhered to when pressures for development, agricultural change and energy production occur.  In order to justify its existence the AONB Unit has carried out a displacement activity by concentrating resources into educational, community and recreational projects which are more the responsibility of a Park rather than trying to manage major changes to the landscape for which this area is renowned.  At present responsibility for AONB management  is given to local government whose interest is local yet the AONB is part of a National Resource.

John Peters was the originator of the Countryside Survey, and states that he would be hard put to find reason for not placing the area into an unique character as it was outside the influence of ice sheets and has raised beaches and rolling country that become rare further west. A point that is emphasised in your own report.



The boundary of the SDAONB and the Case for Extension

The natural beauty the South Hams

The natural beauty of South Devon in general is evidenced by over a third of its area being designated as an AONB and by many other sources ranging from landscape assessments to painters such as Girton and Turner.

There is no recorded statement setting out a clear rationale for the boundary of the South Devon AONB. And this is not surprising because the landscape character of many of the inland rural areas outside the boundary differ little from those within it. This can be seen immediately from the coloured map of landscape character types introducing the 2007 Landscape Character Assessment of the South Hams administrative area below.



South Hams Landscape Character types & Landscape Description Units 

If we do a more careful analysis, the maps of individual landscape character type in the same document show that considerable areas of 6 of the 9 major landscape types occur both inside and outside the AONB. These are:

Inland undulating uplands
River valley slopes and combes
Upper farmed and wooded slopes
Lower rolling farmed and settled slopes
Unsettled farmed valley floors
Coastal slopes and combes


Just two landscape types occur only in the AONB - Open coastal plateaux and Estuaries. One landscape type, Lowland plains, more heavily settled and with a variety of land uses does not occur in the AONB. Lowland plains occupy less than 10% of the South Hams area and the AONB about 30%. So around 60% consists of landscape types shared between the AONB and undesignated countryside. All these landscape types are lightly settled both inside and outside the AONB. To most observers there is little difference in natural beauty between the AONB and the undesignated rural areas of the same type.

The Extent of the Proposal

Among the issues yet to be defined in this proposal is the possibility of joining forces with other designated areas to form a single National Park and final proposals for the boundary of the area in the South Hams to be re-designated.

Possibilities for partnerships in the bid include the Tamar Valley and East Devon AONBs. You have suggested joining with Dartmoor NP but we think this a more remote possibility. No approach has been made to any of these authorities.

We are not sure why you consider the SDAONB too small to be a stand-alone National Park but if the designated area was extended then this consideration would vanish. The evidence from the landscape type analysis above suggests that a much greater area could be considered for re-designation.

The area might include the water sheds of the five rivers rising in Dartmoor extending from the boundaries of the Dartmoor NP to the present boundary of the AONB. This would protect them from the source to the sea, cover much of the South Hams administrative area, implement the recommendations of the Lawton report by providing wildlife corridors from one designated area to another and reinforce the objectives of the South West River Trust to improve the water quality in these rivers.


A Map of the South Devon AONB together with suggested extensions


 

Recreation in the South Hams

We have to acknowledge that the South Hams is already so well-known for its recreational opportunities, and that such strong commercial interests are engaged in promoting those opportunities, that re-designation might not significantly increase visitor numbers above their present high levels.  What it would do is to preserve for future generations the natural environment which underpins the recreational opportunities.

The 2007 Landscape Character Assessment of the South Hams administrative area acknowledges the extensive use of these areas for recreation. Water sports are now accessible to all sections of society - surfing, wind surfing, kite surfing, paddle boarding and kayaking are all very common in the South Devon waters and are not costly pursuits.

The South Devon beaches are famous for their beauty and the safe environments for beach games and bathing they offer especially to families with small children.  There are 68 beaches used by the public and a further 106 inaccessible small coves.

South Devon has a dense network of public rights of way which are extensively used. A major national trail, the South West Coast path follows the whole of the coast line. Altogether there are 384 km of public rights of way in the AONB alone and probably over 1,000 km in the District as a whole.

Tourists come to South Devon from all parts of the UK but because of the ease of access particularly from the population centres of Plymouth and Torbay. The area is used extensively by Londoners and because of the good motorway connections there are many visitors from Bristol and the west midlands including Birmingham and the surrounding towns and cities.

Recreational Possibilities in a National Park

In the 2005 NE publication "Promoting outdoor recreation in the English National Parks: guide to good practice", Lynne Crowe looked at unsatisfied demand and listed a number of activities that an NP might provide. She found that general access to any water for 'low-key family paddling' is poor throughout the NPs.  This is something that the South Devon coast and estuaries, with their secluded sandy beaches and rock pools, offer in abundance. Safe and delightful bathing can also found in its rivers, such as the Dart and Avon.  

It is precisely this type of opportunity, within very good and generally unspoiled scenery, that leads so many parents repeatedly to bring their young families here.  In a country in which children are increasingly isolated and protected from their natural surroundings, this is a much safer and more interesting place for them than most people's home territory now is - it is somewhere that young people can have freedom to explore, on the water as well as on the land.  

Most members of SHS have benefited from time spent somewhere like South Devon in their youth and believe it is of terrific importance.  And of course it fits exactly with the aims of the National Trust, which promotes such experience on the substantial areas of land it owns in the AONB, for example the East Soar Farm camp and other camping ventures such as that at Wayland nursery.

Crowe believed that cycling and horse-riding in NPs would increase if the infrastructure was available. There are many public bridleways in the AONB and there are already some designated cycle routes.  For the true enthusiast the hills are an attraction, and because the lanes tend to follow the ridges they offer wonderful views for those who are prepared for the physical effort.  Mountain bikers are happy getting dirty in the green lanes.

There is certainly scope for more horse-riding and pony-trekking for visitors.  The green lanes, and some of the beaches such as Wonwell, provide very good riding, though for walking as well as riding better north-south routes need to be developed.  The stables and associated accommodation for holiday-makers could often be provided in redundant farm buildings and could help provide farm income, as is more common on Dartmoor.

Other activities listed by Crowe are:

General sight seeing/driving around.  Though there are a few good viewpoints from public roads, this is not an activity that should be encouraged in the SDAONB.  The roads are not well suited as they have steep hills and dangerous bends.
 
Walking/strolling for less than an hour. Very good opportunities around the town centres and short rural walks. The fishing/trading/smuggling/WWII history is always interesting and gives good scope for guided walks.

Walking for 1-4 hours.  Excellent - the South West coast path, the riverside routes such as the Avon (including the Woodland Trust's 400 acre Avon Woods and others with public access).  The South Hams has a good network of public rights of way: green lanes, bridleways and footpaths.  If the traffic can be tamed, the tarmac lanes are also very good for walking and offer magnificent views.
 
Hill or fell walking for more than 4hrs.  Very good, particularly the coast path, but there is a need for more simple, bunkhouse-type, accommodation along it.  This is surely something that farms could provide, alongside camping opportunities.  It seems to fit in with the National Trust's objectives for increasing outdoor activity on its land.  

There is also a need, as there is for horse-riders, for better north-south routes.  It should be possible for walking and riding visitors to move between the South Hams and Dartmoor, not only to experience the very striking differences between them but also to allow them to adjust their plans to their abilities and to the weather that prevails during their stay in the area.  

The South Hams might be seen as a user-friendly companion to Dartmoor, in which conditions are better suited to the young, those who are new to country activities, the elderly and the less able. The environment is much more sheltered than Dartmoor, distances are shorter, map-reading is infinitely easier, shelter or help is more easily found, and enthusiasm can be maintained by the greater variety of surroundings that will be met in a day.  

Boat trips/cruises.  Very good, not only for cruises on the rivers and the Kingsbridge Estuary, but also along the coast.  There is great scope for wildlife-watching trips in environment-friendly craft both up the rivers and along the cliffs and coast.


Angling.  This term encompasses both fresh-water and sea fishing.  There could be considerable gains to the former if the water quality in our rivers can be improved. The latter offers some income to local fishermen and boat owners.

Climbing.  Not a primary attraction for the area, but there are organisations offering coasteering, which is apparently a physical activity involving movement along the intertidal zone of a rocky coastline on foot or by swimming.  Perhaps not good for wildlife.

Caving.  There are no doubt opportunities on the coast, but there is presumably a possible conflict with wildlife.

There is obviously a tremendous offer in the way of water sports.  The estuaries are very good places to learn to sail in a quiet and safe environment but with proper exposure to the vagaries of tide, current and fluky wind.  This level of family-friendly boating needs protection and support in the face of the more profitable accommodation of large power craft.  Canoeing, paddle boarding and kayaking on both sea and river, and of course very good surfing, wind surfing and kite surfing are all readily available.

Crowe speaks of the particular difficulties NPs face in trying to work with 'hard to reach' groups, such as the elderly or young people, spatially or socially isolated groups, and other minorities which may not be formally represented or organised.  There is much in the South Hams for both the young and the elderly.

Crowe has little to say about the provision of accommodation for visitors.  Our location is such that, as now, people from outside the area would visit for a few days - we aren't a day trip from a big city in the way that many NPs are.  Most would come as families, couples or individuals, rather than as groups.  So there are more opportunities to get people into self-catering or catered accommodation on farms and in private houses.  This would greatly benefit the local economy.


Local Views on Re-designation

You have asked for a statement of the extent and nature of the local consensus for designation. We have not attempted to carry out any survey of of the views for and against re-designation as a National Park. In our view it would be premature to do so before a more well defined proposal has been made. Experience has shown that a negative reaction could be generated before a defensible case has been formed and adequate arguments devised to support it.

We could expect the existing South Hams District Council to be against the proposals as it would remove much if not all of their planning powers. We expect that the farming community would be dubious about the proposal unless it could be shown that there would be gains for them in agro-environmental grants.

Because of central Government cuts the South Hams District Council are reducing their support for recreation and tourism. They view the AONB Unit as part of themselves and encourage it to spend time and effort in these activities to replace their role.  The AONB Unit has withdrawn emphasis on landscape and wildlife to follow this path.

In our view this is motivated by the Unit failing to make inroads into Council policy toward AONB protection on these latter aspects and carrying out a "displacement activity" instead.  A National Park would legitimize this developing emphasis by the AONB Unit.


 

Development in the South Devon AONB

To clarify the present planning situation 98.02% of the SDAONB lies in the South Hams District and Devon County administrative areas. 1.95% lies in Torbay, and 0.03% in Plymouth City, both unitary authorities. The SDAONB covers 38% of the land area of South Hams District and includes 41% of its population.

It is clear to SHS that the current rate and quality of development in the SDAONB are degrading its special characteristics. If the trend continues, its future worthiness as a designated national resource must be open to question.

SHS recently held an Any Questions event 'The SDAONB - love it or lose it'. It was chaired by Jonathan Dimbleby, our President, and it was open to all comers.  Its underlying themes were the current threats to the AONB, the rate at which its countryside is being lost, and how it could best be protected in the future.  Our bid for NP status was discussed but the feeling was that remedial action could more quickly and perhaps more effectively be taken by invoking the assistance of NE along the lines set out in its recent designations strategy document.

Our perception is that SHDC is giving planning permission for greenfield sites in the AONB much too readily. In common with all other aspects of national life an AONB has to accept change but we must control development very rigorously indeed if its worth is to be maintained even for the next two or three generations. We must be particularly careful not to sacrifice it's value for future generations for the sake of current maybe transitory goals.

NE has consistently emphasised to us that the protection afforded to an AONB equates to that of an NP.  This is not well understood locally, inside or outside local government, and certainly not among those developers who are regularly seeking permission for wind turbines and other developments affecting the SDAONB which they would not bother to try on Dartmoor or Exmoor.

The National Planning Policy Framework (NPPF) states in paragraphs 115 and 116 that great weight should be given to conserving ...AONBs and that planning permission should be refused for major developments except where it can be demonstrated that they are in the public interest. There is some uncertainty about the definition of major development and how public interest is demonstrated. Central Government has told us that these criteria are determined by the Local Planning Authority. However the South Hams District Council has no written definition of them at present and is unlikely to have before the new local plan is adopted in 2016/7. This planning vacuum is exploited by developers.  

One has only to glance at the property sections of the national papers to appreciate how much effort is going into attracting wealth to the South Hams.  Many developers from throughout the country are seeking to trade in land and buildings here.  The resulting pressure on SHDC's planning function, experienced as persistence on the part of developers, their use of very expensive advisers and their willingness to go to appeal, is undoubtedly very great.  Only very strict adherence to policies and procedures by a well-resourced planning function can resist it.

As examples of the damage being done we are enclosing eleven case studies. The developments covered are for residential, commercial (apartments), agricultural and equestrian use.  For most of the examples we give some explanation of how we believe permission came to be given.  

There can be few landscapes which bring as much money into their local government area as the SDAONB does, so it seems reasonable to ask that the planning function of the LPA should be well staffed, trained and managed.  We do not think this is presently the case and fear that with current pressure to cut costs it may get even worse.  The implications for the AONB need to be made clear.

In 2011 the Society asked SHDC that the AONB Manager be given the opportunity to hold one or more training sessions for planning officers.  This was agreed, but we understand that it has not happened and that there has been a change of mind.  It might help if NE were to repeat the request.

In 2011, the Society strongly supported the adoption of a new planning protocol designed to involve the AONB Unit in significant planning applications.  SHDC's compliance with it has been very patchy - we have already brought to NE's attention the 60 cases in which the AONB Unit had apparently not been consulted.  However even if it directed most of its resources to planning the AONB Unit could look at only a fraction of the applications that might affect the AONB. So the main defence of the Area has to be with the planning officers.

As the case studies show, a particular danger arises where perfectly well-meaning applicants for planning permission are given pre-application advice by planning officers who have not been trained in the characteristics of the AONB that need to be cared for.  Once an application is launched it has a certain momentum which makes meaningful consideration of alternatives very unlikely.  This is a particular problem with the siting of agricultural buildings, where the farmer may already have incurred substantial expenditure at the application stage.  

The main development pressures are for housing and employment, agricultural buildings, wind turbines, photo-voltaic arrays, and equestrian menages. The list at Appendix 2, illustrates the rate of development. It contains some of the applications made in the 20 months from February 2011 to October 2012 for substantial developments on rural sites within the AONB or close to its boundary.  

Appendix 2 excludes applications within development boundaries, replacement buildings, applications for renewal of approval, individual domestic buildings and applications for minor works. The status of the application is noted as registered, withdrawn, approved or refused. In some cases the size of the building is noted. 38 applications for agricultural buildings, 12 the subject of permitted development rights, dominate a total of 57 applications listed.

In none of the applications listed is it apparent that the AONB Unit was consulted under the planning protocol.

Housing and Employment

SHDC has itself initiated the loss of greenfield land by selecting in its Local Development Framework sites for residential development in the AONB.  This is justified by requiring the developer to provide on site urgently needed affordable housing for local people for sale using shared equity or letting at social rents. These dwellings are subsidised by the profits made on open market housing.

So the sites were chosen to be attractive to national developers but the withdrawal of grants by the Government and the current economic situation has resulted in very few  affordable houses being built. Instead the vast majority of the houses built come onto the open market at prices beyond local people.  They are advertised in the national press as having the advantage of being in an AONB.

SHDC was one of the first LPAs to complete the entire process of constructing a Local Development Framework as required by the Office of the Deputy Prime Minister in the last Labour Government.  The last stage was the selection of sites for housing and employment described in the Site Allocation Development Plan Document (DPD), using forecasts for growth made in 2004 and enshrined in the Core Strategy which was adopted in 2006.

The planned total of housing for the rural areas was 500 houses and 3.2 ha of employment land before 2016 and roughly the same beyond 2016 up to 2026. Of the total of 1,000 houses and 6ha of employment land, about 785 and 4.3 ha of employment land lie in or immediately adjacent to the SDAONB.

These sites are being developed at between 20 and 30 dwellings per hectare so the 785 houses in the AONB required before 2026 will use between 26 and 40 hectares, the employment land required raises the total to 30 to 45 hectares and finally the land required for infra-structure raises it to 35 to 50 hectares. This is a significant expansion of the built up area in the SDAONB - depending on how you calculate it about 10 - 20%.

Those 2004 forecasts now look very dated but as the Site Allocation DPD has been approved by the Planning Inspectorate, the District Council has adopted it and is intent on proceeding with the sites it contains. In the rural areas of the SDAONB most of these are large greenfield sites intended to attract housing developers who are asked in the Core Strategy to include 55% of affordable housing and employment land within their planning applications. The Council considers that meeting the target for affordable houses is its first priority and most people agree.

The proposals in the Site Allocations DPD were designed to attract housing developers in order to meet the affordable housing requirement. Small brownfield sites in villages were not considered. Large greenfield sites suitable for low density housing on the perimeter of villages with a school and a shop were selected. This extension of suburban sprawl contrasts vividly with the often high density of traditional village structure. Apart from eating up large amounts of the SDAONB it irreversibly alters its character.

Developers nevertheless claim that in the current financial climate and housing market they cannot fulfil such a programme and are currently including only 20-30% affordable housing within their planning applications for these sites. These applications have been approved by the Council. So there is a possibility that the Council will have to increase the size and number of the sites if it is to meet its targets.

Current housing forecasts present a wide range of possibilities. The Strategic Housing Market Needs Assessment recently conducted for SHDC forecasts for the period 2011-2031 an increase in households of between 3,930 and 15,630 i.e. between 187 and 781 a year.

SHDC has let it be known that in this 20 year period they believe the houses required to be between 10,000 and 15,000, i.e. between 500 and 750 a year. There are other forecasts that even higher numbers of houses are required.

Under SHDC's present policies and at the densities now being used by developers - 20 houses a hectare - the housing will require between 25 and 40 hectares of greenfield land to be built on each year.  

This number of houses would obviously require significant expansion of the supporting infrastructure - roads and sewage and services such as schools and care for the elderly. This will require further land - possibly 20% more - i.e. between 30 and 50 hectares. The median of 40 hectares equates to the removal of one medium sized farm from the South Hams every year. Given present figures 40% - i.e. 17 hectares will be in the AONB.

The District Council has already shown itself to have inadequate resources and skills to deal with previous levels of development without considerable damage to the AONB. SHDC could not ensure that such future development would be accommodated without considerable damage to the AONB, even if it were totally committed to its protection. With present levels of control considerable damage can be expected.

 Agricultural Buildings

The type of new development that would most likely strike a visitor as disfiguring the AONB is the rash of agricultural buildings, prominently sited and of industrial appearance.  That farmers should not be put at a disadvantage by virtue of their land being in the AONB is certain, but we believe that the designation must involve some constraints if it is to be meaningful.

Farmers often remark that they are responsible for the beauty of the AONB but the truth is that leaving aside natural features what is most attractive about the AONB was formed by their fathers and grandfathers. We do not accept the dictum that what is good for farmers must necessarily be good for the AONB.  There has been a tendency on the part of the council, which is very strongly supportive of farmers, to permit buildings on the sole grounds of their being for agricultural use, without close examination of need, of siting or of appearance.  

The list at Appendix 2 includes 38 applications for agricultural buildings, including a number under permitted development.  Their total floor area is 20,000 sq. m (about a quarter of the size of the O2 Arena).  The desire for these large buildings arises from modern farming practices which include the overwintering of livestock and the storage of large machinery.

The old stone barns are not adequate for these purposes, so they are turned into dwellings, often second homes or holiday lettings and planning applications are made for large new buildings.This change is not a total loss as the old buildings provide an opportunity for accommodation of all sorts to support recreation.

Of course it is not within planning control to alter farming practices but the siting and construction methods of the buildings are selected by the applicant solely for ease of use and economy. They are not examined carefully by the LPA for integration into the AONB landscape.

They often occupy prominent greenfield sites on the skyline which are isolated and not integrated with other farm buildings. They are usually large in size, have low pitch roofs with ridges up to 12 m in height. The construction materials are often unsympathetic - poured concrete, profiled metal sheeting and stained boarding. Access to the buildings by large 32 ton articulated lorries is required which require wide splays for turning and visibility and large hardstandings.

All these features make them stand out from the traditional Devon landscape of small stone and cob barns and narrow twisting lanes with high 'Devon banks'.  Consequently their siting and construction require sensitive handling.  But because farming is correctly considered an important activity it is incorrectly assumed that any more careful examination of the farmer's proposal will be obstructive.

This assumption is especially convenient in an LPA with a high workload of planning applications - over 2,500 in most years.  However these agricultural buildings have a greater effect on the AONB than many other applications, especially those within development boundaries, on which more effort is often spent.

Faced with such a rash of new 'farmsteads', we would expect an NP to give serious thought to mitigation, but neither SHDC or the AONB Partnership appear to have done so.

Before the period covered in Appendix 2, NE's Exeter office had already taken one case of agricultural development up with SHDC.  During the 3 year period 2007-2010 there were 20 planning applications for buildings at Hendham View Farm, Woodleigh, totalling more than 5,700 sq. m (which are not included in the 20,000 sq. m mentioned above). They are prominently sited in the Avon Valley, a rural and undeveloped part of the SDAONB.  
No credible landscape impact assessment was produced for any of the Hendham View planning applications, and there was no prospect of adequate landscaping.  None of the applications went to the Development Management Committee for wider consideration. They were approved by the local ward member and the Chair of the Committee.  

NE Exeter wrote to SHDC about this case on 24 Oct 2010, emphasising the need for SHDC to work closely with the AONB Unit, to have an effective planning protocol in place, and to require landscape assessments by qualified professionals.  Their letter is at Appendix 3.

Several other farms have followed the same course, for example, Borough Farm, Prawle, where the buildings total 1,800 sq. m.; Higher Hatch Farm, Loddiswell, with 1,020 sq. m. and Winslade Farm, Frogmore, where they total 1,234 sq. m.

Meanwhile development at Higher Hendham Farm has continued. The buildings there now cover over 6,700 sq. m. and several of the applications in the most recent batch were again retrospective.

Wind Turbines and Photovoltaic Arrays

Renewable energy projects include large wind turbines and solar farms. The LPA is developing a policy for renewable energy installations but at present this is only a guide to the sources of information and does not amount to a clearly stated set of boundaries of acceptability.

The current empirical policy adopted by the planners is that small - up to about 25 meters - wind turbines for local enterprises are acceptable. Larger commercial turbines - typically 80-100 meters high - have been refused to date although appeals are now being made. Many smaller turbines of 25 m or less for supplying power to local farms and enterprises have been approved.

Proposals for solar farms are increasing and applications have been made for several of between 10 and 25 hectares. These can be just as damaging as wind turbines to AONB as they not only cause visual damage to the landscape when visible but also have a dramatic effect on wildlife. An application for a 12.4 hectare array outside the AONB has been approved and another immediately adjacent to it is being considered.

But applications for large turbines and solar farms of 10 acres and more are regularly made for sites along the 33 Kv power lines. Under the NPPF and central Government policies on renewables these would probably have had to be accepted in the long term despite surveys showing a majority of the public against them by 4:1.

However the public outcry has at last reached Government's ears and the new Guidance to NPPF on renewables has provided a stronger voice for public opinion and more protection of the landscape. Despite recent reinforcement of these views to planning inspectors in statements by the Secretary of State it remains to be seen how effective this guidance will be.

SHDC has guidance documents on renewables in place but these only provide sources of information and do not amount to a policy. So each of the many applications now coming forward generates argument, in the course of which the importance of landscape is at risk of being sidelined.  This not helped by SHDC's extreme reluctance to require applicants to provide Environmental Impact Assessments - see below.

Equestrian

Conversion of land from agricultural to equestrian use, together with the building of stables, probably accounts for comparatively little damage to the AONB, but it is extremely difficult to justify.  It does alter the landscape for the worse, and it benefits nobody other than the person who seeks to do it.

Perhaps because the area is known for its recreational opportunities and has attracted significant wealth, there is nevertheless an ever increasing demand for equestrian facilities in the AONB. This requires stables and the division of fields by fencing into small parcels. The result is that the landscape changes into a sort of scrappy suburbia which is quite foreign to the agricultural scene.  

At the instigation of the SDAONB Manager a policy on horse-related development (DP18) was included in SHDC's most recent LDF.  It allows new buildings only where they are well-related to existing ones, but in practice new stables are often permitted in open countryside, and the policy does little to control incongruous tape and fencing. A NP would be able to advise on such development as a positive support for equestrian recreation.

The Planning Protocol

In the first part of 2011 the Society exchanged a number of letters with SHDC in an attempt to strengthen the wording of the new protocol then being sought by the AONB Manager for consultation between the AONB Unit and SHDC's Development Management Department.   

The Society was particularly concerned that the AONB Unit be involved from the outset in any pre-application discussion of proposals which would impact the designated area, that it be kept informed of new applications, that it be given extra time in which to comment if it so requested, and that it be involved in the council's deliberations on any new local plan.  

We also asked SHDC to take steps to counter the practice of gaining very substantial development rights through the submission of incremental applications.  We did secure some improvements to the wording of the document, but we must acknowledge the fundamental difficulty that the AONB Unit doesn't have the resources to keep on top of all the applications.  

If too much emphasis is placed on the protocol there is a danger that planning officers will consider that the council's duty to protect the AONB is discharged simply by informing the AONB Unit of the application without any input by Development Management.

The new protocol was adopted late last year, but as the list makes clear there are many cases in which SHDC has apparently not followed it.  It may be helpful if we give an account of three recent examples of inappropriate development, all very prominent, all squarely in the designated area, all the subject of strong objections by the Society and mentioned again in the case histories at the end of this document:

a.  Three barns totalling 1022 sq. m at Higher Hatch Farm, Loddiswell applied for in February 2012 (0291, 0292 & 0292 /12).  The position is a very prominent one in the Avon Valley.  Asked why the AONB Unit had not been consulted the (senior) planning officer e-mailed "There has been no involvement from the AONB Unit.  Advice from the AONB team is not always required and is a judgement for officers to make when considering the application".

The AONB Manager was then involved and objected to the applications, as did the council's own landscape officer.  The officers eventually recommended refusal of all three, on landscape grounds, but the Development Management Committee approved them as being essential to the farm. It was later revealed that another site much less prominent was available but not investigated.

b.  Barn in field to north of Marlborough-Salcombe Road.  The site is prominent in a stretch of undeveloped land and can be seen from many parts of the AONB and the Salcombe/Kingsbridge estuary.

A large barn was permitted by agricultural determination in 2010 (0246/10), but when erected it was found to differ from the approved plans.  At the same time there were objections that the holding was actually equestrian rather than agricultural.  

One application (0323/11) to retain the building was withdrawn.  Another (1313/11) was refused, after the council's consultant questioned the agricultural justification and both the AONB Manager and the council's landscape officer objected strongly on landscape grounds.  

At the end of 2011 a fourth application (3087/11) was submitted by a different agent with a revised opinion from the same agricultural consultant.  Despite continued objection from the AONB Manager and the council's landscape officer this was approved under delegated powers.  We do not know what the building is being used for now.

c.  Barn at Preston Cottages, West Alvington (3021/11).  Agricultural determination was granted late last year but it is only now that the building has been erected that people have commented on the eyesore that it is.  There is a landscaping condition but it is obvious that the building will always be very obtrusive.  

Now that questions are being asked it has emerged that the neither the parish council or the ward member, or anybody else, was consulted.  The officer report says that the council's landscape officer raised no concerns subject to the landscaping condition.

SHS has several times asked SHDC what qualifications its landscape officers hold, but the information has been refused on the grounds that personal data is exempt from the provisions of the FoI Act.  A request that the AONB Unit should be allowed to hold a training session for planning officers on the special characteristics of the designated area was initially agreed, but SHDC told us in June of this year that it had not taken place and there were no plans for it in the future.  

Environmental Impact Assessments (EIAs)

We believe that SHDC is taking a damagingly lenient view on the need for EIAs when they are required for developments in or near the AONB. In February of this year the Society analysed the 34 screening requests made to the council since the current Regulations came into force in August 2011. 23 had been decided: 4 positive (EIA required) and 19 negative (EIA not required).  All 4 positive decisions were made by the same planning officer, who  has now left the council. The 19 negative decisions were made by the 9 other planning officers.

The Regulations also stipulate that the reasons for screening decisions should be published, but they were not on SHDC's website for any of these 23 cases.  When a screening opinion has come to light it has often been little more than a yes/no officer's view rather than a reasoned conclusion.

There have also been proposals which should have been screened but were not. Under the EIA Regulations of 2011 a development with 2 or more turbines, a turbine with a hub height over 15m or a solar array covering more than 0.5 ha. constitute Schedule 2 development. Under the selection criteria defined in Appendix 3 of the Regulations the need for an EIA must be considered for Schedule 2 developments when it would be in or near a 'sensitive area' such as an AONB.   

Planning permission granted for a turbine with a 20m mast at Chivelstone, in the AONB, was recently quashed upon judicial review because the council had not screened it for the need for an EIA. Yet a later application for two turbines in the AONB at Bantham was not screened for an EIA despite the Society pointing out it as necessary.  

A developer wishing to install two turbines with masts of 50m at Torr Hill was  told that no EIA was required, even though they would overlook the AONB from 150m and 400m respectively. Three other developers wishing to install masts of 80 to 90m. at Yealmpton, Ugborough and Halwell, all near the boundary of the AONB were also not required to provide an EIA. Since no record of the council's reasoning in these case has yet been made available, we cannot say what importance, if any, was attached to the AONB.

The AONB Partnership

We believe there would be advantage in NE looking at the role of the AONB Partnership.  It is too concerned with attracting money and with the encouragement of tourism, neither of which are purposes for which we fund it.  It could do very much more to promote understanding of the designation and to explain why the landscape should be protected.  There is a very great need for local education.

The Role of Natural England

Lastly, we ask that NE itself, when asked for support, be more forthcoming.  Too often requests or consultations are met only with standing advice.  A recent example of this is the application for a wind turbine 80 meters tall at Higher Torr Farm just outside the boundary of the SDAONB and visible from many parts of the AONB and Dartmoor NP. The first letter sent  consisted of standing advice. Only when a resident complained and asked for a stronger response related to the actual case was a second letter was sent detailing the  objections to the specific application. The case history of Gerston Point where NE visited the site only after a strong appeal by the Society.

 


Eleven Case Histories of poor development in the South Devon 0AONB

Introduction

The type of new development that would most likely strike a visitor as disfiguring the AONB is the rash of agricultural buildings, prominently sited and of industrial appearance.  That farmers should not be put at a disadvantage by virtue of their land being in the AONB is certain, but we do believe that the designation must involve some constraints if it is to be meaningful, and we do not accept the dictum that what is good for farmers must necessarily be good for the AONB.  

There has been a tendency on the part of the council, which is very strongly supportive of farmers, to permit buildings on the sole grounds of their being for agricultural use, without close examination of need, of siting or of appearance.  

Conversion of land from agricultural to equestrian use, together with the building of stables, probably accounts for comparatively little damage to the AONB, but it is extremely difficult to justify.  It does alter the landscape for the worse, and it benefits nobody other than the person who seeks to do it.

We  believe there would be advantage in Natural England looking at the role of the AONB Partnership.  It is too concerned with attracting money and with the encouragement of tourism, neither of which are purposes for which we fund it.  It could do very much more to promote understanding of the designation and to explain why the landscape should be protected.  There is a very great need for local education.

As the examples show, a particular danger arises where perfectly well-meaning applicants for planning permission are given initial advice by planning officers who have not been trained in the characteristics of the AONB that need to be cared for.  Once an application is launched it is difficult to change it.  The Society asked SHDC, in 2010, that the AONB Manager be given the opportunity to hold one or more training sessions for planning officers.  This was agreed, but we understand that it has not happened and that there has been a change of mind.  It might help if Natural England were to repeat the request.

As examples of the damage being done we are enclosing eleven case studies. In some cases they have been mentioned earlier but are now covered in greater detail and with photographs to illustrate them. The developments covered are for residential, commercial (apartments), agricultural and equestrian use.  For most of the examples we give some explanation of how we believe permission came to be given.  


1. Gara Rock Hotel (SX752371)

A coastguard station was built at Gara Rock in the 19th century, with a row of cottages.  In 1909 they were converted to a hotel


The old hotel buildings from the Coast Path

Apart from a break in WWII, the hotel continued to operate until 2004, when it was bought by Coast Group, which on its website describes itself as 'a first class coastal development company'.  In the same year a planning application for the demolition of the hotel and its replacement with 21 holiday apartments and other facilities was submitted and refused. At the same time it was observable that the buildings and services of the hotel were allowed to run down.

In 2005, after another unsuccessful application, permission was given for redevelopment into a hotel including 19 self-contained holiday apartments, restaurant, bar, staff accommodation, parking and ancillary infrastructure (application 1858/05).

In 2007, after three more applications, permission was given for a hotel comprising 14 bedroom suites, 19 self contained holiday apartments, restaurant, bar, swimming pool, staff and ancillary infrastructure, car parking and associated works (2627/07).

In 2009, after two more unsuccessful applications, permission was amended to 14 holiday apartments, 5 holiday cottages, 18 bedroom hotel, restaurant, bar, swimming pool, staff and ancillary infrastructure, car parking and associated works.  A condition restricting apartments and cottages to a maximum of 8 weeks occupancy by any one person was replaced by one which required the developer to ensure that none of the holiday apartments or cottages were occupied as a person's sole or main place of residence (1244/09).

Late in the same year permission was revised, while retaining the 14 holiday apartments, 5 holiday cottages, 18 bedroom hotel, restaurant, bar, swimming pool, staff and ancillary infrastructure, parking and associated works (0027/10).

In June 2010 permission was given for the easing of a condition requiring the completion of the hotel restaurant and bar before any of the apartments were occupied (1273/10).

In July 2011 July 2012 further applications were made for a external changes and a new structure in the grounds (1710/11, 1058/12).

In November 2012 an application to allow for permanent occupation of the apartments and cottages was refused (2733/12).

SHDC has refused several of Coast Group's applications, mainly on grounds of protecting the AONB and local tourism.  But it must be assumed that when it bought the hotel in 2004 the company was given an indication that development would be allowed provided the building did no more damage than the one it was replacing.  The earlier applications included statements to the effect that the new building would be within the footprint and height of the old hotel.  Not having drawings of the old hotel, we cannot say for certain whether this remains true of the current development, but we are almost sure that the current building is larger and higher.

It is true that the developer has been at some pains to listen to local views and that recently opinions have been more favourable than they were at the beginning.  But both the council and local people have been worn down by the stream of applications and, latterly, by the sight of an inactive and very unattractive building site and have wanted it finished.  In the face of the developer's claim that the project will make a loss and may be abandoned or mothballed, the Council has recently refused to allow permanent occupation.

The old building, dating from long before the designation of the AONB, was a familiar blot on an otherwise unspoiled and very remarkable piece of coastal scenery, recognised as such and protected as a national resource.  In such a case an LPA should surely permit change only where it really will protect and enhance the landscape.  This would require a much more rigorous starting point in any negotiation.  

At Gara Rock the new development is much more prominent from the adjacent beach, the coast path and the sea. We have no doubt that, having established such a large foothold, the developer and the individual buyers of the apartments and cottages will be wanting more.

The two photographs below were taken in May 2013.

 

 

 

 

 


2. Gerston Point (SX741418)

(Approved and now building.)

 

Birds eye view of site using Google Earth

Gerston Point is an extremely sensitive site in the Kingsbridge/Salcombe Estuary:

There had been a bungalow and out-buildings there from well back into the last century.  They had a small footprint, were of a small enough size to mean that human activity would not greatly affect the surroundings, and they were very inconspicuous. Tony Soper the well known naturalist was the owner/occupier of the site.

In 2008, despite very strong local objections, permission (2067/08) was granted for its replacement by a much more obtrusive modern building, two-storey in parts and with a footprint over four times greater .

The new building will incorporate 5 bedrooms (of which 3 will be en-suite) and a swimming pool.  It is clearly intended that it will be occupied by many more people than the old bungalow.  Human activity will be greatly increased much to the detriment of the natural environment.


View of site, with old building, from the estuary

The Kingsbridge/Salcombe estuary is an SSSI. To quote from the SSSI citation 'The estuary is used as an overwintering ground by large numbers of wildfowl and the intertidal mudflats are important feeding grounds for passage waders'.

The foreshore site to the immediate south of the site, Collapit Creek, where a large area of mud is exposed at low tide, is a major feeding ground for the estuary's bird population. At a favourable time an observer at the creek may expect to see 20 or more species of wildfowl, duck and waders including Merganser, Grebe, geese, Pintail, Tern, Garganey, Shoveller, Teal, Gadwall, Scoter, Pochard, Goldeneye, Redshank, Curlew, Wimbrel, Oystercatcher, Dunlin, Godwit, Plover and Greenshank

The South Hams Society objected to this application vigorously. Its President, Gordon Waterhouse spoke against it at the Development Control Committee and a site visit by committee members was arranged. The Society then pressed the Committee to obtain a further report from Natural England.

Dr Simon Dunsford visited the site and his report acknowledged the sensitive nature of the site and the development pressure on the South Devon AONB and urged the District Council to carefully consider the effects on the AONB including the possibility of future upgrades.

However in the Society's view his report did not do justice to the birdlife surrounding the site. He remarked that Natural England had no knowledge of Cirl Buntings on the site although their presence as breeding pairs was well known to Tony Soper. During his visit only Widgeon, Redshank and Merganser were present on the mudflats - in contrast to large number of species mentioned above - but acknowledged that they were disturbed when he moved to the terrace overlooking the estuary.

He suggested that to minimise the impact the trees and bushes screening the house and garden from the estuary should be preserved. The Society knows from experience how seldom this type of protection is preserved - the occupants choose the site because it is adjacent to the estuary and whatever planning conditions and preservation orders are placed on the screen the desire for wider views ensures that it is gradually nibbled away until it becomes ineffective. This type of action is impossible to police.

The effect of this was that the Planning officer concerned stated in his report to the Development Control Committee that Natural England considered that 'the proposal will not have a significant effect on any protected species. No objection is as such raised'. This statement ignored the concerns expressed in Dunsford's letter about the sensitive site.

Similarly the officer report summarising letters of representation made no mention of the effect on the birdlife expressed by the RSPB, the South Hams Society and others.

This permission was contrary to many policies, and it was clearly damaging to the AONB.  The officer report includes no attempt to justify it on grounds of public benefit, and it is difficult to avoid the impression that it was motivated by an interest in modern design and a desire to draw wealth to the area.  The council's thinking is perhaps summed up by this paragraph:

'It is considered that the proposed design is striking, modern and will make a positive contribution to the landscape setting it enjoys.  The isolated rural setting and the site juxtaposition with the estuary justify and require a very high quality architectural solution to its development.  It is acknowledged that the existing single storey chalet is unassuming but what does it contribute as a building to the sensitive setting?  This is an opportunity to achieve a piece of architecture that although modern and more visually evident than the current building will present a visually positive building.  The replacement of the existing with a more traditional deign is of course an option but there is a danger of introducing design mediocrity which while less challenging to the decision maker is also less likely to positively contribute to the exceptional setting of this site.'

 

3. Three agricultural buildings at Higher Hatch Farm, Loddiswell (SX710469)

(Approved but not yet built.)

The site, ringed in yellow, seen from across the Avon valley

In January 2011 SHDC registered planning application 0215/11 for the conversion of five agricultural barns to three residential dwellings, one holiday let unit and one storage unit. The AONB Unit Manager objected on the grounds that certain external features needed to be determined before the grant of any permission and also that it had not been made clear where the displaced farming activities would be housed.  Permission was granted without this latter point having been addressed, at least publicly.

In February 2012 applications 0291, 2 & 3/12 were lodged, for a 9m x 24m livestock building, an 18m x 32m dry crop store and a 12m x 18m machinery store, total floor area a little over 1000 sq m in a yard of about 0.6 ha.  The site was the hillside to the south of the farm, but well away from it.  This is what the AONB Unit Manager had feared when he objected to the earlier barn conversion application.

In the design and access statement it was claimed that a named council planning officer had indicated this site as being acceptable.  When asked about it, the planning officer denied this, but said he had kept no record  of the discussion.  Asked why the AONB Unit had not been consulted on the application under the planning protocol, he replied to the effect that it was for him to decide whether to involve the AONB Unit or not.   

When the AONB Unit Manager was consulted, both he and the council's landscape officer objected to the proposals on landscape grounds.  Planning officers eventually recommended refusal, but the council's development management committee voted to approve the applications.  Only afterwards did less damaging alternatives come to light.


 The site seen from Rake Farm


Higher Hatch Farm already does the lower Avon valley no favours.  When the new buildings are erected, the damage to it will be even greater.  This appears to be another case in which a poorly researched proposal goes forward on the basis of bad pre-application advice from a planning officer.  Once the applicant has gone to the considerable expense of having drawings made, the plans put forward by an architect, and the application paid for, it has a momentum which makes the consultation process almost meaningless.




4. Barn at Horsecombe (SX726398)


The barn from Horsecombe Cross
     
In 2010 SHDC was asked for an agricultural determination for construction of a general purpose agricultural building,  24m x 18m, close to Horsecombe Cross.  This was granted, subject to a slight adjustment to its position.  The officer report made no mention of the site being in the AONB.

When the building, measuring 27.4 x 19.2m, had been erected it differed from the plans and it emerged that the agricultural justification for the determination previously given had been incorrect.  The applicant was required to submit a retrospective full planning application.  The first (0323/11, early in 2011) was withdrawn after the council's landscape officer had raised concerns.  A second one (1313/11) was refused after the AONB Unit Manager had added his comments and after the council's agricultural consultant had questioned whether the land was really used for agricultural needs or required such a large building.  This and some other parcels of land were being used for horses but hay was also being sold for horse consumption, which it was claimed made the operation agricultural as opposed to equine.

The council gave as its primary reason for refusing 1313/11 that the building, due to its prominent location in an area of undeveloped countryside, size, roof materials and associated earthworks, was considered to have a detrimental impact on the character and appearance of the AONB, the Coastal Preservation Area and the countryside as a whole.

Application 3087/11 was made late in 2011, through a new agent.  The same agricultural consultant offered a revised opinion, based on the applicant now growing hay on slightly more land and an apparent shift of emphasis from the hay being used for the applicant's horses toward it being sold for other people's horses.  The council approved the application, despite the continued objection of the council's landscape officer and the AONB Unit Manager.  When asked, the councillor who approved it said he had done it because it was what people wanted.

We consider that the agricultural justification was extremely weak, the activity being the keeping of horses and the production of food for them, neither of which are defined as agriculture in Section 336 of the Town and Country Planning Act 1990. The council has a duty to protect the AONB.  It should have made closer enquiries for the agricultural determination and from then on it should have worked very much harder to ascertain that this was a justifiable breach of that protection.

The problem, as so often, was the planning officer's limited knowledge and understanding of the AONB at the first discussions with the applicant.


 

5. Barns at Hendham View Farm, Woodleigh (SX745506)

(SHDC applications/permissions  2054 & 2055 of 2007; 1225, 1233 of 2008; 0104, 0105, 0106, 1468 & 1469 of 2009;  1630, 1631, 1632, 1633, 1634, 1635 & 1636 of 2010; and ongoing)

The buildings from the Woodleigh - Preston Cross road

Applications were made in July 2007 for two agricultural buildings which would be joined to make a single barn covering 839 sq m.  Asked why they could not be placed in some other part of the farm where they would be less conspicuous and be outside the AONB, the applicant's agent said that SHDC had been consulted and that a named planning officer had indicated the application site as being the preferred one.  The planning officer subsequently denied this.  The applications were approved.

In 2008 applications for two more buildings, for what was now clearly to be an intensive beef operation, were submitted but were withdrawn after SHDC's landscape officer visited the site.  He found that the original building, which had by then been erected, was not compatible with the AONB.   He said he was fairly horrified at its impact on a sensitive landscape and inclined to recommend refusal of any further buildings.  His 'pragmatic' way out of the problem was to ask the applicant to resubmit the applications for the proposed new buildings (now three in number) with a Local Visual Impact Assessment, to include landscaping measures which would improve the appearance of the building already erected.   The LVIA was commissioned and paid for by the applicant and it said that, with some landscaping and planting, compatibility with AONB policies would be achieved.  This conclusion was accepted by SHDC with seemingly very little questioning and fresh applications submitted in January 2009 for the three buildings, covering a total of 1384 sq m, were approved.

Later in 2009 applications for two more buildings, covering 988 sq m, were approved.  And in September 2010 applications for a further seven buildings totalling 2494.5 sq m. were approved.  The total area of all the buildings up to this point is 5760 sq m.

The applicant has said that the council has requested and received a further ten retrospective applications for additional development that has taken place.  These applications have not been published.

SHS Analysis

Whether or not the planning officer indicated the site as acceptable, he clearly conducted the site meeting(s) without appreciating the protection he should have been giving to the AONB, and probably without knowing where its boundary lay.  By its own account, the council never probed to find out the applicant's full intentions.  No landscape advice whatsoever was taken at the outset.  Later a very obviously partial LVIA, by an unqualified person working for the applicant, was accepted as evidence that the AONB would not be harmed.  Strenuous attempts by local people to protect the AONB, including requests that the later applications should be considered by the council's planning committee, were dismissed.  

Under the provisions of the 1999 Environmental Impact Assessment Regulations then in force intensive livestock installations with a floorspace exceeding 500 sq m constitute a Schedule 2 development for which the council is required to publish an EIA screening opinion, in the course of which the AONB would have been a material consideration.  There appear to have been at least three points at which this should have been done but was not.

In a letter to SHDC about the development, dated 24th November 2010, Natural England's SW Regional Office said "We consider that the industrial character, sheer size of the development, and location in a prominent position is not in keeping with the character and setting of the AONB".



6. Newpark, North Huish (SX272562)

Newpark from the Diptford road


In June 2010 the new owner of the field above approached SHDC for retrospective planning permission for change of use from agricultural to equestrian and also for the buildings, which she wished to enlarge.  The photograph above shows the development as it was then.

In November 2010 an SHDC planning officer gave written advice, saying that there was no record of any planning application having been made and that one was now needed in order to 'regularise' the change of use and the buildings.  She did make the point that the site is in the AONB 'where planning policy aims to restrict further development, only allowing it where amongst a number of other criteria it supports the conservation and enhancement of the natural beauty'.  

However she went on to say that she had no objection in principle to the change of use but that she did think that some features of the buildings and the gateway detracted from the AONB and would need to be changed.  These all related only to what could be seen from the road at the gateway (in the photograph, immediately the other side of the buildings).  There was no consideration of the longer landscape views, such as the one in the photograph, that are the essence of the AONB.

An application (2989/11) was submitted in November 2011.  The council's landscape officer listed the policy objections but concluded that the effects could be mitigated with landscaping conditions. The application was approved.  It included a doubling of the size of the buildings but this has not yet been implemented.  Such landscaping as has been done holds little promise of making the development into one which conserves or enhances natural beauty.

While the case may relate to a comparatively small development, it does show how weak the  protection of the AONB in practice is:

a.  in the initial discussions with the applicant, the planning officer didn't explain, and perhaps didn't herself understand, the essential characteristics of the AONB that needed protection.  So the applicant submitted an application that she believed met any objections that the council might raise, and the planning officer gave it a fair wind.  In very many cases inappropriate planning applications are being supported because of bad initial advice from officers.

b.  in failing to object, the landscape officer, who was consulted only after the application had been launched and had wings, worked to a standard of protection far below that stated in the policies.

c.  no attempt whatsoever was made to test whether the development met the requirement set out in structure plan policy CO3: 'Within AONBs, development will only be provided for where it would support their conservation or enhancement or would foster their social and economic well-being provided that such development is compatible with their conservation.'  The parish's objection was disregarded; the only winner was the applicant.  The similarly-worded public benefit test set out since then in para 116 of the NPPF is proving similarly elusive.

It has to be said that a neighbour unsuccessfully complained to the Ombudsman about SHDC's handling of this case.  The finding was that the papers showed that the council had considered all the policies and matters it needed to.  Notwithstanding the Ombudsman's opinion, it is locally clear that the quality of consideration was poor, and that it led to unnecessary degradation of the AONB.

 

 

7. Barn at Preston Cottages, West Alvington (SX714429)

 

Barn from the Malborough - Kingsbridge road

This was an agricultural determination for a 21m x 21m x 6m building under SHDC reference 3021/11.  The officer report notes that "The proposal was discussed with the Council's Landscape Officer who raised no concerns subject to the implementation of the landscape plan, which will be conditioned accordingly." The site lies within the SDAONB but the AONB unit was not consulted.

The barn lies adjacent to the road from Malborough to Kingsbridge and it's prominence due to its elevated position has attracted many unfavourable comments. The landscaping proposed will do little or nothing to conceal it.


 

8. Barns at Prawle (SX782380) Barns from the East Prawle - Chivelstone road

The site is within both the SDAONB and the Coastal Preservation Area.

Application 2208/10 for a single barn 30m x 15m and yard was submitted in October 2010 and approval was given on 18 November in the same year.  Eight days later applications 2782 & 2783/10 were made for two further barns of the same size, to go into the yard.  They were approved.   In April 2011 an application (0980/11) was made for a fourth building of the same size, and it was granted in June. In August of last year outline permission (0073/12) was granted for an agricultural dwelling.

The first application, for a single general agricultural building, was based on the breakup of a partnership making it desirable for separate storage to be provided.  At least in the documents made available to the public, no mention was made of any other plans or of any intention to apply for permission for other buildings.  SHDC planning officers should, we feel, have been very much more vigilant where designated land was involved.


 

 

9. Thurlestone (SX6742)

Thurlestone from off the coast path

Over the years the village of Thurlestone, which lies in the SDAONB and undeveloped coast, has been expanded by a rash of low density development seen on the right of the photograph. Development has now extended below this to the edge of an area of wetland much frequented by water fowl. The new development is approximately three times the area of the original settlement, is prominent from the South West Coast Path and disfigures the coastline.

This type of development has occurred in a number of other coastal villages in the SDAONB and undeveloped coast most prominently in Wembury and to a lesser extent in Bigbury and Stoke Fleming.

10. Agricultural Building at South Allington  (SX789387)

(Approved but not yet built)

Site of barn from off the Chivelstone - South Allington road


In June 2012 SHDC received an application for an agricultural building 36m x 15m, with a height of 7m, for the storage of grain and farm machinery for a farm based in South Allington.  The site is a prominent one - greenfield, separated from other farm buildings, in an attractive valley that is overlooked from a number of vantage points.

The development would involve the creation of a large turning area for 44-ton HGVs, and the plans show that some 100m of stone field boundary wall would be destroyed.  This is probably an understatement as large splays would also be required in order to get a 44-ton lorry off the lane.

The building was to be covered in mid to dark grey steel cladding, with a fibre cement roof, so it would be of industrial rather than agricultural appearance.  No attempt was made to follow the guidance given in the county council's design guide "New Farm Buildings in Devon".

The site was actually chosen by SHDC planning officers, after discussion of a number of options, though they say that the building then being considered was smaller and better-looking than the one eventually applied for.

In later discussions the applicant agreed to revised door designs with wooden panels and to copper beeches being planted along the field-line closest to the roadside.  Neither seems likely to make much difference within any meaningful timescale.  Officers were not successful in pressing for wooden cladding on a steel-framed building.

Since the use of 44-ton lorries is implicit in the proposal, it seems surprising that no serious highway concerns were raised.  The approach road is shown in the photograph below.


 

Officers eventually, in April 2013, recommended refusal of planning permission:

'It is considered that there is a qualified agricultural need for a grain store at this farm operation around South Allington. The proposed grain store solution will result in an isolated and modern industrial-type barn that will be extremely incongruous in the local precious AONB landscape to the detriment of this valley and the wider character of the area. More intensive use of the highway network, access and neighbour amenity are all at acceptable levels, but the farming need does not justify such an intrusive building in this area.  For this reason, the proposed agricultural building is considered harmful and contrary to the policies of the Development Plan.'


but the council's Development Management Committee voted almost unanimously to allow the development.

11. Warcombe
Warcombe from Watkins Wood

Background (SX733471)

Application 0678/08 for a temperature controlled potato store 42m x 24m x 10m was submitted in April 2008 but was refused on landscape grounds.

Application 1352/08 for a potato store 30m x 24m x 10m (A) was submitted in July 2008.  Officers considered that with realignment of the building, a reduction in its size and a planting scheme it was now acceptable.  It is difficult to see whether any planting has been done but if so it is clearly ineffective.

The applications for the store made no reference to any need for anybody to live at the site but in December 2011 approval was given (2732/11) for an agricultural dwelling (B).  This was justified on the grounds of the value of equipment and stock in the new store, and risk of equipment failure there.  No livestock are involved.

Foreground (SX734477)

Long Park Farm has about 80 acres of pasture.  The dwelling F was under an agricultural tie (0266/98) until it was removed by a certificate of lawfulness (1371/09) in 2009 on the grounds that the agricultural condition had not been complied with for ten years.  A certificate of lawfulness for the non-agricultural use of the farm buildings at E had already been issued in 2002 (2218/02), on the same grounds.

In July 2010 there was an agricultural notification for the building at D, measuring 13m x 9m x 5m.

In April 2012 application 2732/11 was submitted for an agricultural livestock building C measuring 23m x 9m x 5m.  The design and access statement said that the building would be 'well screened from any view, situated in rolling countryside where it fits into the local landscape and is not prominent from any elevation.'  This was not queried in the officer's report which stated that 'the development will be visually acceptable in the landscape and there will be no adverse impact on landscape character'.  The council's landscape officer apparently made no comment.

These cases illustrate the way in which agricultural buildings proliferate, even where other buildings have quite recently been taken out of agricultural use.  They also show how planning officers rely on their personal (but often mistaken) views on visual impact rather than on the wording of policies.

Postscript

Since the above was written another barn has appeared slightly beyond and above the one marked A in the photograph.


 

Appendix 1

Who wants to live in a National Park?


AONB's and National Parks together are chosen by government to represent the full gamut of our national landscape types. Although important to all of us as a tourist attraction they are increasingly under threat due to pressures from development including changing agricultural practices and energy generation.

In 1931 the South Devon coastline was identified as a potential National Park in the Addison report. By 1945 South Devon had lost its place on the National Park shortlist. The 1949 National Parks and Access to the Countryside Act laid a statutory framework for designating AONBs. The AONB designation program rolled out from the mid-1950s gave priority to the protection of the South West coastline.  South Devon was finally designated in 1960 and has just celebrated its jubilee.

The South Hams Society has been concerned for some time that insufficient care has been taken of our South Devon AONB. Both local planners and the AONB Unit have been targeted by members of the local community as failing to protect our unique landscape which is so treasured by visiting tourists. However, the real problem has more to do with the weakness in the legislative framework than the fault of those responsible for managing our landscape resource.  Our local AONB Unit is not even a statutory consultee on planning matters. This means that our local authority planners can take decisions without reference to the Unit and in any case are responsible for little more than a local view of planning proposals within the area of the AONB.

The government became aware that the protection of the these areas of national landscape importance was failing and a new act the Countryside and Rights of Way Act 2000  (CROW) was passed which gave local authorities permissive power to take action to conserve and enhance the natural beauty of the AONBs in their areas.  It requires that a management plan be produced and agreed by the local authorities. The duty falls to local authorities who must act jointly to produce a plan (in the case of the South Devon Area of Outstanding Natural Beauty, the relevant local authorities are South Hams District Council, Devon County Council, Torbay Council and Plymouth City Council.) Once adopted and published this management plan must be revised at intervals not exceeding five years. The CROW Act states that the purpose of the management plan is to formulate policies of local authorities for the management of the AONB and to carry out their functions in relation to it.

The planning system has been the fundamental mechanism for maintaining the special character of AONB. The role of the management plan is to help inform and guide the statutory planning process and identify the distinctive features which need special attention through the planning system and how to give 'great weight' to the conservation and enhancement of the natural beauty in their decision-making as is required by The National Planning Policy Framework. The five yearly review of our South Devon Management Plan begins this autumn.

Although there are moves by the government to make the AONBs statutory consultees this is merely a verbal ministerial recognition of the problem and is unlikely to improve AONB protection unless there is  concomitant provision of resources to the AONB Units to conduct planning surveys and monitor change.

I attended the recent 3 day meeting of the Association of Areas of Outstanding Natural Beauty as a member of the South Devon management committee and was struck by how many other Areas are up against damaging landscape developments but many of them find the pressures on the boundaries rather than directly within the AONB. This is partly because their nature as wildernesses does not place such an emphasis on the active living community. In our South Devon Area there is much more going on than just tourism.

AONBs and National Parks are defined as having equivalent landscape status in national terms. In Devon, our Dartmoor National Park is considered no more important scenically than the South Devon AONB but through its |National Park status it has been considered to be of greater recreational potential. Natural England is the body responsible for the designation of areas of landscape importance and they publish criteria against which to judge the category into which an area falls as well as how the boundary should be set. These criteria are presently being revised and will be published in about a months' time as Natural England's Designation Strategy.

We are fortunate to have, 97 kilometres of coastline of which 60 kilometres is in the hands of the National Trust. The South Coast Path along with our five estuaries provides great recreational potential for visitors with easy access from Plymouth and Torbay. While the primary purpose of both AONB and National Park designation is to conserve and enhance the natural beauty of the area, National Park designation also has a secondary purpose of promoting opportunities for recreation - the understanding and enjoyment of the special qualities of the area by the public. I suggest that the South Devon AONB is of at least equivalent recreational potential to Dartmoor.

AONBs and National Parks are also different in the way in which they are managed.  National Parks are managed by National Park Authorities (NPAs) which are local authorities in their own right and have forward planning, development control functions and other executive powers. The Park attracts national funding to reflect these responsibilities and takes away the local authority necessity to fund planning control within the park boundary. Recently the South Downs AONB and the New Forest AONB have become National Parks. This confers co-ordinated control on the designated area rather than relying on several local authorities to commit to participating when many other pressures distract their attention. By contrast, there are very limited statutory duties imposed on local authorities within an AONB.

Through this initial bulletin article the South Hams Society would like to test the community response approaching Natural England to begin the process of designating a South Devon National Park. It is an integral part of the new Localism Act to be able to make new decisions based on community views. In this process boundaries can be re-negotiated. The Natural Environment White Paper of 2011 based on the Lawton Report proposes connecting designated areas for wildlife migration routes. An extension to the existing boundary to link the Avon valley with Dartmoor National Park springs to mind as just such a wildlife route. I spoke to Sir John Lawton at the conference at York and he considered that the extension was just such a candidate to satisfy the concept of connected landscapes.

What about it folks?  Do we go for a South Devon National Park?  The parishes and towns that join us may be heard at last in the planning process!

John Peters

Appendix 1 References:
1.  Natural England Designations Strategy, July 2012

2.  Natural Choice, the Natural England White Paper, H M Government, June 2011

3. Biodiversity 2020: A strategy for England's wildlife and ecosystem services, DEFRA,     August 2011

4.    Marine Protected Areas, Marine Conservation Zones, Shoreline Management Plans

5.    Tourism statistics - to be obtained, compare with Dartmoor

6.    European Landscape Convention, Council of Europe March 2007

7.    National Character Area 151 South Devon, Natural England, 2012

8.    The bid for funds from the Catchment Restoration Fund under the Water Framework     Directive is supported by the SDAONB, the Aune Conservation Association, South West     Water, the Wild Trout Trust and the Environment Agency

9.    We need to identify wildlife links.

10. Quantify and illustrate by reference to letters in local press, etc.


 

Appendix 2

Applications to South Hams District Council for substantial development in the rural South Hams in the period Feb 2011 - Oct 2012


Below are listed some of the applications made in the 20 months from April 2011 to October 2012 for substantial developments in rural South Hams either within the AONB or close to its boundary. In none of them is it apparent to a member of the public that the AONB Unit was consulted under the planning protocol. The list excludes applications within development boundaries, replacement buildings, applications for renewal of approval, individual domestic buildings and applications for minor works. The status of the application is noted as registered, withdrawn, approved or refused. In some cases the size of the building is noted. 38 applications for agricultural buildings, 12 the subject of permitted development rights, dominate a total of 57 applications listed.

2011
0677, Ag bldg, 300 sq m, Ley Fm, Diptford, approved, 4th appln. in 3 years.
0740, Ag bldg, 625 sq m, Kerswell Fm, Diptford, approved.
0980, Ag bldg, 450 sq m, Borough Fm, E Prawle, last of 4, approved totaling 1800 sq m
0985, PV array, Broadmead, Diptford, approved.
1007, Redev, The Huts Thurlestone Sands, approved.
1099, Ag bldg, 243 sq m, Ley Fm, Modbury, approved.
1154, Ag bldg, 384 sq m, Penparks Fm, Modbury, det agreed.
1184, Amendments, Gerston Point, W Alvington, refused.
1298, Caravans, Hellier Field, Ashford, refused.
1317, Holiday Lodges, Buckland Park, Bantham, approved.
1322, Refurb garages, Higher Lannacombe Mill, Chivelstone, approved.
1334, Ag bldg, 208 sq m, Weston Fm, W Alvington, det agreed.
1507, Ag bldg, 377 sq m, Avonwick, det agreed.
1509, Ag bldg, 460 sq m, Court Park Fm, S Milton, det agreed.
1566, Ext of stables, Cuttwellcombe, Avonwick, approved.
1641, Ag bldg, 450 sq m, Colehanger Barn, E Allington, det agreed.
1642, Ag bldg, Higher Coltscombe Fm, Slapton, det not agreed.
1727, Ag bldg, 167 sq m, Combe Lane, Galmpton, det not agreed - landscape issues.
1790, PV array, Cotmore Fm, Chillington, approved.
1815, Ag bldg, 28 sq m, Houghton Cottage, Ringmore, det agreed.
1912, Amendments, Gerston Point, W Alvington, approved.
1985, PV array, Croft FM, W Charleton, approved.
2002, Ag bldg, 35 sq m, Redlap, Stoke Fleming, approved.
2004, Ag bldg, 600 sq m, Keynedon Barton, Sherford, approved.
2012, PV array, Springfield Barn, A Gifford, approved.
2019, Slurry Container, Higher Coltscombe Fm, approved.
2031, Ag bldg, Higher Torr, Yealmington, withdrawn.
2036, Ag bldg, 324 sq m, Firs Cross, E Allington, withdrawn.
2040, Ag bldg, 420 sq m, Wilburton Cross, Yealmpton, approved.
2071, Ag bldg, 432 sq m, Dundridge, Harberton, approved.
2120, PV array, Colleen Fm, Blackawton, approved.
2123, Stables, Stoke Cross, Noss Mayo, approved.
2190, PV array, Dart View, Aish, Stoke Gabriel, approved.
2195, Ag bldg, 188 sq m, Chillaton Cross, Loddiswell, det agreed.
2196, Ag bldg, 168 sq m, Cumery Fm, A Gifford, det agreed.
2200, Extn ag bldg, 292 sq m, Churchland Fm, Ivybridge, approved.
2245, Ag bldg, 442 sq m, Sandridge Hse, Stoke Gabriel, det agreed.
2351, Ag bldg, 536 sq m, Hazlewood Quarry, Loddiswell, refused.8152
2352, as above, refused.
2476, Ag bldg 441 sq m, Court Barton Farm, South Huish, approved
2598, 2600, 2601,  Solar panel ground arrays, Yealmpton, approved
2726, Ag bldg  150 sq m, South Huish Farm, South Huish, approved
2743, Aircraft hangar 525 sq m, East Soar, approved
2839, Ag bldg 455 sq m, Preston Cottages, West Alvington, det agreed
2915, Ag bldg 167 sq m, Muckwell Barns, Beeson, approved
2941, Ag bldg 150 sq m, Woolston Court, West Alvington, det refused
2951, Ag bldg  764 sq m, Higher House Farm, East Prawle, approved.
3087, Ag bldg  191 sq m, Salcombe, approved.

2012
0010, Ag bldg 206 sq m, Warcombe, Churchstow, approved.
0291, Ag bldg 221 sq m, Higher Hatch Farm, Loddiswell, approved.
0292, Ag bldg 582 sq m, Higher Hatch Farm, Loddiswell, approved.
0293, Ag bldg 220 sq m, Higher Hatch Farm, Loddiswell, approved.
0455, Ag bldg 540 sq m, Poole Farm, Holbeton, approved.
0520, Ag bldg 150 sq m, Woolston Court, West Alvington, approved.
0651  Extn to Golden Meadow. Widewell, approved.
0896, Farm dwelling & garaging, Scoble Farm, South Pool, registered.
0914, Ag bldg 750sq m, Warcombe, Churchstow, registered.
0959, Ag bldg 460 sq m?, Butland Farm, Modbury, registered.
1212,  Ag bldg 445 sq m, Burton Farm, Galmpton, registered.
1213,  Ag bldg 207 sq m, Folletts Farm, Curtisknowle, registered.
1313, Ag bldg 62 sq m Woodside Farm Loddiswell, det agreed
1314, Ag bldg, 188 sq m, Leigh Cross, Kingsbridge, det agreed
1345, Menage, 1800 sq m Poole Farm, Slapton, approved.
1352, 26 new dwellings, Wembury, no decision.
1383, Ag bldg, 540 sq m, S Allington, Chivelstone, no decision
1384, Ag bldg, 108 sq m, Langworthy House, withdrawn
1442, Barn to dwelling, Hingston Borough Farm, Averton Gifford, withdrawn
1621, Ag bldg, 171 sq m, Coombe Kingsbridge, det agreed
1646, Ag bldg, 536 sq m, Hazelwood Quarry, Loddiswell, no decision
1647, As above, no decision
1674, Change ag land to burial site, 0.6 ha, Ashprington, approved
1699, Ag bldg, 224 sq m, Torre View Farm Kingsbridge, det not agreed
1747, Ag bldg, 464 sq m, Winslade Farm, Frogmore, approved
1748, Ag bldg, 385 sq m, as above
1749, Ag bldg, 385 sq m, as above
1861, Ag bldg, 126 sq m, Mary Mills, Sorley Green, det agreed
1894, Ag bldgs, 405 sq m, Higher Leigh Farm, Kingsbridge, approved
1922, Ag bldg, 111 sq m, Bridgend, Newton Ferrers, approved
1932, Ag bldg, 252 sq m, Manor Bourne Road, Down Thomas, ag det not agreed
1957, 2 x 5 KW turbines,18m & 15m to hub, Chuka Cheese Farm, Bantham. not decided
1968, 2 x 0.9 MW turbines, Torr Quarry, East Allington, withdrawn
1990, 2 x 2.3 MW turbines, 98 m to tip, Luscombe Cross, Halwell, no decision
2106, 2 x 20 KW turbines, 18m & 15m to hub, Caulston Farm Noss Mayo, withdrawn
2128, Ag bldg, 322 sq m, Raddicombe, Brixham, approved
2255, Ag bldg, 276 sq m Didwell Farm, South Milton, det not agreed
2260, 5KW turbine, 18.75 m to hub, Little Chillaton Farm, Lodiswell, no decision
2286, Ag bldg, 444 sq m, Homefield Park Farm, Sherford, no decision
2295, Ag bldg, 288 sq m, Little Coombe Farm, Dittisham, no decision
2398, Ag bldg, 175 sq m, Fishley Farm, Modbury, no decision
2443, Ag bldg, 123 sq m, Langworthy House, Averton Gifford, no decision
2444, Ag bldg, 501 sq m, Caulston Farm, Noss Mayo, no decision
2496, Ag bldg, 456 sq m, South Down Farm, South Milton, no decision
2537, Ag bldg, 450 sq m, Bowden Farm, Sherford, no decision


Appendix 3

Natural England Exeter letter of 24 November 2010 to SHDC

 


  

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