By Laura Brook, Conservation Officer
As we head in to the second week of COP26, we’re also entering week two of the Examinations in Public for the Worthing and Brighton Local Plans. This is where the discussions are happening that will shape development in these areas for the next 15 years.
The constraints are real for Worthing and Brighton, sandwiched between the sea to the south and the South Downs to the north. On top of this, some parts of Brighton and Worthing fall within the South Downs National Park (SDNP) and are covered by a separate SDNP Local Plan process, which further restricts the area of developable land. Despite this, environmental factors have zero influence over the number of houses Local Planning Authorities (LPAs) are expected to deliver. These housing numbers are generated by central government and it might surprise you to know that they are based purely on social and economic factors (the Objectively Assessed Housing Need (OAHN)). The numbers generated are often so astronomical that Local Authorities have no hope of meeting them.
There is no attempt by the government to consider environment capacity in those initial OAHN calculations, so an area’s ability to provide sufficient water, air quality, green space for people and nature - including the vital space needed to adapt to a changing coastline - is not factored into the OAHN calculation. This puts nature on the back foot right from the start. LPAs are expected to provide evidence to show what proportion of the initial OAHN number can be delivered in their area, and this is no small ask. Local Authorities often have limited or no in-house ecological expertise and a limited budget to buy this in, with requirements for transport, employment and social needs all requiring a share of the same pot.
When Local Authorities do put forward the housing numbers that they feel could be achieved in their area, they’re often significantly under the OAHN calculation and this leaves an ‘unmet need.’ In Worthing, which is significantly constrained, that unmet need is itself significant and therefore every decision made, and every local green space, can find itself vulnerable. In Brighton the housing number means we’re seeing Local Nature Reserves and Local Wildlife Sites being put forward for potential development. This is not the route to a sustainable future.
As a conservation officer, I feel it’s vitally important that we understand this: just because an area of land isn’t built on, doesn’t mean it is not delivering a valuable service for us and providing the infrastructure we need to live a sustainable future. It could be an uncapped surface able to absorb water and reduce impacts on our struggling sewerage system; it could be a stepping stone for wildlife that will ensure species don’t become isolated by climate change; it could be an area where we restore nature and improve air quality; or it could be a place to access nature sustainably without the need for a car, encouraging a positive behaviour change. We’re not at a point in this ecological and climate crisis where we can only care about a piece of land if it is protected by a formal designation, although sadly even these sites are struggling in the face of incredible pressures. Therefore, Sussex Wildlife Trust recognises the importance of participating in the process of strategic planning, from consultations through to the examination hearings, to ensure that biodiversity is key to those discussions.
Last week the Examination hearing in Worthing looked at broad spatial elements and has mainly focused on the Green Gaps / Local Green Spaces and related policies. This week we head into the detail of the proposed allocations, and we will be scrutinising how the allocations have considered the safeguarding of Local Wildlife Sites and Priority Habitats. For Brighton, the discussions to date have centred on the designation of Local Green Spaces and the wording of the biodiversity policy, with a focus this week on the allocations and the urban fringe sites, and we are again trying our best to argue for the integrity of locally designated sites. Next week the examinations will enter their third and final week, and while it’s not SWT’s place to second guess the way these Local Plans will go, we hope our input may influence the inspectors’ recommendations as to how these plans progress.
So, while COP 26 continues and the positive words keep tumbling out of leaders’ mouths, let’s not forget that real action cannot come quickly enough for our natural environment. Decisions are being made right here and now that will influence our local green spaces, air, water and all that depend on them for many of the critical years to come, and we all have a part to play in making sure decision-makers know just how important they are to us.