Andy Horton 



Tel:  01273  462043/465433   EMail: Shoreham.html


7 August 2006


Adur District Council

Planning Policy



Environmental Representations


Mill Hill Nature Reserve


Attention is drawn to the important wildlife reserve, with a nationally important population of about 3000 Chalkhill Blue butterflies.


”The Shoreham Bank (Mill Hill) was nationally the most famous of all of the Sussex butterfly localities, yet its reputation was gained from just one phenomenon - the numbers and aberrations of the chalkhill blue butterfly, the archetypal downland butterfly that has been nationally celebrated on the bank since at least the 1820's after nearly two centuries of tradition, I have seen more than one aged lepidopterist's eyes fill with tears when discussing the insect's modern demise on those hills.“

(From “A Revised History of the Butterflies and Moths of Sussex” by Colin R Pratt.)


This is authentic natural downland with a special characteristic of a large expanse of five acres of a carpet of prostrate Horseshoe Vetch (a legume) and compatible downland herbs as the dominant flora and another five acres of grass with Horseshoe Vetch. This is a rare low fertility habitat.


This means it is a unique flora that does not fit in with the National Vegetation Classifications (The computer test means it does not comply with the general nature of such classifications and therefore should be unclassified).


This means that any change of management from meadows and rabbit warren needs a proper scientific environmental assessment which has not been done.


Note: prostrate Horseshoe Vetch is destroyed in the short term by cattle grazing and it is not renewable in a human lifetime as it is a slow spreading perennial herb. Once gone, it cannot be replaced. The main method of destruction is eutrophification, which occurs in patches over large pastures, but on the small area of Mill Hill will occur rapidly all in one go. (References available.)


The other threat is ecological succession into woodland. The shrub that is the leading incursor is Privet. Management needs to be in place to aggressively control the Privet spread which will wipe out the Horseshoe Vetch within 20 years at the current rate of spread.


There is an animal welfare issue with animals on the land as both Horseshoe Vetch and Privet are poisonous to livestock. (No guarantee they will eat it though.)












1)     A proper environmental assessment should be made of the flora and fauna of the land before any change of use (or enhancement)  is proposed or implemented and that trial and error methods should not be used. This could result in SSSI status and scientific advice become  compulsory from English Nature, because of chalk downland indicator species, rare BAP species, and specialised flora and fauna.


2)     That a Friends of Mill Hill and Shoreham Downs should be established with local representation.


3)   That management should be undertaken by a committee with local representation with a local Councillor representation.


4)  That decisions should be made on a scientific basis.


5)     That the primarily conservation interest should be the preservation of the Horseshoe Vetch and the Chalkhill Blues in preference to other concerns. (i.e. no enhancement by introductions or management change without scientific advice and public consultation.)


6)     That the area should be retained as a public open space and not put into private management.


7)     That an ongoing environmental assessment should be made.


8)  That the biological information should be readily available in the public domain (including a schedule of work undertaken).





















Note on the Local Plan:


Core Strategy

Annexed 1


ENV1 Nature conservation and biodiversity


Delivery Mechanism


Delivery mechanism should be by a local management group and “Friends of ……” groups with scientific advice (e.g., scientists at English Nature or West Sussex County Council with elected representatives who can be contacted.). Management should be in local hands and not privatised to outside third party bodies or private clubs like the Wildlife Trusts.


Local knowledge should be consulted. Management should not be delegated to an absentee management group. 


Yours sincerely


Andy Horton

Institute of Biology Affiliated Societies Membership