This draft plan has recently undergone its public examination, and the Inspector's detailed recommendations are awaited.  CPRE Sussex made extensive written representations in advance of the examination hearings which led to a number of modifications to the examined plan.  We also spoke at the hearings to expand on our concerns re the proposed hydrocarbon policies in the Plan.

Our first main concern related to the potential adverse impact of the proposed allocation for soft sand extraction of a site at Ham Farm near Steyning on the very edge of the South Downs National Park.  In fact the Inspector has taken issue with the authorities' whole soft sand strategy, which relies heavily on being able to import it from elsewhere rather than maintain sufficient local reserves (as the National Planing Policy Framework basically requires all Local Planning Authorities to try to do).  Whilst the Inspector has asked the authorities to rethink their soft sand policy from scratch, we cannot assume that the Ham Farm site, however undesirable, will disappear from their revised Plan; indeed it is quite possible that other new soft sand sites will come forward for allocation as part of main modifications to the Plan, and those sites might be within the SDNPA.

Our other major issues related to the proposed hydrocarbons extraction policies.  On this aspect we teamed up with the Friends of the Earth (the FOE).  The Plan policies do draw a distinction in the authorities' approach as between the use of conventional extraction techniques on the one hand and hydraulic fracturing on the other (indeed recent legislation banning fracking within national parks and AONBs requires them to do so).  However the policies do not, in our and the FOE's opinion, offer adequate assurance that acidisation and other hazardous extraction techniques will not be allowed without requiring far stronger planning safeguards than are currently proposed - a point advocated by a barrister appointed by the FOE. 

CPRE Sussex argued at the hearing that the Plan needed expressly to require planners to take into account in their decision making process the Government's progressive move away from dependence on fossil fuels through tightening carbon budgets under the Climate Change Act 2008.  We find it extraordinary and disappointing that the minerals plan makes no mention at all of that Act and the responsibilities of planning authorities to lead in progressive decisions that will facilitate the Government's ability to honour its domestic and international commitments to reduce CO2 and other harmful emissions.

CPRE Sussex's last point at the hearings - which we were asked to make on behalf the South Downs Society as well - was that development on the fringes of the National Park and AONBs that would harm the purposes for which the areas have been designated should receive the same degree of protection within the Plan policies as a development within the Park/AONB itself.

We await the Inspector's recommendations shortly.