Where it all began: Helen's Open Letter to BHCC regarding the inclusion of Benfield Valley on CPP2
Updated: Jan 10, 2022
Dear Caroline Lucas MP, Peter Kyle MP and the Members of the Brighton and Hove Planning Committee
RE: The planned development of Benfield Valley as stated in the CPP2 Proposals
As I begin this letter, it is 4.27am on a Tuesday morning and I cannot sleep. I have been wanting to write this email to you for weeks but have not been able to find the words, so I will just write it anyway. It’s a long one (and yes it has attachments and footnotes!) but please read until the end. I would also be grateful for a response to the points I have raised as this has taken a significant amount of my time to put together and I would be grateful if this could be respected.
Six months ago, at the beginning of lockdown, I heard about the CPP2 plans to develop a section of the Benfield Valley (Special Area 7 on the CPP2) via a school whatsapp group for the parents of my daughter’s class. I felt so impassioned by what I found out that I spoke to a number of local individuals, community groups, including:
Cllr. Dawn Barnett,
the Benfield Wildlife and Conservation Group (who look after the site to the north of the A27),
The Hangleton and Knoll Project,
our local Bat Group and Moth and Butterfly group,
and the Hangleton Community Centre
- and set up the Benfield Valley Project, a community group to support and protect the wildlife, flora and fauna of the Benfield Valley for generations to come. Going forward we will be working with Claire Johnson at HK Project to become a Constituted Community Group and provide social and conservation activities for the land and local residents.
What's the Problem?
You see, fellow residents (and I address you as such as we are all residents of Brighton and Hove and this affects us all), the fact is that people become attached to natural spaces; lockdown strengthened this attachment for local residents and visitors to the space. The CPP2 threatens not just the mental health of those that use this space - something that could arguably lead to greater expenditure by the local NHS in caring and providing for those whose mental health may suffer as a result of seeing this land carved up for profit - but the wildlife that lives there, the trees that grow there and which do an incredible job of absorbing the emissions from the neighbouring A293 (the lower section of which is an AQMA as detailed in Brighton & Hove’s Air Quality Report 2020, see below for further detail) and the busy A27.
We cannot keep needlessly carving up our landscape, nonchalantly claiming, ‘oh, it’s just a little bit,’ and expect our natural world to recover from the damage we have already done to it. No-one is disagreeing that we need affordable housing, of course we do, but, if as local Councillor Stephen Bell said in the Argus recently, deleting the urban fringe sites such as Benfield and Whitehawk Hill from CPP2 will still bring Brighton and Hove council 1,900 dwellings above their target, then building on a green space which is the last green lung that connects the Old Shoreham road to the South Downs, is senseless and destructive. There are plenty of unused dwellings (and perhaps some recently vacated office spaces?) within and around B&H which can serve this purpose; but once any section of the Benfield Valley is concreted over, however much we try to ‘make room for nature’ (which I hope would be up there on the list of top priorities should the council go against consensus and dangerously continue with the plans), the fact is that those trees will no longer exist. Ecologists tell us that our land is now so depleted that re-planting trees is not the same as allowing old ones to continue to grow, we cannot recreate the conditions that the trees initially grew under so anything that follows is, whilst still better than nothing, of less value to the biodiversity of the area:
‘The older the tree, the more vital to wildlife it becomes.’ (The Woodland Trust)
The Sustainability Appraisal
Every Space Has Value
In my eyes, having read the Sustainability Appraisal as it applies to Benfield Valley, section 5.6 of the CPP2 Sustainability Appraisal does not go far enough to recognise the value of this space. I will go through the main issues here. Firstly, it cites that,
‘Although the policy was found to have potential for adverse effects for biodiversity in the short term, it was found to have positive effects for biodiversity and open space in the longer term, as whilst the policy supports housing delivery on two parts of the site, the policy was found to have overall benefits these objectives, as it seeks to secure funding to protect and enhance the remainder of the site for nature conservation and open space purposes. It is also noted that the areas for development have been assessed as having lower ecological value than other parts of the site which should help to minimise ecological losses.’
No local conservation group or Ecologist not driven by financial gain would agree that any of this statement is true and I cannot understand how something so counter-intuitive could end up in an official document such as the CPP2 - why do we need to build on this space in order for it to have value and deserve protection and therefore access to funding? No area in a space like Benfield Valley is of ‘lower ecological value’ and I would appreciate the evidence for this being presented to the local community conservation and wildlife groups. In the natural world, every space has value, whether it’s the fungi that grows on the woodland floor and nourishes the earth through its mycelium, or the foraging and living space that it provides for local wildlife such as:
the now threatened hedgehog
rare Wasp Spiders
Common Lizards, which are protected in the UK under the Wildlife and Countryside Act, 1981 and are priority Species under the UK Post-2010 Biodiversity Framework (see video and highlighted images in the link at the bottom of this letter)
butterflies of many species including the Common Blue and Red Admiral
Buff Ermine Moths
Peach Blossom moths
Buff Arches moths
and Buff-Tip moths
(see images and videos in the link at the bottom of this letter as evidence - all taken by local residents and community groups from in and around the areas marked for development),
...as well as the homes that the canopies of the trees in this area provide for local birds such as:
and also our community of climate-indicators, Pipistrel bats.
If this space is seen as having ‘lower ecological value’ it is only because it has not been properly managed or cared for: paths have not been maintained, rubbish has not been cleared, tree canopies have not been tended to so as to provide more light to the woodland floor and encourage further growth and biodiversity. Why the council feels it could only do this if the land were to be ‘developed’ (and I use that term ironically), as mentioned in the Sustainability Appraisal, is anyone’s guess.
The Impact on Mental Health
To continue on from the Sustainability Appraisal,
‘Delivery of housing, particularly affordable housing can help reduce housing-based deprivation and also contributes towards economic growth. The policy was found to have potential for significant adverse impact for landscape in the short term, although impacts should improve over time, as the areas of the site suitable for housing have been assessed as having potential for significant landscape effect120 based on a lower amount than proposed in the policy and therefore a higher amount could have a greater significant landscape effect particularly in the short term whilst any screening mitigation is ineffective. Impacts become less significantly adverse in the longer term as mitigation becomes more effective.’
The irony here is that working class people, ethnic minorities (who are statistically more likely to face socioeconomic disadvantage), and those facing ‘housing-based deprivation’ are those most likely to suffer the long term mental health effects of a lack of good quality, accessible green space (and this does not include sports pitches) as those lower income households are more likely to live in urban areas, which generally have with less uninterrupted green space. A 2014 OECD report based on the results of a project conducted 2010-2013 states that, ‘what we do know about living in cities is that it increases our risk of mental health problems…(and that)…cities have both health risks and benefits (such as accessible health care and social support), but mood and anxiety disorders are more prevalent in city-dwellers and the incidence of schizophrenia is much higher in people born and raised in cities.’
Studies prove that the human brain needs natural biodiversity for so many reasons. US researcher, Richard Taylor and his team, found that natural shapes and repeated patterns in nature (known as fractals) prompt the alpha and beta waves in the brain, suggesting a ‘relaxed but focused state’ when out in good quality green spaces.
This was supported by recent study by the University of Derby, which demonstrates a greater level of activity in the parasympathetic nervous system when in a natural setting. The parasympathetic system is also known as the ‘relax and restore’ system and is the state that humans need to be in in order to feel and be well, rather than in the sympathetic nervous system, which prompts the ‘fight or flight’ response in the brain, raising levels of adrenaline and cortisol in the blood, thereby depressing the immune system and causing physical and mental health problems.
An OECD report in 2019 reported that the NHS spends approximately £94billion per year on mental health conditions; if something as simple as natural green spaces can help and actually improve the mental health of human beings, eventually saving the council and NHS money, then why get rid of them at such a rate?
Moreover, thanks to the law of Trespass, 92% of land in the England is privately owned, meaning that unless you are privileged enough to call an expanse of green space your back garden, you only will have access to 8% of good quality green space in England. We must hold onto to whatever spaces we have with both arms, not sell it off to the highest bidder who cares for nothing but profit at the expense of public health.
The Last 1% of Chalkland in the South Downs is Here…
Alongside this, the suggestion here if we look at the second sentence is that we are better off with these plans because ‘…based on a lower amount than proposed in the policy and therefore a higher amount could have a greater significant landscape effect particularly in the short term whilst any screening mitigation is ineffective. Impacts become less significantly adverse in the longer term as mitigation becomes more effective.’ My argument would be that no section of the Valley should be built on - be that 100 dwellings or more - due to it’s ecological value. The whole of the Valley is part of the last 1% of chalkland (known as a priority habitat) that we have in the South Downs. From the National Trust website,
‘Wildflower meadows on chalk downland are sometimes called Europe’s tropical rainforest. They're home to an incredibly rich and diverse range of plant and insect life…Up to 40 species of flowering plants can be found in one square metre of chalk grassland – also called lowland calcareous grassland. Many species grow nowhere else, including many beautiful orchids and wildflowers. In turn, they attract many insects and rare butterflies such as the Adonis Blue and Duke of Burgundy…Lime-rich, but low in nutrients, the thin soil holds little water and heats up quickly. These stressed conditions stop the dominant lush grasses from taking over. This allows a diverse range of smaller herbs and lower plants to flourish.
Anyone who has walked from the bottom end of the Benfield Valley all the way to the top at the South of the A27 on a Summer’s day will know this to be true. Attached are images of just a few of the species to be found on the section of land marked for development and include:
Old Man’s Beard,
We cannot afford to lose any of this space and the council is setting a dangerous precedence by allowing any of it to be built upon.
Before I begin this section, did you know that it takes seven trees to provide enough oxygen for one person? As stated in the Sustainability Appraisal,
’The policy was found to have potential for significant adverse impacts for air and noise quality. The site suffers from road noise, which could impact upon occupier amenity and which could worsen through any increase in transport movements. Although outside the AQMA, delivery of 100 dwellings on the site could result in an increase in vehicle movements that has a significant effect on air quality.’
The area to the south of the Benfield Valley, at the bottom of the A293, is stated on the 2020 Brighton and Hove Air Quality survey as being an AQMA (see map attached). It stands to reason that with a significantly reduced number of trees to absorb carbon emissions from the passing traffic, air quality could not only worsen the situation further but also put more pressure on the local NHS services. As stated in the 2018 government guidance document ‘Health Matters: Air Pollution,’
‘Air pollution has a significant effect on public health, and poor air quality is the largest environmental risk to public health in the UK. In 2010, the Environment Audit Committee considered that the cost of health impacts of air pollution was likely to exceed estimates of £8 to 20 billion.’
We already know from cases such as the death of nine year-old Ella Kissi-Debrah in 2014 as the result of a fatal asthma attack thought to have been brought on by spikes in nitrogen oxide and PM10s near to her home in South London, that high levels of air pollution have the potential to cause serious health damage. Especially in the times we are facing now, councils should be helping with constituents to remain healthy and safe, not decimate one of the few, uninterrupted green spaces we have left in the borough.
So where do we go from here and what could the space become? Some ideas.
My offer to you then is to come to the Benfield Valley, to see the section the planning committee has marked for development, and allow me to walk you around it, showing you everything that is there and the potential it offers us for becoming a nature reserve that could be a source of pride for Brighton and Hove and East Sussex as a whole (this outdoor meeting would not be a contravention of any current government restrictions and could take place at a time of your convenience).
There is funding and support available outside of town councils for protecting green spaces such as Benfield Valley and by tapping into these, working with local rangers, Ecologists and Conservation and Community groups, this space could be something even more wonderful than it already is, drawing in visitors from around the country. Some suggestions and possibilities are as follows:
Create a stopping off point for walkers visiting the South Downs Way, which runs nearby,
Create a centre for environmental/conservation education for young people and students as well as the wider community.
The grade II listed barn (also a home for our Pipistrel bats) on the north site could be restored by local builders to become a community arts and learning hub,
Convert the garden behind the barn to a ‘wild garden’ to teach and learn about permaculture and biodiverse gardening in small spaces wold provide an opportunity for local conservation and community groups
Designate the Benfield Valley a Local Green Space,
Add it to the list of Conservation areas,
Create a Field in Trust, or saving the space
Transform it into a legally-protected Nature Reserve in the way that the Worthing and Adur Council have done for the New Salts Farm the council would be protecting the health and wellbeing not just of our local ecosystem, but of our children, who want so much to grow up in a world rich with biodiversity and wildlife.
This space also provides an opportunity for ‘green jobs’ for locals for many years to come, contributing to the local economy in innovative and creative ways.
The current leaseholders do not care for this space as the local residents do, and as the council should (and my thoughts on that could write another four page letter entirely!). Spaces such as the Benfield Valley should not be held to ransom in this way. It is dangerous, it is unethical and it is just a small (but no less significant) part of what seals our fate as a species. All it takes is imagination, community engagement and the courage to do things differently.
Thank you for taking the time to read this letter. Please do let me know if you would like to take me up on my offer of introducing you to and guiding you around the space.
A Local Resident and Mother of two children aged 4 and 6.
***Please go to this link to view all images and videos referenced in this letter: https://drive.google.com/drive/folders/198S-tbnTg8IpW9mZAZVbqF3LCxI_0yZK?usp=sharing ***
NB. Please note that a copy of this letter has also been sent to Peter Kyle MP, Caroline Lucas MP, a representative at BBC South Today, BBC Radio Sussex, the Sussex branch of the CPRE, the Sussex Wildlife Trust, The Woodlands Trust, community and conservation leaders and in the local area.
References and Links https://www.wildlifetrusts.org/wildlife-explorer/reptiles/common-lizard E. Hewlett & V. Moran, Making Mental Health Count’ (OECD, 2014) L. Jones, Losing Eden (Allen Lane, 2020) C.M. Hagerhall, T. Laike, R.P. Taylor, M. Kuller, R. Kuller and T.P. Martin, ‘Investigations of Human EEG response to viewing fractal patterns,’ Perception, (2008) pp. 1488-94 M. Richardson, K. McEwan, F. Maratos, D. Sheffield, ‘Joy and Calm: how an evolutionary functional model of affect regulation informs positive emotions in nature.’ Evolutionary Psychological Science (Dec 2016) https://www.oecd-ilibrary.org/social-issues-migration-health/health-at-a-glance-2019_4dd50c09-en (https://www.nationaltrust.org.uk/features/whats-special-about-chalk-grassland ) https://www.sciencefocus.com/planet-earth/how-many-trees-does-it-take-to-produce-oxygen-for-one-person/ (https://www.gov.uk/government/publications/health-matters-air-pollution/health-matters-air-pollution ) https://www.bbc.co.uk/news/uk-england-london-48132490 (https://www.gov.uk/guidance/open-space-sports-and-recreation-facilities-public-rights-of-way-and-local-green-space#Local-Green-Space-designation) (http://www.fieldsintrust.org ) https://www.theargus.co.uk/news/18696946.new-salts-farm-shoreham-bought-kept-nature-reserve/