2.1 There are 8 main issues on which the Agency is seeking comments :1. Membership of the National Park Authority (NPA) :

number of members, skills of members, parish representation.2. Land use planning :

responsibility for forward planning and development control3. Land Management :

4. Visitor Management :

5. National Park Management Plan :

6. Partnership Working :forming strategic partnerships, representation on SEERA 7. Involving Local People :

working closely with local people and LSPs8. Boundary Proposals :

2.2 Additional areas which have been identified for comment either through District Council meetings or by respondents are :

- finance

- setting up the Shadow Park Authority

3.1 There are three main areas for comment under this issue :

ii) How the parish council representatives should be chosen.

iii) Ensuring that Board members provide a range of skills and expertise.

i) An effective and modern decision making body

3.2 The current formula would result in a Board of 46 members :

- 3 members per county or unitary council 12

- 1 member per/ district council 12

- town and parish councils 10

- Government appointees 12

__

Total 46

3.3 However, the Countryside Agency received comments at the initial consultation stage that a Board of this size would be an unwieldy and inefficient decision making body and that the size of the NPA should be reduced. The Countryside Agency is therefore proposing to advise the Secretary of State that she should discuss with the local authorities ways to reduce their overall numbers on the NPA (page 36). A previous Agency report mentioned the possibility of the smaller local authorities sharing a representative. An alternative is for the county councils to reduce their representation.

3.4 The Agency has confirmed that any reduction on the local authority side would be matched by a reduction in parish council representatives and the number of government appointees. The current formula, which gives local authorities the majority of the seats (50% + 1), would be retained.

3.5 Members have already expressed concern that EHDC would have only 1 Board Member to represent half of the district area. Respondents to the Council (i.e., the Local Advisory Group, the Joint Panel meeting, and Central, South and North East Area Community Committees) have all rejected the idea of reducing the size of the Board because of the need to retain the maximum number of area representatives and ensure the greatest range of skills are provided by Members. All consider that more modern means of decision making can be achieved (e.g., Cabinet style) without the need to reduce the overall size of the Board. A smaller Board was considered to be a detrimental step as it would also result in fewer parish council and specialist representatives. Members? comments on the size of the Board and the number of representatives per District are welcomed.

ii) Selecting Parish and Town Council representatives

3.6 The parish and town council representatives are appointed by the Secretary of State. The Countryside Agency is seeking views on how the representatives should be selected from about 180 parish councils included within the proposed Park boundary. One suggestion is that the county associations should hold county level elections.

3.7 The view expressed by respondents to the Council is that the representatives should be selected by election and not nomination by the county associations. It is not clear how the elections would be held - this would be for the town and parish councils to agree in conjunction with the county associations.

3.8 The Countryside Agency is proposing to recommend to the Secretary of State that all Board members should bring a variety of skills to the Board which are relevant to the South Downs as well as representing their area / interest group. These could include some of the following :

3.9 This suggestion was supported by respondents to the Council and the following requirements were suggested :

i) representatives should ideally live or work within the Park area

ii) businesses and landowners should be represented on the Board

3.10 The Agency is also proposing that all Board members should sign a code of conduct and take part in ongoing training. This was supported by respondents to the Council. However, comments were made (in relation to recent problems with the parish councillors code of conduct) that this should not be used to prevent people from coming forward for election / selection.

iii) the impact on planning in split districts had not been fully realised.

4.5 Members comments on the Agency?s new proposals, in particular how the District Council, residents and businesses should be involved in the development of planning policy for the Park area, would be welcomed. Comments on who should prepare and adopt supplementary planning guidance documents, such as development briefs, design guides and village design statements are also welcomed.

4.6 The Countryside Agency?s proposed advice to Government on development control is that :

"a South Downs National Park Authority (SDNPA) should be responsible for development control .... However, ministerial advice ought to encourage a SDNPA to work with the existing local authorities to determine the most effective means of handling and determining the casework".

Unfortunately, it is not clear what sort of arrangements for "effective means of handling and determining the casework" the Agency has in mind.

4.7 It is suggested that the main issues to be covered in the Council?s response are :

i) who should have overall responsibility for development control?

iii) what should be included in the scheme of delegation?

iv) where will the service be operated from?

v) how can local people be involved in the process?

vi) who will provide the specialist services?

vii) what resources will be needed to provide a planning control service for the Park?

4.8 The 1995 Environment Act gives NPAs the responsibility for development control within National Parks. This means that the NPA is the ultimate decision making body. However, it does not mean that the NPA has to undertake the whole development control service.

4.9 Some respondents to the last consultation on the National Park wrote strongly in favour of the NPA making all of the development control decisions. This was seen to provide consistent decision making which could be relied upon to achieve decisions which have be in the best interests of the Park.

4.10 The Countryside Agency has recognised the implications for the NPA if it should choose to run the development control service alone. To provide the service over such a wide area with a population of approximately 100,000 people, a large number of businesses and about 3,000 planning applications per year, would be very resource intensive. It would not necessarily be the best use of the Board?s resources to deal with the great majority of planning applications. In the main, these applications do not impinge on the prime purposes of the Park, i.e. conservation and recreation.

4.11 A sensible alternative would be for the NPA to delegate the great majority of the casework to the local authorities, through an agreed scheme of delegation. Ideally the local authorities would deal with the casework and consider all applications, setting out any detailed conditions or the reasons for refusal. The NPA would be able to have applications which would have a significant impact on the Park referred to it for decision. This scheme would allow local councillors to take the majority of decisions locally and have an influence on decison-making negotiations on developers? contributions for the significant applications.

4.12 Respondents to the Council were all in favour of such a scheme, which offers maximum delegation to the local authorities, decision making being taken in the local area, and local authorities dealing with the conditions / reasons for refusal for all applications.

4.13 The experience of the Broads Authority shows that it is important to have a detailed scheme of delegation and a Service Level Agreement. NAPLAMOG (the South Downs National Park Local Authorities? Members and Officers Group) is working on draft delegation schemes for discussion this Autumn. It is suggested that the principles of the schemes should include the following :

c) Local authority planning committees should determine all planning applications which are not being determined by the NPA and which do not meet the criteria for delegation to officers.

4.14 A scheme of delegation will require close working between the NPA and the local authorities to ensure that the purposes of National Park designation are achieved. Some practical issues could be overcome if the following procedures are adopted :

- led by the development plan (or its replacement)

- unbiased and even handed in its dealings with applicants and objectors.

ii) There should be an unobstructed interchange of all relevant planning information between the local authorities and the NPA to enable the NPA to monitor and review the development control service provided by the local authorities.

iv) Existing local authority development control facilities (e.g., IT hardware, databases, premises, staff, planning committees etc.) should be used as much as possible. This will help maintain current levels of performance and avoid the NPA incurring additional costs by setting up and running a separate development control system.

v) The NPA should agree how expert advice (e.g., heritage, transport, environmental health) is obtained and funded when dealing with all aspects of a planning proposal (i.e., pre-application advice, planning applications, amendments, appeals, enforcement).

vi) County councils should continue to provide the development control service for minerals and waste applications unless the NPA is able to justify the need for and expense of running its own minerals and waste team.

4.15 A major concern of councillors and local people is where will planning decision making take place - at a central Park headquarters, or at Area offices, or at district council offices? If the NPA deals with all planning applications, it will be essential for decisions to be taken as close to the local area as possible. This will enable local people to attend and make their views known. The local authorities? proposal to have most of the applications delegated to them for decision would mean that meetings will automatically be held locally.

4.16 Respondents to the Council supported meetings being held in the local area. They also supported the Countryside Agency?s proposal to let local councillors and local people attend and speak at NPA planning meetings concerning applications in their area.

4.17 East Hampshire District Council is unusual amongst the NAPLAMOG authorities in the considerable amount of local councillor and public involvement in the planning control process. There is wide publicity for all applications received, with immediate neighbours being personally notified. All EHDC councillors sit on one of the two Area Planning Committees, which are open to the public. Some public speaking is allowed on contentious items (i.e., Section I items). This is not the case in all councils. The comment from the Local Advisory Group, Joint Panels meeting, and the Area Community Committees is that they would want this close local involvement to be continued in the Park.

vi) Who will provide the specialist services for the development control service?

4.18 Development control is not just dealing with planning applications. It also involves other disciplines to give advice on planning applications, such as conservation (historic buildings and conservation areas), arboriculture and landscaping, enforcement, highways design advice. Ideally, these services should be provided by the authority carrying out the development control function, as they will know the local area best.

4.19 A case could be made for the NPA to provide the specialist ?heritage? advice services if these can be resourced at a better level than the local authorities currently provide it. However, enforcement should not be separated from the decision making function.

4.20 Work undertaken by NAPLAMOG suggests that it could cost up to £2.5 million for the NPA to run a full planning service, of which the development control service is likely to be the major amount of this total cost. The local authorities have yet to investigate how much it would cost to run the development control service in the remainder of their areas. It is likely that, when taken together, the National Park and local authority costs would be greater than the current local authorities? budgets for development control, especially if the specialist support services are taken into account.

6.1 Together with land management, this was seen by the Council?s consultees as a major area for action by the NPA and where much of the funding should be directed. The main proposals put forward by the Countryside Agency are set out below, together with a summary of the responses received by the Council.i) Countryside Management :

6.2 The Agency is proposing that the NPA should run its own comprehensive countryside management service, co-ordinating and adding value to existing services. This has received unanimous support, provided the NPA does bring "added value".ii) Site Management :

6.3 The Agency proposes that the NPA should play a strategic role in site management, setting high standards for publicly owned land. Where there is a demonstrable benefit, the NPA could take on land. This proposal was also supported by the Council?s consultees. The NPA could also encourage high standards in site management by other owners and operators. Land ownership should not be a prime objective for the NPA as it is could be resource intensive to maintain. iii) Access and Rights of Way :

6.4 Public access to the South Downs National Park is a major priority for the NPA. The Agency is proposing that the NPA should prepare, in conjunction with a Local Access Forum, a comprehensive access strategy for the Park which covers access to open country, rights of way, management and maintenance standards.

6.5 The public rights of way network will be the main means of accessing the National Park for pedestrians, cyclists and riders. The Agency is proposing that local highway authorities should be asked to delegate their rights of way powers in the park area to the NPA so that it can integrate rights of way with its other statutory access responsibilities. As with development control, the NPA and the local highway authorities should agree the most efficient way of providing the rights of way service in the Park.

6.6 This proposal had full support from the Council?s respondents, who felt that the full rights of way service (including legal work) should be delegated to the NPA. Again, respondents considered that the access and rights of way service of the NPA needed sufficient funding to show that National Park status adds value, rather than just replicating the current level of service provided by the local authorities. A similar standard of high maintenance and signing should be provided throughout the Park area . There should be no difference as local authority boundaries are crossed.iv) Transport :

6.7 The Agency proposes that the NPA should take the lead in preparing a park-wide traffic strategy, working with the local highway authorities. The strategy would be used to inform transport policies in general and the content of county local transport plans in particular. The Local Transport Plans should include a specific section on the National Park, identifying the resources and work programme needed to implement the policies. The Agency is also proposing that the NPA should be responsible for implementing parts of the transport strategy for the Park.

6.8 Respondents generally supported these proposals but there was some concern that too much emphasis on transport could divert badly needed funds from other important aspects of the NPA?s work. The main emphasis should be on schemes to manage visitor access. It will be important to ensure that local authorities and local people are also able to have an input to the Transport Strategy.v) Tourism :

6.9 The proposal here is for the NPA to prepare and promote a joint sustainable tourism strategy with the relevant tourist authorities. This was supported by respondents. Views were expressed by some people that although the Agency does not consider that the Park will attract large numbers of additional visitors, in reality there would be more. A strategy for tourism and visitor management is therefore essential. Local authorities and local people should be able to have an influence on the content of the strategy. vi) Education and interpretation :

6.10 Another key aspect of the work of the NPA is to promote better pubic understanding of the Park and what makes it so special. The Agency is proposing that the NPA should develop and co-ordinate an interpretative strategy for the Park, including publicly owned land and other important sites. It is also proposed that the NPA should develop an outreach programme for communities within and outside the Park.

6.11 There was general support for the NPA preparing and co-ordinating an interpretative strategy for the Park as this will aid local and visitor understanding of the special qualities of the South Downs, hangers and heaths. Local authorities and local people should be involved in its preparation. It was unclear to respondents what the outreach programme might entail.

7.1 The Management Plan is the principal working document for the NPA, setting out its role in preparing, co-ordinating and implementing policies and programmes for protecting and conserving the Park area, promoting outdoor recreation and meeting National Park purposes. The Agency is proposing that the Secretary of State should clarify the role and status of National Park Management Plans and the need for other bodies to take account of national park purposes in their plans and activities. Progress should be reviewed against targets and the results published annually.

7.2 Respondents to the Council supported the need for the National Park Management Plan. The Council will have to show in its future strategies and plans how it will be working to help achieve National Park purposes. It is, therefore, very important that the local authorities and local people are closely involved in drawing up and reviewing the Management Plan.

8.1 The Agency recognises that if the NPA is to be successful in achieving National Park purposes, it must work closely in partnership with other organisations. It must also achieve a place on the relevant committees of other bodies, in particular SEERA.

8.2 These proposals were supported by respondents to the Council. As the National Park will cover about 50% of East Hampshire District, the NPA should be invited to join the East Hampshire Strategic Partnership. This would provide a ready forum in which the NPA could work closely at a strategic level with local communities and other service providers to help meet the social, economic and environmental needs of the Park area within East Hampshire.

9.1 In this Section the Countryside Agency recognises the importance of involving local people in its plans and activities. It suggests that the NPA should draw on the aspirations of community strategies in its work. This proposal was supported by respondents to the Council. Without local support and involvement the NPA will not be able to achieve the maximum potential for protecting the National Park area and achieving National Park purposes. Hence the comments in the sections above for the need to involve local authorities and local people in the preparation and review of strategies and plans for the Park.

10.1 Many of the respondents on the proposal to establish a South Downs National Park have called for the Park to add value to the work of existing bodies and not just to replicate them. The prime responsibilities of the NPA, conservation and outdoor recreation, will require considerable new resources. Some work has been done in estimating the resources needed to run the Park and achieve a future National Park Management Plan, but much more needs to be done.

10.2 The Wildlife Trusts have estimated that about £22 million will be required each year to fund nature conservation work, including downland restoration. This would be in addition to running a countryside management service and a rights of way service, let alone any measures to introduce sustainable transport and tourism services.

10.3 NAPLAMOG has estimated that it will cost about £2.5 million per year to run a full planning service in the Park. Work needs to be done by the local authorities to estimate what resources will be needed to run the planning service in the remaining parts of the districts / counties outside the Park as it will not be a straight forward split of existing resources between the NPA and the local authorities.

10.4 The Countryside Agency and Sussex Downs Conservation Board have estimated the National Park budget is likely to be in the region of £6m per annum. Although the costs will be met in full by the Government (either directly or by repaying the local authorities), it is vital that the correct level of funding is provided so that the NPA can achieve its strategies and plans.

10.5 Greater clarification is needed about the extra resources which National Park status will bring. For instance, it is not clear whether the Park will have to make use of existing national grant schemes and project funds to finance its work or whether there will be significant new direct funding from Government for the NPA?s work.

11.1 It is clear from the work carried out by NAPLAMOG to date that DEFRA needs to start soon on setting up a shadow NPA so that it can run for at least a year before the National Park comes into being. This will enable the shadow NPA, local authorities, local people and other organisations to establish the framework for running the National Park and agreeing how it will work with the community. It would enable the NPA and the local authorities to test schemes of delegation and refine them. It could also enable the shadow NPA to begin to draw up its own Management Plan and begin to influence key strategic bodies, such as SEERA and SEEDA.

11.2 The District Council?s Members? Steering Group on the South Downs will be looking at this over the next few months in order to influence NAPLAMOG, the Countryside Agency and DEFRA.

12.1 Part of the NPA?s remit is to help secure the economic and social well-being of the Park area. If the NPA has a seat on all the Local Strategic Partnerships in the Park area and on SEERA and SEEDA, it will help better understanding of the needs of people and businesses in the Park. It will also have an influence on the future strategies and plans of local and strategic bodies.

12.2 Two areas need particular consideration at this stage : the impact of National Park designation on the provision of affordable housing and the future expansion of local businesses. Concerns have been expressed about the likely increase in land and house prices in the Park area once the National Park is designated. This could impact on housing needs and the provision of affordable and key worker housing, both in the Park and in the area just outside it. The issues are well expressed in the letter from the Chairman of Drum Housing Association (see Appendix 5) and should be drawn to the attention of the Countryside Agency.

12.3 Looking to the future, communities within the Park will continue to require additional housing in order to meet local needs - not just for affordable housing but also for market sale / rent accommodation. Although the planning policies within a National Park will be the same as those in an AONB, public perception is that there will be less new building in a National Park. The Agency has been careful to stress that there will be new development in the National Park but they have not indicated the likely scale of development required.

12.4 The South Downs National Park will have a population of about 100,000 people - far larger than any existing National Park. The amount of development needed to meet local needs will therefore be much greater than that experienced in other Parks.

12.5 Local businesses have mixed views about the impact of the Park. Those in tourism and leisure welcoming it, but those with expansion plans being less certain. NAPLAMOG is beginning to find out more about the economy of the Park area and a start is being made on drawing together existing information about what enterprises are currently located in the Park. Further work will be needed to find out what contribution they make to the local and regional economy, and what their expansion needs are.

12.6 The Countryside Agency has said that National Park status will not stop further appropriate development from occurring in the Park. However, it is not clear what scale and type of development is thought to be ?appropriate?. Some national and international companies are currently based within the Park area; if they are unable to expand they may move away not only from the local area but from the South East Region.

a) Changes Made to the Proposed Park Boundary 13.1 The Countryside Agency has taken into account many of the suggestions made at the initial consultation stage in February, 2002. The main changes in East Hampshire are :i) Areas now to be included in the proposed Park :

- Lower Farringdon

- the land between Four Marks, Chawton and Lower Farringdon

- a small area of land off Portsmouth Road, Liphook / Wheatsheaf Enclosure - additional land at Blendworth.ii) Areas now to be excluded from the proposed Park :

- Land near Wolfhanger Farm, West Tisted

- land at Dogford Wood, East Tisted

- Greatham village.

If Council agrees with these changes it will be important to support them, as well as the continued inclusion of Liss and Petersfield and that part of the A3 corridor.

13.2 The proposed boundary takes some account of the suggestions made by the District Council during the informal public consultation stage. However, the Agency did not take all of the Council?s suggestions into account. The proposed boundary still does not include :

- Woolmer Forest

- Rowlands Castle

- land by the Oakhanger Stream

- land to the west of Blackmoor.

13.3 The Agency has taken account of the Council?s previous comment not to split settlements. As a result, Lower Farringdon and Blendworth are both now within the Park boundary whilst, unfortunately, Greatham is proposed to be excluded from the Park.

13.4 The Agency sets out its arguments for a National Park covering a wider area than the "chalk ridge" (see page 40 of the consultation document). The reasons for including or excluding major towns and settlements is covered on page 41 of the document.

b) Detailed boundary issues raised by the Area Community Committees, Parish Councils and Local Amenity Groups

13.5 The comments of the Area Community Committees on the proposed boundary are set out in Appendix 2, whilst those of the town and parish councils, amenity societies and individuals are set out in Appendix 5. The comments of North West Area Community Committee will be reported verbally at the Council meeting. Wherever possible, maps of the proposed areas for inclusion in the Park have been included with the Appendices.

13.6 The main areas of concern are :

i) Central Area : the exclusion of Greatham and Woolmer Forest

ii) South Area : the exclusion of Catherington and Rowlands Castle

iii) North East Area : Woolmer Forest, Headley.

13.7 There are some minor boundary anomalies which are being investigated by the Principal Landscape Officer; his comments will be reported to the Council meeting. The areas include small areas of land at Newton Common Farm, Newton Valence and at Finchdean.

13.8 The Countryside Agency has stressed that any areas to be included in the Park must meet the national criteria for designation, as set out in Appendix 7. Council needs to keep these criteria in mind when making its recommendations to the Agency for additional land to be included in the Park.

13.9 The Agency has already indicated that it is willing to reconsider Woolmer Forest and Rowlands Castle if further supporting information can be provided. Where the Agency has already rejected areas and outlined the reasons why in the consultation document, then further information will be needed to refute these reasons.

13.10 The Principal Landscape Officer is assessing all of the areas proposed against the Countryside Agency?s designation criteria. He will give advice at the Council meeting about whether the additional areas which Councillors and local people want to have included in the Park will meet the Agency?s criteria.

c) De-designation of the AONB13.11 The Agency?s proposed de-designation of the East Hampshire AONB is a separate exercise which will be undertaken in August and September, 2002 (see page 111 of the consultation document and the Agency?s covering letter). This has particular implications for small areas of land in East Hampshire which are currently in the AONB but which are not proposed to be included in the National Park.

13.12 The Agency is intending to make the De-designation Order at its meeting in November. However, the Agency has given an assurance that de-designation would only occur if and when the National Park comes into being.

13.13 Members may wish to comment on this proposal as there is only a short period for response to the de-designation consultation. The Council?s formal response will be probably have to be agreed at the Cabinet meeting on 4th September, 2002. The areas of land potentially affected by de-designation are shown in the maps set out in Appendix 8. They include land at Clanfield, Finchdean, East Tisted, Greatham, West Tisted and Newton Valence.