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ITEM EN5(b)

Note from Stuart Hylton on GOSE's representations on the SE Plan

Government Office for the South East

A: General comments

Provides a section of facts and figures about the South East, including its importance to the national economy.

Wants stronger relationship to other regional strategies.

Detailed comments on process – largely supportive.

Suggests Plan is too long and detailed, and not regionally specific enough (yet most of their proposals involve further additions to the Plan, not taking anything out).

Economy: Questions whether Plan has a coherent long-term strategy to support objectives of high and stable economic growth, set out in PPS11.

Queries logic of having no long-term GVA target at a regional level, but sub-regional targets (which are much more prone to uncertainty).

Suggests inclusion of employment growth and/or employment land/floor space as indicative economic growth targets.

Points to likely worsening of labour supply/ demand mismatch. Wants to see: evidence base underpinning labour supply/ demand at regional and sub-regional levels investigated; whether the strategy supports the region’s and sub-regions’ economic objectives; consequences of the forecast scale and distribution of future growth.

Housing: Wants to see a wider range of housing growth levels tested, as per RTP report.

Wants robustness of demographic forecasts testing at regional and sub-regional levels.

Does scale and distribution of growth adequately reflect the vision for the growth areas/ growth points?

Is the Plan robust in dealing with uncertainties, such as possible overspill from London?

Do the levels of housing growth meet PPG3, the Sustainable Communities Plan, the Government’s response to Barker and ODPM’s December 2005 call for a speedy turnaround in affordability?

Why are some authorities’ future housing figures lower than current ones?

Supply side factors: Have capacity studies, housing market delivery capabilities and local housing trajectories been taken fully into account? Is the assessment of best spatial options robust – have all alternatives been considered? Has the impact on environmental constraints and infrastructure been fully factored in?

Promotes the idea of growth areas and growth points and implies the Plan could do more in this respect. Suggests new growth points could be a focus for additional housing and economic growth.

Relationship to other regions: Quotes English Regions Network report Regional Futures showing how constraint in the South East would have adverse effects for other regions and for the national economy. Shows importance to Government tax revenues of linkages between London and the South East.

Transport: Concern that approach to infrastructure needs remains over-simplistic. Want more focus on demand management in relation to transport. Asks whether the spatial distribution has had adequate regard to spare infrastructure capacity. They float the idea of a housing distribution modelled to minimise infrastructure costs (?). Infrastructure affordability has not been adequately fed into the process and needs to be tested at the EiP. Want to see clear evidence of need for additional infrastructure.

In particular, they want the Panel to explore the robustness of the relationships in the Plan between housing numbers and distribution, and traffic management, planning, and infrastructure provision. Other transport issues they list are:

  • whether the Plan has failed to pick up on a long list of changes to Government Policy;

  • whether the implementation of the Plan is acceptable, given the omission of costs and timescales and the inclusion of very local interventions;

  • whether RTS objectives could be more regionally specific and hierarchical, and related more to a summary of the evidence base;

  • whether RTS conforms with the Air Transport White Paper;

  • whether the Plan gives due consideration to affordability (refers to demand management, making better use of existing infrastructure and the need to prioritise interventions;

  • whether the Plan can contain a clearer, more positive and more spatially specific policy on road user charging;

  • the need for greater specificity about the location of inter-modal freight exchanges.

Health: Supports the principle but wants the Panel to show how the vision can be developed.

Crime: Plan lacks any provision for the community safety agenda. Asks the Panel to consider how this can best be done. (Detailed suggestions are made in part B of their response).

Climate change and sustainable development: Wants to see:

  • The implications of the latest climate change scenarios addressed;

  • Development moved away from areas at risk from flooding and water shortage;

  • Consideration of the physical and environmental constraints on development of land.

Town Centres: Concern at the selection of some centres and at whether the policies provide a south east-specific context.

Water resources: They recognise the importance of this (and public concern) and want the EiP to give it comprehensive consideration.

Sub-regions: Detailed comments in section B. Their general thought about some of the sub-regional policies was the degree of overlap with the core strategy and a lack of sub-regional specificity. There was also an inconsistency of approach, with some sub-regions having employment land policies and employment targets, and others not.

B: Detailed comments:

This runs to over 40 pages and comments on individual paragraphs and policies. Some of the main points are picked up below, but I would encourage anyone preparing evidence or appearing at the EiP to read the relevant parts of it in detail, since it looks to be an excellent guide to the Panel’s likely agenda.

Para 4.2: They are clearly sceptical about London’s ability to deliver its housing target and want the Panel to consider what the ramifications for the South East are, if it does not.

Para 3.3: In addition to challenging the overall level of housing provision, they are very sceptical about the way the 29,000 housing backlog is being handled (and whether the 2001 figure of 29,000 is still applicable).

Table C3: They want the robustness of the sub-regional and "rest of" housing figures to be tested, in the light of:

  • The demographic evidence;

  • Economic objectives;

  • Robustness of the housing capacity estimates;

  • Alignment between sub-regional, housing market area boundaries and the deliverability implications resulting from it;

  • Appropriateness and implications of very low housing provision figures proposed for some of the "rest of" areas.

They are particularly keen to test the deliverability of the housing figures.

Policy CC5 - Infrastructure: They are concerned that the Plan tackles infrastructure in such a generic manner. They say:

  • It fails to recognise the scope for making better use of existing infrastructure or for managing demand;

  • The idea that growth should be "conditional" upon infrastructure ignores the fact that RSS can influence investment as well as respond to it;

  • Not all new development automatically leads to increased demand for all types of infrastructure (eg education);

  • Infrastructure concordat – the Government cannot make binding long-term commitments over the whole life of an RSS;

  • They also want the need for community safety infrastructure to be considered – prisons, courts, police and agencies such as drug treatment services (?).

Policy CC6 - Use of Public Land: They have some thoughts about the process for disposing of public land and the role of the likes of the Regional Assembly in that process.

Policy CC8a - Urban focus: They think 60% brownfield is not challenging enough.

Policy 8b and c - Hubs: They challenge the inclusion of Wycombe as a hub.

Policy CC10a – Green Belts: They want the Panel to consider partial reviews of Green Belt.

Policy CC10b - Strategic and local gaps: They consider the RSS policy to be a "blunt tool" and query the 10,000 population criterion in the policy.

Policy CC12 – Character and quality of life: Does this fail the PPS11 tests of regional specificity and adding to national policy?

Para 1.23: They are very sceptical about being able to bring up to 265,000 economically inactive people back into work.

Paras 1.20 – 1.23: They want the Panel to explore the meaning, relevance and application of smart growth to the region and says our policy WCBV5 "contains guidance on smart growth that could usefully be referred to".

Policy RE2 – Employment and land provision: Wants the Panel to advise on indicative economic/employment targets.

Para. 1.7: They are keen that the Plan should be more prescriptive about types of housing.

Para. 1.8: They think the vacancy rate in parts of the region © 2% shows that the housing market is too tight.

Policy H4 – Affordable housing: They want local affordable housing policies to take viability into account, and question the value of a regional target based on a needs assessment.

Transport: Concern that the transport parts of the Plan have been developed bottom-up, via the sub-regional strategies, and that the opportunity for a strategic overview has been missed. They feel the sub-regional sections show little justification for the transport proposals in them. They are "a list of interventions which are not clearly related to the spatial strategy and which have a great deal of information missing". They ask the Panel to consider:

  • whether the RTS objectives are regionally specific enough;

  • the role of demand management;

  • whether the list of schemes is incomplete;

  • whether all the schemes identified are regionally/sub-regionally significant;

  • whether schemes need to be prioritised;

  • whether schemes are affordable (?);

  • whether the Air Transport White Paper has been properly taken into account.

Paras. 1.25 and 1.26: They issue a warning (no doubt of general application throughout the Plan) that it is inappropriate for RSS to challenge Government policy.

Water resources: They would like to see more spatially specific guidance.

Policy W15 – Hazardous waste: They want more detailed guidance, including broad locations for major facilities.

Policy M2 – Recycled aggregates: They want the Panel to test their apportionment to MPAs.

Town centres: They think the chapter:

  • Does not set a clear vision and strategy for growth – it needs to set out strategic choices about centres – where major growth should be encouraged.

  • Does not do enough about community safety in the context of coherent day- and night-time development plans.

  • Conflicts with PPS6 in relation to out-of-town centre development.

Policy TC2 – Town Centres: Their concerns:

  • They want to see more of a hierarchy of town centres;

  • They want to see more guidance on the appropriate scale of development;

  • They want guidance on the roles of individual town centres;

  • They want to make it clear that changes to the strategic network of town centres should be done via revisions to RSS.

Policy S1 – Social inclusion: They want more explicit and spatial content. They use Slough as an example of a town whose deprivation problems might be different to those of an area like, say, Hastings.

Sub-regional comments

This section is prefaced by some general concerns:

  • Alignment between jobs and housing growth at sub-regional and local level;

  • Lack of sub-regional specificity;

  • The need to avoid unrealistic expectations about future infrastructure delivery;

  • Inconsistent approaches to phasing housing development;

  • The appropriateness of the provisions for settlements in the "rest of" parts of the region;

  • Inconsistencies in key demographic and economic evidence.

Turning to the specific comments on the WCBV sub-region:

They want greater clarity on the treatment of the Blackwater Valley, which cuts across sub-regional boundaries.

Policy WCBV 3 – Housing: They question whether the sub-region will meet its housing needs, in the light of the footnotes relating to Wokingham and Basingstoke in this policy. They want contingencies put in place, against the event that these authorities’ worst fears are realised.

Policy WCBV4 – Employment land: They think this blanket policy for retaining employment sites is contrary to the latest PPG3 updates. It needs to be underpinned with up-to-date employment land reviews.

Para. 2.12: They ask the Panel to investigate a serious mis-alignment between jobs and houses in the sub-region.

Policy WCBV5 – Smart economic growth: They see this policy as sub-regionally specific and they cast doubts on its appropriateness. They wonder whether its aim is to depress jobs growth, rather than to increase economic activity. Does it align with the economic growth objectives in the draft RSS and RES?

Policy WCBV6 – Infrastructure: They say the policy has no sub-regional specificity and should be deleted.

Policy WCBV9 – Thames Basin Heaths SPA: They want this investigating as a priority. In particular:

  • Is the Assembly’s assumption that a workable approach to mitigation can be found a realistic one?

  • They want English Nature’s three-pronged approach tested;

  • They want the 16 and 8 hectare mitigation standards tested.

Berkshire authorities’ Joint Strategic Planning Unit

September 2006

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