Highways England have announced a route for the Arundel bypass which passes through three villages, with a far worse effect on communities than any of the other routes. HE will be hoping that their terribly damaging scheme will be approved because it is outside the National Park, which is protected in planning law.
But Natural England pointed out in their 2019 consultation response that UK planning policy protects the setting of National Parks, as well as National Parks themselves. They argued that the whole area, inside and outside the National Park, is essential to the species which live there.
Highways England tried to justify the Grey route in 2019 by saying ‘It is more distant from core foraging and roosting locations used by woodland bats’. Natural England disagreed: ‘We advise that all the offline options [i.e. including Grey] present significant impacts regarding severance and loss of habitat which are of great concern to Natural England. The bats have been shown to use this area in a dynamic way and are clearly foraging over this area as a whole.’
They explained further: ‘The woodland is known to contain maternity roosts for two ‘Annex II’ species of bat (barbastelle and Bechstein’s) and also of an ‘Annex IV’ species which is currently considered to be extremely rare in England, the alcathoe bat. The presence of maternity roosts for these rare bat species is of exceptional significance and, together with the wider baat species assemblage, indicates the landscape as being of the highest quality.
‘The mosaic of long-established ghyl and shaw woodland, meadows and riverine habitats represent crucial supporting habitats for these species. It is highly likely that these interconnected habitats are used in their entirety by all the bat species present for roosting, commuting and feeding, and potentially for swaming and hibernation.’ Large areas of woodland are included in the National Park, but the ‘mosaic of long-established ghyl and shaw woodland, meadows and riverine habitats’ which are ‘crucial supporting habitats’ for these species are not included in the Park.
As Natural England said, ‘This area is extraordinary. It is clear that this environment is of exceptional importance for biodiversity, with key, priority and irreplaceable habitats and species.’ One of the Special Qualities of the National Park is ‘A rich variety of wildlife and habitats including rare and internationally important species’. A road scheme separating these habitats and damaging these species would ‘have an impact’ on the whole of this extraordinary area. ‘Mitigation’ for bats is known to be ineffective. Parts of the Grey route are on a viaduct, raising the road closer to the flight paths of bats.
This should mean that the Grey route, although just outside the National Park, is still against the UK’s planning policy. The inhabitants of these three villages, and the thousands of people who love and visit the area, will certainly hope so.
 National Policy Statement for National Networks, 5.154, says: ‘The duty to have regard to the purposes of nationally designated areas also applies when considering applications for projects outside the boundaries of these areas which may have impacts on them.’