| The AONB Management Plan
is a statutory requirement, involving the relevant County and District
Councils, Natural England, Environment
Agency, and many others. It is, the official guidance makes clear,
meant to be “much more than a guide for the activities of an
AONB staff unit” (page 17). The strategy element should be “an
ambitious visionary statement” (page 6). The policies of the
relevant local authorities “need not be confined to those aspects
they can deliver themselves” (page 75). “Some policies
may need to extend beyond the AONB boundary” (page 22). And
so on.
The draft Dedham Vale
AONB etc. Management Plan (“the draft
Plan”) does aim to provide both the visionary strategy for
the AONB to 2025 and the action plan for the AONB staff unit to
2014. While the Dedham Vale Society (DVS) accepts that the draft
plan does aim to provide both a visionary strategy for the AONB
to 2025 and an action plan to 2014. DVS considers that the strategy
lacks specifics, particularly in relation to the AONB, and the
action plan is almost entirely restricted to the activities of
the project staff unit. DVS has the following suggestions for sharpening
the plan:
- The Traffic & Transport
Theme Vision for 2025 should be much more specific, as at the
1st attachment.
This applies
just to the AONB: it would need to be adapted to apply to the
rest of the Project area.
- Climate
change merits more explicit discussion, as at the 2nd
attachment.
- Preventing
mass tourism “killing the thing it loves” needs
more consideration.
- Consideration
should be given to establishing the concept of “Gainsborough’s Country”. It is a myth that
all Gainsborough’s landscapes, unlike Constable’s,
were imaginary. Some known counter-examples in the Project area
are at Bulmer (Mr & Mrs Andrews), Abbas Hall (Cornard Wood),
Lamarsh and Clare. Others might well emerge with research. Working
with the one serious art-historical resource in the area, Gainsborough’s
House, could help develop a useful counter-magnet to Dedham/Flatford.
- The Plan
should be reviewed in light of the just-published Pretty Report
(the Essex Rural Commission).
The conclusion may
well be that its recommendations are not all appropriate for
the AONB – eg DVS strongly disagrees with its views on
rural affordable housing – see our 2nd
attachment, point
3 – but it needs careful consideration, and in many instances
adds weight to the AONB Plan.
- All public
bodies and statutory undertakers operating in the AONB should
be invited to spell out how they are fulfilling their
statutory objectives under the Countryside and Rights of Way
Act 2000, section 85 . See points 6 and 7 below.
- Provision
should be made for working with other AONB staff units on common
issues (such as traffic calming, sat navs,
CRoW 2000 s85)
- Constable
Country is too narrowly defined, excluding for example Stoke
by Nayland and Stratford St Mary, both sites
of major pictures
by the artist (Theme 1, 1.12.3.3. last para and again at
1.14.1 third para)
- On Utility
infrastructure: the Plan should aim not merely for the removal
of redundant infrastructure (Action 15.2),
but also for continuing infrastructure eg mobile phone
aerials to
be hidden.
- On Undergrounding
(low-voltage electricity and telephones): the Plan should not
merely plead for undergrounding (Action
14.3) but identify and prioritise all the undergrounding
needed in
AONB. It should flag up need to underground in villages
(outside OFGEM scheme). It should aim to research, with
others, why
undergrounding seemingly costs so much less in other
countries eg France.
- On Bio-diversity:
with landowners, the Plan should aim to create “green
infrastructure” links
between river/woods/parks/golf course.
- Concern
has been expressed to us that the DVS Project should seek to
protect the farmers' ESA. Apparently
if the farmers
lose this status they will plough the grasslands
of the Vale and plant
wheat. We ask that this be looked into, and suitable
action included in the Plan.
The 3rd
attachment notes some detailed points.
1 Countryside
Agency’s
Guide to AONB Management Plans, available at http://naturalengland.etraderstores.com/NaturalEnglandShop/product.aspx?ProductID=0d1fc619-dede-4f5d-907c-970f3e223df0
2 This provides that In exercising or performing any functions in relation
to,
or so as to affect, land in an AONB, [all public bodies and statutory undertakers]
shall have regard to the purpose of conserving and enhancing the natural beauty
of the AONB
Attachments
relating to the above
1st attachment: Suggested
2025 vision for Traffic & Transport
- 40 mph limit on B1029, B1068 and B1087 outside villages
- 40 mph
limit on other secondary roads (“brown roads” on
1 : 25,000 scale Ordnance Survey (OS) maps) outside villages
- Self-enforcing
20 mph speed limits on all minor roads (“yellow
roads” on 1 : 25,000 scale OS maps) and in all villages. “Self
enforcing” measures (eg raised platforms, sharp bends)
to have no adverse effects on amenity (other than vehicle drivers’).
- Roads as
at 3, excluding B1029 through Dedham and B1068 & B1087
through Stoke, Thorington Street & Higham to be “shared
space”, ie where motor vehicles accommodate to pedestrians,
cyclists, horses etc. (as well as to motor vehicles).
- Where current footpaths end on roads with speed limit above
20 mph, links to be provided that connect to other pedestrian-friendly
routes
- Cycle-friendly routes for all journeys between villages
- Pedestrian-friendly routes for all journeys within villages
- Juggernauts
confined to A12 and A134 except for necessary access. “Necessary
access” to be controlled, and activities requiring juggernaut
access to be relocated as and when practicable (ie excluding
farms). “Juggernaut” definition
to start high, eg four or more axles including trailer, and come
down over time.
It
is recognised that the DV AONB & SV Project cannot bring
these things about on its own. But it can help bring them about,
by eg
- Publicly endorsing and publicising the objectives
- Lobbying for those within the gift of the Highways Authorities/police
at negligible cash outlay (1 and 2)
- Monitoring and publicising their attainment (eg which
yellow roads are effectively shared space with self-enforcing
20
mph limits?
Which footpaths end on pedestrian-hostile roads? What
proportion of juggernauts is not for necessary access?)
- Advising Parish Councils on suitable traffic-calming
measures
- Locating non-standard funding sources for traffic-calming
measures
- Analysing, critically, the demands for juggernaut
access
- Helping design and negotiate new walking and
cycle routes
- Sponsoring walking and cycling maps that take
account of permissive paths and suitable
yellow roads (ie
unlike OS
maps).
- Working with other AONBs, and National Parks,
on common concerns. For example, the Dartmoor
National
Park is
permitted to sign
speed limits by signs on the road surface
only, with no obtrusive road
side signs.
Anyway,
the AONB Management Plan is meant to be “much more
than a guide for the activities of an AONB staff unit” (see
opening paragraph of main text).
2nd attachment: Suggested
2025 vision for Climate change We consider
the need to address this has radical, and generally positive,
implications for the AONB. Its implications
merit being
dealt with much more explicitly than in the draft Plan – see
2 and 3 below. But we do not agree that it should become the dominant
criterion – see 1 below.
- Transition
Town status for the AONB (Action A13.2). We consider it wrong
for a body concerned with amenity
to adopt non-amenity
objectives. Climate change is important, but it is not what the
AONB is for. Obviously AONB management must comply with government
and legal obligations in the climate change area as all others.
Often climate change considerations point in the same direction
as amenity considerations – see 2 and 3 below. But none
of this justifies a body concerned with amenity in adopting non-amenity
objectives. We know, after all, that not all climate change initiatives
are consistent with the AONB. One example is large-scale windpower.
Commercial-scale bio-mass farming for generation of electricity
or liquid fuels would probably be another.
- Spatial
planning: The AONB Plan should emphasise that the crucial carbon
footprint objective for spatial planning
is locating
development of every kind, industrial, commercial, public sector
and residential, so as to minimise transport mileage. In northeast
Essex and southeast Suffolk, this means that all significant
development should be located in Colchester or Ipswich, at Felixstowe
or Harwich, by an A12 or A14 junction or alongside the Great
Eastern mainline. That is, on carbon footprint grounds alone,
no development which is capable of taking place elsewhere should
take place within the AONB. NB the “climate change”, “sustainability”, “carbon
footprint” agenda is required to be central to Planning
Authorities’ Local Development Frameworks.
- Housing:
The AONB Plan should emphasise that significant additional
housing is incompatible with preserving
the character of the
AONB, and incompatible with climate change objectives as at 2
above. However desirable it may be to provide affordable housing
in rural areas for people working there, there are insuperable
legal/financial/institutional obstacles to (a) ensuring such
housing remains affordable; (b) ensuring such housing remains
occupied by people with a local connection. In particular, Rural
exceptions sites for “Affordable Housing”, ie sites
outside village envelopes, have no place in an AONB.
3rd
attachment: points of detail
- “affects” for “effects”,
1.12.3.5 second para
- “negative effect and careful consideration is required
when them.” 1.13.3.3 last para
- “There are issues of commuter It is recognized” “…not
usually in itself a problem but the problems caused by congestion…” (both
1.16.3.4)
- The Vision
Statement uses the expression “working landscape” without
really defining what “working” means.
- The maps are largely unreadable.
- “In 2025 the people of the Dedham Vale AONB and Stour
Valley community understand the importance of the area that they
live in” (Theme 2, 1.13.2 first para). Do they not now?
- “In general, the design and location of new buildings
has taken into account the character of the area.” This
use of the phrase “in general” in a vision statement
is alarming. It accepts that not all buildings will when surely
the vision ought to be that all will. (Theme 2, 1.13.2 last para).
- “Many of the villages in the area are accessible by
bus although services have a restrictive timetable” (Theme
5, 1.16.1. fourth para). Should “restrictive” be “restricted”?
- The list of abbreviations on pages 90 and 91 should be at
the start not end of the Delivery Plan to act more helpfully
as a guide to the perplexed.
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