New Guidance on Bird Surveys Coming in 2019

Bird Survey and Assessment Guidance in preparation

New guidance on bird survey and assessment will be released in 2019, according to an update from CIEEM.

They report that

guidance for ecological consultants and decision makers working in planning and built development is in preparation. A steering group consisting of consultants and representatives from CIEEM, Natural England, RSPB and the BTO is developing the guidance to provide consistency of approach and effort to bird survey and assessment within the industry.

The current issue with bird survey practices is that commonly used methodologies (such as the common bird census) were not designed for assessing the potential impacts of development on wildlife within a site, but for long-term monitoring.  This has created a certain amount of guesswork when designing surveys and a risk that an LPA ecologist won’t agree with the approach taken.  Having a common set of guidance will reduce this risk, whilst improving the quality of data used in assessment.  There isn’t an indication whether the survey effort requirement will be higher than that used at the moment, but I suspect that we will be moving from a minimum of three visits in the breeding season to four or five and something similar for winter bird surveys.  I hope that the guidance will also set out at what point surveys for birds are required for planning applications, so that a similar treatment can be applied across sites.

We will report back when the bird survey guidance is released and provide guidance to our clients.

What does the new National Planning Policy Framework mean for ecology and biodiversity?

NPPF Update – Ecology and Biodiversity Discussion

A revised National Planning Policy Framework has been published today. The document sets out the government’s planning policies for England and how these are expected to be applied.

The most relevant sections to our work are repeated below and I have commented on some of the more directly ecological / biodiversity points (I have paraphrased or truncated many sections, so please view the full text here).

Section 2 Achieving Sustainable Development

This section sets out the three objectives of the NPPF. These are economic, social and environmental:

environmental objective – to contribute to protecting and enhancing our natural, built and historic environment; including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy”

It is worth noting that much of the NPPF concerns the production of development plans by planning authorities, rather than being directly related to planning applications.  Although the NPPF would be used where there isn’t an up to date plan, and there are some exceptions where the NPPF refers to applications (or decisions on them) rather than plans. As sections which relate to planning applications are more immediately relevant to us and our clients, I’ve highlighted references to decisions and applications below.

Section 15 Conserving and enhancing the natural environment

  1. Planning policies and decisions should contribute to and enhance the natural and local environment by:
  2. a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan);

This is quite broad brush, but hierarchies of protection are discussed later.

  1. b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland;

This is also quite broad brush and subjective.

  1. c) maintaining the character of the undeveloped coast, while improving public access to it where appropriate;
  2. d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;

There are two things here – note that this states’ minimising impacts AND providing net gains for biodiversity’. This also emphasises the importance of networks for biodiversity.

  1. e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans;
  2. f) remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.

A further call for brownfield development, but this can obviously also conflict with biodiversity issues.

  1. Plans should: distinguish between the hierarchy of international, national and locally designated sites; allocate land with the least environmental or amenity value, where consistent with other policies in this Framework; take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure; and plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries.

This tightens up that loose statement in section 170 which suggests protection of all environmental sites; plans at least should acknowledge that not all sites are equally important.

Again we have an emphasis on networks and introduce the term ‘green infrastructure’, which we have seen as a rising topic in planning and biodiversity in recent years (and interesting that this is at a landscape scale).

  1. Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads.

We already expect scrutiny of wildlife issues for our projects in National Parks to be higher than that in other spaces.  We haven’t noticed a difference in scrutiny of wildlife issues in AONB sites and equivalent non-AONB habitats (i.e development on a wildflower rich pasture would be subject to scrutiny whether or not it was in an AONB). Perhaps this will raise biodiversity further up the agenda in these areas.

The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:

  1. a) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
  2. b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and
  3. c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.
  4. Within areas defined as Heritage Coast (and that do not already fall within one of the designated areas mentioned in paragraph 172), planning policies and decisions should be consistent with the special character of the area and the importance of its conservation. Major development within a Heritage Coast is unlikely to be appropriate, unless it is compatible with its special character.

Habitats and biodiversity

  1. To protect and enhance biodiversity and geodiversity, plans should:
  2. a) Identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity; wildlife corridors and stepping stones that connect them; and areas identified by national and local partnerships for habitat management, enhancement, restoration or creation; and

Here again we have an emphasis on networks and corridors, also note that plans should protect areas identified by local partnerships for habitat management; the NPPF doesn’t define what it means by local partnerships, but I take this to include local action groups and conservation groups.

  1. b) promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity.

Noteworthy here are the terms enhancement, networks (again) and recovery of priority species.  The big impact for planning applications here are ‘measurable net gains for biodiversity’.  More on that after 175a below …

  1. When determining planning applications, local planning authorities should apply the following principles:
  2. a) if significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;

This is a reinforcement of the mitigation hierarchy – this should already be the standard approach taken in Ecological Impact Assessments (EcIA), although the process isn’t always explicitly set out in Preliminary Ecological Assessment reports.

  1. b) development on land within or outside a Site of Special Scientific Interest, and which is likely to have an adverse effect on it (either individually or in combination with other developments), should not normally be permitted. The only exception is where the benefits of the development in the location proposed clearly outweigh both its likely impact on the features of the site that make it of special scientific interest, and any broader impacts on the national network of Sites of Special Scientific Interest;

This essentially means that development on or near SSSI is ok if you can justify it – hopefully this will not be taken, for example, as an excuse to develop golf courses on SSSI sand dunes. [https://scottishwildlifetrust.org.uk/our-work/our-advocacy/current-campaigns/coul-links/]

  1. c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists; and

This is a really important point.  These habitats are irreplaceable (i.e. genuinely impossible to artificially re-create) and it is difficult to see what could be ‘suitable’ compensation for their loss.  I would expect that this means that ancient woodland and veteran trees are effectively wholly protected in planning, the wording doesn’t even state ‘should normally be refused’, nor does it state that the development should be refused ‘unless the benefit outweighs the impact’ (as it does for SSSI in 175 c) – so perhaps even national infrastructure projects would be held to this?

  1. d) development whose primary objective is to conserve or enhance biodiversity should be supported; while opportunities to incorporate biodiversity improvements in and around developments should be encouraged, especially where this can secure measurable net gains for biodiversity.

Here are those ‘measurable net gains’ again – I think that this will bring forward a stated requirement within development plans that new applications should use quantitative impact calculations, such as the Biodiversity Impact Assessment Matrix, where a numerical value of a site’s biodiversity can be predicted before and after development. Note that this doesn’t go as far as to say that projects should be refused if they do not deliver gains, only that they should be encouraged (although future plans may include specific requirements).

  1. The following should be given the same protection as habitats sites:

The NPPF defines habitats sites as Special Areas of Conservation, Sites of Community Importance, Special Areas of Conservation and Special Protection Areas and any relevant Marine Sites; these are internationally protected sites notified through the Habitat Regulations.

  1. a) potential Special Protection Areas and possible Special Areas of Conservation;
  2. b) listed or proposed Ramsar sites; and
  3. c) sites identified, or required, as compensatory measures for adverse effects on habitats sites, potential Special Protection Areas, possible Special Areas of Conservation, and listed or proposed Ramsar sites.

It will be interesting to see how such compensation sites will be recorded and protected.

  1. The presumption in favour of sustainable development does not apply where development requiring appropriate assessment because of its potential impact on a habitats site is being planned or determined.

So no presumption in favour of development that may affect those ‘habitats sites’ listed above.

Natural England Consultation on Licence Charges

Natural England are currently consulting on a proposal to introduce charges for wildlife licences.

Natural England states that it “want[s] to ensure this service offers value for money for licence applicants and the taxpayer and achieves good outcomes for wildlife.”

We work with our clients when they need a wildlife licence from Natural England, for example when planning to disturb or remove protected wildlife or damage protected habitats.

This will primarily affect licences we apply for under The Conservation of Habitats and Species Regulations 2017, Wildlife and Countryside Act 1981 (as amended) and the Protection of Badgers Act 1992.

Natural England state that the proposal aims to:

  • Improve the licensing service for customers by enabling investment in line with changes in customer demand
  • Change the licensing service from wholly taxpayer-funded to a mixture of taxpayer-funded and service user-funded, in line with Treasury and Cabinet Office principles for the funding of regulatory activity.
  • Charges will also include cost recovery for compliance monitoring. This will enable a consistent level of compliance checks to be sustained, which will improve conservation outcomes for wildlife.

Natural England are consulting on exemptions from charging where the application is in relation to health and safety, the prevention of serious damage to property or the spread of disease, householder development projects, conservation delivery projects and conservation research.

Natural England has powers to charge for licences under the Natural Environment and Rural Communities Act 2006.
Charging would begin in the second half of 2018 if approved.

I have responded to the consultation on behalf of our clients. I have long held the view that licences should be paid for, where the funds are ring fenced to ensure that they fund a better services (at times we have to wait for two months or more to receive a licence), fund production of literature and training for consultants to standardise the quality of applications across the industry and to fund compliance monitoring where appropriate.

In general, I support the introduction of charging. However, I strongly object to the exclusion of householder applications from the charges and the size of the charge (roughly £130 per survey licence and £700 per development related application).

I consider that a fairer approach would be to levy a smaller charge (£75 – £100) per application across all applicants, rather than hit developers with £700 per application. We work with many clients who are small builders and are managing single house renovation projects with small budgets, and this seems to unfairly hit them.

The consultation is now open and will close on Monday 5 February 2018.

https://consult.defra.gov.uk/natural-england/wildlife-licence-charges

If you have views on this subject, you may want to have your voice heard.

Brexit and Ecology – Update

Since the results of the referendum on Britain’s membership of the EU were announced, there has been much speculation on how this will affect our client’s projects and the ecology consultancy industry as a whole.

As I discussed at the time here I am optimistic – my personal opinion is ‘not a lot’, at least not for some time.

It would appear that this is closer to reality now, since Theresa May’s announcement at the Conservative Party conference at the beginning of the month of a proposed Repeal Bill.

The Repeal Bill would end the authority of EU law by converting all its provisions in British law on the day of exit. At the same time, the 1972 European Communities Act would be repealed. The aim of the legislation will be to end the authority of EU law by converting all its provisions in British law on the day of exit from the bloc whilst repealing 1972 European Communities Act at the same time.

We now know that as of the date that we leave the EU (by March 2019) all existing wildlife legislation will be on the UK statute book.  It is likely that there will then be a review of the legislation (as for many other laws), which may result in a change to the protection of species and sites in the UK, but this is likely to be a lengthy process.

Brexit and Ecology Consultancy

Since the results of the referendum on Britain’s membership of the EU were announced, there has been much speculation on how this will affect our client’s projects and the ecology consultancy industry as a whole.

I am optimistic – my personal opinion is ‘not a lot’, at least not for some time.

Although much of the UK’s wildlife and environmental legislation is based on EU directives, these have been transposed into UK law, such as the Habitats Regulations.  Leaving the EU will not automatically repeal these laws, but will leave them open to be unpicked, if there is a political will to do so.  However, leaving the EU will not automatically remove protection from what we refer to as ‘European protected species’ or ‘European Sites’.  Perhaps we will need a new term?

In the long-term it is likely that the wildlife legislation that protects our habitats and rarer species will be reformed and modernised, in fact there is a stalled draft Wildlife Bill in parliament which sets out to consolidate various pieces of wildlife law into one piece of legislation; this has gone through a period of consultation and so would seem to be an easy win (for Government and the environment) as it is ready to go.

We are also signatory to various international treaties on wildlife protection, such as the Ramsar Convention and Convention on Biodiversity, which we will still be obliged to follow on leaving the EU.

And so I think it is likely that we will not see significant change to wildlife legislation for at least three years. Even then, it may be that new legislation is better than the current situation.  What you call better obviously depends on your perspective:  personally I feel that protected species legislation currently focuses too strongly on protecting individual animals/plants than on populations and communities.  Conservation efforts (and mitigation / compensation from development activities) should be better focused on maintaining local populations and habitats, rather than ensuring that every individual is ‘saved’ (for some species impacts to individuals may have a population scale effect, but for animals with high fecundity, such as great crested newts, this will not usually be the case).

Government Strategy for Pollinating Insects

Environment Secretary Elizabeth Truss is launching the National Pollinator Strategy to support bees and other pollinators

The government is launching a new strategy to support bees and other pollinators that are vital for fertilising plants so they produce fruits and seeds.

Organisations such as Network Rail, Highways Agency and the National Trust which manage more than 800,000 hectares of land in England have signed up to the National Pollinator Strategy, and pledged to take actions such as planting more bee-friendly wild flowers and allowing grass to grow longer.

Environment Secretary Elizabeth Truss said:

As much as one third of the food we eat is pollinated by bees –from apples and pears to strawberries to beans. We now estimate the value of insects pollinating our crops and plants amounts to hundreds of millions of pounds.

That’s why we are doing everything we can to help them thrive. Not everyone can become a beekeeper, but everyone from major landowners to window-box gardeners can play their part in boosting pollinators.

Defra is setting up bee hives on the roof of their building in London and supermarkets including Waitrose and Coop have been distributing bee-friendly flower seeds to their customers.

Motorway verges, railway embankments and forests will be used to create bee and insect friendly paradises as part of the major new strategy to protect the 1500 species of pollinators in England.

Defra has also announced the first ever wild pollinator and farm wildlife package, which will see more funding made available to farmers and landowners that take steps to protect pollinators through the new Countryside Stewardship Scheme.

More information about how everyone can help pollinators is on the Bees’ Needs website.

Source 

Prime Environment will be reviewing our ecology enhancement strategies and mitigation schemes for developments over the next year with pollinators as the main focus.

This short video shows the importance of pollinators, some of the problems and what everyone can do to help pollinators thrive.

 

CIRIA’s BIG Challenge

The natural environment provides us with a range of crucial benefits including food, water, materials, flood defences and carbon sequestration. Biodiversity underpins most, if not all, of them. Besides the growing consensus that it is prudent to work with and make use of natural processes and systems where possible, it is wrong to let species become extinct and to exploit or dominate nature as if it were an obstacle to progress.

With this in mind, biodiversity enhancement needs to be at the heart of all design and engineering processes, but knowing where to start and how to incorporate such enhancements into developments can be daunting. This is especially true when the development is already under construction and changes are hard to make.

Do One Thing For Biodiversity

CIRIA is the Construction Industry Research and Information Association. Its Biodiversity Interest Group launched the BIG Challenge. The BIG Challenge encourages organisations to “do one thing” i.e. to implement one new biodiversity enhancement on each site or development. The enhancements can be as simple as adding hanging baskets planted with native wildflowers, creating bug hotels, creating rain gardens, planted cycle locks or skip gardens. These can be permanent features of the development or temporary installations during the construction phase which, when finished, could potentially be transferred to the next site and enhanced further. The challenge can also include initiatives such as creating biodiversity champions within organisations, or initiating biodiversity programmes that engage with the local community.

Construction companies are encouraged to sign up to the BIG Challenge so that the Biodiversity Interest Group can begin to map these enhancements across the UK. Once the enhancement is completed organisations will have an opportunity to showcase it to encourage others to sign up and demonstrate the simplicity of the achievement.

Prime Environment are very pleased to be contributing towards the BIG challenge and already always include biodiversity enhancements in Phase 1 Habitat Survey reports – in fact it is a requirement of the National Planning Policy Framework that councils seek such enhancement in all planning applications where possible. We can demonstrate how biodiversity enhancements can be simple, affordable and achievable and how organisations can get involved and help to make biodiversity mainstream.

The BIG Challenge shows that small enhancements are the crucial first step in engaging with and understanding biodiversity. Hopefully the challenge will gain enough momentum to ensure that biodiversity becomes a much greater consideration in developments during construction through to the final scheme.

 

 

Natural England’s Revised Standing Advice for European Protected Species

Natural England have revised their standing advice for European Protected Species.

European protected species include bats, great crested newts, dormice, natterjack toads, otters and two reptile species (sand lizards and smooth snakes).

Natural England say that:

“Local Planning Authorities (LPAs) and developers will no longer have to wait for 21 days for advice from Natural England on wildlife species covered by European law.

The latest improvements follow a wide-ranging review that Natural England has been carrying out to look at how standing advice can be used more widely to help reduce red-tape for LPAs, which has included carrying out pilots in the Summer with Cornwall County Council and 60 authorities in the South East.

By having access to standing advice on European Protected Species (EPS) on its website, LPAs and developers will be able to consult Natural England less often. The new approach on EPS will mirror the approach for species protected by domestic legislation, where Natural England has been referring LPAs and developers to standing advice for the past two years.

The new approach for EPS will provide greater consistency for LPAs and developers, and by helping speed up decision-making will reduce delays in the planning process.”

The Standing Advice provides a basic advice which can be applied to any planning application that could affect protected species. It provides advice to planners on deciding if there is a ‘reasonable likelihood’ of protected species being present. It also provides advice on survey and mitigation requirements. As standing advice it is a material consideration in the determination of applications in the same way as any individual response received from Natural England following consultation. Information for LPAs on the Standing Advice for protected species is available on Natural England’s standing advice internet pages.

What this means to developers is that it is now even less likely that bespoke, project specific consultation with Natural England will occur and, unless the LPA employs its own ecologists to provide advice, these sheets will be all that they can rely on when determining an application. It may lead to a more consistent approach, and it will be interesting to see how often LPAs refer to these documents in their considerations.

When giving advice on protected species issues for our clients, we will be reviewing the new standing advice and referring to the survey effort, mitigation and compensation levels in these documents to ensure that our project work is compliant.

If you have any questions about European Protected Species, get in touch.

European Protected Species Licensing

This article aims to describe what European Protected Species  (EPS) Licences are, and outlines how they are obtained.  

I often provide advice to developers on EPS issues and obtain licences on their behalf.  I thought it may be useful to set out some text here that I can direct people to for further information.  If you would like more assistance, please feel free to contact me, I’m always happy to provide free advice or second opinions.  

The animal and plant species listed on Schedule 2 and 4 of The Conservation of Habitats and Species Regulations 2010 (as amended) are referred to as…

European Protected Species (EPS).

If a project is likely to impact European protected species, such as by removing dormouse hedgerows, developing arable land around a great crested newt pond or renovating a barn with bats, and where avoidance measures can’t remove the impact, licences can be obtained to allow persons to carry out activities that would otherwise be prohibited, without committing an offence.

Natural England has powers to grant such licences in England if it meets three ‘derogation tests’. For development activities this licence is normally obtained after planning permission has been approved.

The three derogation tests are that:

1)      The activity to be licensed must be for imperative reasons of overriding public interest[1] or for public health and safety;

2)      There must be no satisfactory alternative; and

3)      Favourable conservation status of the species must be maintained.

The licence application consists of three documents, Section one – Application details (a basic application form), Section two – Method Statement (MS) (specifying the proposals, mitigation, compensation and schedule and demonstrating how the project meets Test 3) and Section three – Reasoned Statement (RS) (demonstrating how the project meets Tests 1 and 2). The Application form and Method Statement are usually completed by your ecologist (who is included in the application as a Named Ecologist) and the Reasoned Statement by the client or their planning consultant or environmental lawyer.

The developer is usually the applicant and licensee and is legally responsible for carrying out the method statement. In order to protect other people working on the project (and also to legally tie them to the MS) contractors and consultants that may affect the EPS, such as demolition or construction contractors and the ecologist should be appointed as ‘accredited agents’ to the licence by the licensee.

Natural England aim to determine an application within 30 working days, at which point they make a Further Information Request (FIR) if there are uncertainties or they do not agree with the MS or RS. At the end of the licensable activities the named ecologist is required to submit a licence return, where they declare the success (or failure) of the mitigation and are obliged to report on breaches to the MS.

Although Natural England ‘aim’ to determine within 30 working days, in reality this can take much longer, so if possible please allow 90 working days from sending the application before you intend to start on site.

 


[1] This is usually arguable where the project meets an identified planning need, i.e. social housing.

Smoother route to ecology licence and planning applications?

New Consultation Services from Natural England for Planning and Licence Applications

Natural England is rolling out two chargeable advisory services for planning and licensing from the beginning of April 2013.

      • The Pre-submission Screening Service (PSS) for European Protected Species mitigation licence applications
      • The Discretionary Advice Service (DAS) to provide discretionary pre-application and post-consent advice

 

These two new services came into effect from the beginning of April 2013.

The aim of the services is to help applicants take appropriate account of environmental considerations at an early stage of plan development. For applicants, this can reduce uncertainty and the risk of delay and added cost at a later stage, whilst securing good results for the natural environment.

 

Pre-submission Screening Service (licence applications)

The new Pre-Submission Screening Service enables potential applicants for a European Protected Species licence – such as a bat licence to find out whether their plans are likely to meet licensing requirements prior to the submission of a formal application, for example whether your bat surveys meet their expectations.

The full roll-out will involve the implementation of the Discretionary Advice Service as their standard offer for all new pre-application cases, including Nationally Significant Infrastructure Projects (NSIPs) and offshore work.

 

Discretionary Advice Service (planning applications)

The Discretionary Advice Service is geared towards cases with the potential for significant impact on protected sites, landscapes/seascapes and species, or those which could deliver significant environmental gain. The service would be useful for large scale housing applications, where we could consult and agree an ecology survey schedule with Natural England, and later agree appropriate outline ecology mitigation ahead of submitting a planning application. Being able to demonstrate fuller engagement with Natural England will help contentious projects through planning and appeal; recently this level of engagement has been difficult as Natural England have pared back their consultation due to budget cuts, and often only provided standing advice for many projects.

Natural England will offer a level of initial advice, free of charge, to help identify key issues and opportunities on a development proposal. The developer/consultant would then have the option of paying for further access to Natural England’s advice to help in the further development of their proposals. The Discretionary Advice Service also covers the post consent stages of marine development proposals.

 

How Prime Environment can Help

If you would like to engage with Natural England with these new services, please contact us to discuss your project. There are protocol to follow when requesting advice, such as filing a request form, which can be completed by the developer, or we can manage on your behalf. We can also represent your interests at site meetings with a Natural England officer. There are certain levels of series which Natural England will provide for free, and a tariff for detailed input and report review.

For further information on the Discretionary Advice Service visit: http://www.naturalengland.org.uk/ourwork/planningdevelopment/das/default.aspx.

For further information on the Pre-submission Screening Service visit: http://www.naturalengland.org.uk/ourwork/regulation/wildlife/species/epsscreening.aspx

Prime Environment is an ecology consultancy which provides advice, surveys and reports for planning and licence applications in the Midlands, Chilterns, South East and M1 corridor (Hertfordshire, Bedfordshire, Cambridgeshire, Berkshire, Buckinghamshire, East Sussex, Hampshire, Kent, Surrey, West Sussex, Peterborough, Oxfordshire, Gloucestershire and Northamptonshire).