Hampshire County Council Item 7

31 March 2005

261: Draft South East Plan - Response to Consultation

Report of the Cabinet

Contact: Debbie Vaughan, ext 7330, e-mail: [email protected]

With the concurrence of the Chairman under Section 100B (4)(b) of the Local Government Act 1972, this matter has been included on the agenda to enable the latest information available to be brought to the attention of Members.

1. Summary

1.1 The County Council has been consulted by the South East England Regional Assembly (SEERA) on the draft South East Plan, as part of the public consultation which ends on 15 April 2005. This report sets out the background to the consultation and seeks agreement for the content of the County Council's response.

2. Background

2.1 A new system of spatial planning was introduced as a result of the 2004 Planning and Compulsory Act which requires that a Regional Spatial Strategy (RSS) be produced for each region; the South East Plan being the RSS for the south-east. The Strategy will provide the statutory regional framework for development to 2026 and is designed to integrate policies about development with wider matters such as education and training, health and social issues. It is due to be finalised in 2006 or 2007 and will replace both the Regional Planning Guidance (RPG 9) and the existing Hampshire Structure Plan.

2.2 On 28 October 2004, Members of the County Council considered reports on the South East Plan Sub-Regional Strategies, and on the Central Hampshire and New Forest area along with a detailed presentation, and submitted its advice to SEERA. Members expressed a number of key concerns including the central importance of the quality of life of Hampshire residents; the need for growth to be accompanied by investment for adequate infrastructure - roads, rail, water supply and sewerage - as well as in schools and hospitals; strategic gaps; affordable housing; and certain local issues.

3. Consultation

3.1 The County Council has been consulted on a suite of South East Plan items comprising the Core Document which sets out the context, vision and strategy options together with the draft regional and sub-regional policies, a draft Sustainability Appraisal, an Implementation Plan, and proposals for Indicators and Monitoring. These documents are available in the Members' Rooms and can also be viewed on SEERA's website at www.southeast-ra.gov.uk/southeastplan.

3.2 As part of the consultation process, SEERA commissioned a region-wide public opinion survey through MORI, distributed a leaflet-based questionnaire to all households in the Plan area, and asked the principal authorities including Hampshire County Council, to put in place arrangements to ensure effective local consultation was undertaken. The County Council has conducted this by way of:-

· setting up, and participating in, a range of public and stakeholder events;


· as part of the campaign, distributing a special edition of the "Hampshire Now" magazine to approximately 530,000 households advising them of the draft Plan content and consultation arrangements, and incorporated a public opinion survey questionnaire encouraging residents to respond;


· initiating a campaign entitled "Holding out for Hampshire" to raise public awareness of the consultation and the potential impacts of the draft Plan on Hampshire;


· commissioning independent consultants, Chris Blandford Associates, to report on how the draft South East Plan will impact on the quality of life of Hampshire communities; a key concern identified by the County Council in October 2004.

In addition, Hampshire County Council along with six other members of the South East County Leaders' Group (Buckinghamshire, East Sussex, Kent, Oxfordshire, Surrey and West Sussex plus the neighbouring unitary authorities of the former Berkshire area) jointly commissioned an extensive public opinion survey from pollsters ICM, aimed at capturing more detailed local opinion, and included specific questions for the two sub-regions that fall within Hampshire. This survey was conducted by telephone with over 8,000 residents across the south-east being contacted. The ICM poll results indicate that Hampshire residents support the stance the County Council has taken to date; the key findings are as follows:-


· the majority of respondents want house building levels at, or below the proposed lowest option (i.e. 25,550 per year), with new housing meeting the needs of the south-east population;


· 20% of respondents (mainly young people in rented accommodation) considered the proposed middle range option of house building was appropriate (i.e. 28,000 per year);


· identified transport, roads and health as important infrastructure improvements, but indicated a low level of confidence across Hampshire and the south-east that such improvements would keep pace with housing growth; and


· showed a high level of support for new infrastructure to be paid for by contributions from developers above other options.


The closing date for the return of the special edition Hampshire Now questionnaire is 30 March 2005 and to date the level of response is thought to have been exceptional, possibly in excess of 15,000 questionnaires being received. The outcomes will be presented to the County Council on 31 March 2005, however early indications are broadly in line with the ICM poll findings.

3.3 This matter was considered by the Cabinet on 21 March 2005 with the recommended response to SEERA being commended to the County Council for consideration on 31 March 2005; a decision which supports Aims 2, 3, 4 and 5 of the Corporate Strategy (Stewardship of the environment, Achieving economic prosperity, Building strong and safe communities and Improving services) by helping to ensure that Hampshire's environment, economic prosperity, services and infrastructure are safeguarded in the final South East Plan.

3.4 Further background reports will be made available on the public opinion surveys and the Quality of Life study, and additional information will be supplied at a special briefing meeting prior to the commencement of the formal business of the County Council on 31 March 2005.

Recommendation

That the County Council agrees the content of Appendix 1 (attached) as the County Council's response to the draft South East Plan.

APPENDIX 1

CONSULTATION DRAFT SOUTH EAST PLAN

RESPONSE OF HAMPSHIRE COUNTY COUNCIL

NB: Data from the South East Counties poll, the County Council's own questionnaire and the Quality of Life report will be presented to Members prior to final determination of the County Council's response to the South East England Regional Assembly.

Strategy and overall content

1. The consultation draft South East Plan lacks a coherent, soundly-based overall strategy, is pre-occupied with the issue of housebuilding to the detriment of other important topics and fails to provide an adequate framework for the preparation of Local Development Documents.

2. The technical basis for the scale of development proposed in the strategy options is the demographic projections produced by the Office of National Statistics (ONS). These are trend-based, i.e. they assume the past rate of change will continue into the future. A planning strategy should decide the appropriate future rate of change, not unquestionably accept and maintain past trends. Even if this approach were to be accepted, the trend projection includes a substantial level of migration into the South East from abroad; this is a questionable basis for future planning in view of the Government's stated intentions to reduce the number of overseas migrants.

3. Major concerns remain over many of the assumptions underpinning the technical work on water (as set out in the report to SEERA from the Environment Agency and water companies in September 2004) which has fed into the preparation of this draft Plan. Whilst such scenario modelling is a major step forward for a spatial planning document, it remains full of uncertainties and assumptions that make the bold opening sentence of Policy NRM1 less than convincing. Particular concerns include ignoring growth scenarios in adjoining administrative areas even though they may draw on the same water resources available in the South East, the assumptions made on climate change and demand management/water efficiency, and ensuring that adequate new water infrastructure will be developed in a timely and sustainable manner.

4. The two distribution options - continuing current policy (i.e. Regional Planning Guidance (RPG)) or a variant on this called `sharper focus' - are equally flawed. The RPG housing distribution has no sound technical foundation, being a set of figures compiled as a political compromise when the RPG was finalised. To base a strategy looking 20 years ahead on such shaky foundations is indefensible and perpetuates the technical weakness.

5. The preparation of an inaugural Regional Spatial Strategy represents a tremendous opportunity to start from first principles and think radically and widely about how the Region should change and grow up to 2026. Disappointingly, the consultation draft Plan has settled for a timid set of variants of the existing strategy. Options to seriously address regional economic disparities, to consider the balance of development across the Region, to focus development around the major new infrastructure have been left unexplored.

6. A strategy needs to be formulated and included in the next version of the Plan, which is economy-led, addresses economic disparities and prioritises regeneration, clearly articulates the new infrastructure required and how the pace of development will be related to infrastructure provision, and provides for the housing and social needs of the South East whilst maintaining the environment and quality of life.

7. The document fails to provide a coherent comprehensive strategy in view of the absence of any spatial dimension to the economic / employment policies and the lack of information on major infrastructure required to serve new development. Apart from failing to give adequate guidance to Local Development Frameworks on the location of new employment and infrastructure, these shortcomings undermine the credibility of the housing proposals. It is now widely acknowledged that the strategic planning of new housing cannot satisfactorily be undertaken without knowing the location of employment growth and without relating it to major infrastructure. With the exception of the retired, employment determines population growth/movement, while from a sustainability point of view it is desirable to plan housing in close proximity to jobs.

8. No clear analysis is provided in the draft Plan of the key drivers of change in the South East, nor the characteristics, potential and opportunities of the Region. The strategy options for the region and the sub-regional strategies appear isolated from each other, and with no attempt to identify links or trade-offs between the sub-regions. No explanation is provided to justify the division of the region into the chosen sub-regions nor any attempt made to link these with the housing market areas identified earlier in the Plan and defined as "the areas of search considered by the majority of households". In addition, the introduction to this section does not clarify the scope of the original brief and therefore explain their subsequent focus on development.

9. The chapters on the sub-regions are written in a different, more stylised, planning language from the rest of the document and lack consistency. Most importantly there is no attempt to consider the various proposals as a whole instead of simply as isolated parts.

10. Many of the regional policies lack clarity and direction and do not provide an appropriately detailed framework for the development of policies in the forthcoming Local Development Documents. Most have little or no region-specific dimension and add little to existing national planning guidance. The current draft document requires substantial development if it is to be made `fit for purpose'; it is unlikely this can be done in the short period between the close of consultation and the submission of Part One to the Government this summer.

11. A lot of these shortcomings may reflect the deadline set by the Government for plan preparation, compounded by the Regional Assembly's decision to voluntarily add an additional stage of public consultation. Concern about the timetable and the resulting inadequate time for political engagement and stakeholder involvement, has been aired repeatedly by this County Council and others. The quality of the `product' has also suffered as a consequence of insufficient time for sound technical work and strategy formulation, while tasks which ought to have been undertaken sequentially (e.g. regional and sub-regional strategy preparation) have had to be undertaken in parallel.

12. This has impacted too on preparation of the accompanying Sustainability Appraisal (SA), which is a wholly inadequate document. The region wide options and policies in the draft plan show no real connection with, or influence from, the SA process, while the SA document admits that the sub-regional strategies/policies have not yet been assessed at all. These deficiencies will need to be addressed by the time the revised and final versions are produced in summer and autumn 2005 respectively. The final version will need to show greater influence over emerging and final option selection. There is a risk that the requirements of the SEA Directive are not being met because of the lack of any early appraisal, influencing and assisting with identifying and modifying key issues. This leaves the process open to legal challenge.

13. It must be said that the preceding analysis demonstrates the need for a sub-regional tier of strategies, prepared subsequent to and within the framework, of the regional strategy. This would enable regional resources (officer and Member time) to be focused on region-wide issues, delegating sub-regional matters to the sub-regional level. It would enable a slimmer regional document to be produced, and avoid the confusion and discontinuity which has arisen from regional and sub-regional strategy development proceeding in parallel. The sub-regional strategies for Ashford and Milton Keynes/South Midlands are proceeding to different timetables from the draft South East Plan; there is no reason why the other sub-regions should not be dealt with in the same way. The opportunity still exists for the Regional Assembly to switch to such an approach; progressing forward with the region-wide strategy and policies, but pausing the sub-regional work so that attention and resources can be concentrated on the former. Continuing down the current path will be to the detriment of both.

Infrastructure

14. Development must be accompanied by the provision of adequate new infrastructure, while the pace and scale of development must be conditional on infrastructure provision. Firm commitments are needed from central Government on increased infrastructure funding, to serve new development and to tackle the investment backlog.

15. Policy CC4 which was inserted into the draft Plan at the instigation of West Sussex County Council to articulate the above principles, is strongly supported. The research by Roger Tym & Associates makes the case for a step-change in infrastructure investment in the South East ( more to be added when their final report is available). The Deputy Prime Minister's statement at the launch of the Sustainable Communities - Homes for All document, that "responsible growth also means providing infrastructure" is a welcome endorsement of the case. Recently completed research by pollsters ICM for the South East Counties reveals that in both Hampshire and the Region as a whole, there is far greater public acceptance of new development if infrastructure provision will keep pace with it.

16. The next version of the South East Plan must clearly set out the mechanisms for phasing and managing land release to match infrastructure provision, as well as itemising the major infrastructure schemes required. One way of achieving this would be to divide the development provision into say, five year tranches, the release of which will be dependent on adequate infrastructure provision/funding commitment. Development in some specific locations may also be conditional on individual infrastructure schemes. This would help reassure public doubts that infrastructure provision will keep pace with development. (The ICM poll mentioned above, showed that 60% of South East residents and 56% in Hampshire are not confident this will occur.)

17. Related to this, is disappointment that the transport chapter adds very little to the already approved Regional Transport Strategy, despite the draft Plan's proposals for major development looking twenty years ahead. Several of the proposed new transport policies are vague and lacking in sufficient detail to enable local authorities and others to understand them fully. The County Council had hoped that the Regional Assembly would have used the 18 months since the public examination into the RTS to develop these concepts into a level of detail where they could be implemented more easily.

Economy and employment

18. The economy section of the draft Plan is inadequate. The draft policies fail to consider the likely demand for different types and locations of new employment, and are an inadequate framework for the preparation of Local Development Documents.

19. ODPM research stresses the importance of assessing the potential supply of commercial employment sites in order to test the quantity, quality and location in comparison with current commercial business criteria. Such a comparison is a vital component to regional planning policies due to the pace of commercial change facing all European economies as business adjusts to global market changes.

20. The draft polices should set out the amount and general location of employment development to be provided for in Local Development Documents. There are several ways to do this, such as an employment land provision figure for each District or identifying the general location of strategic sites, in tandem with policy guidance on the quality and type of employment development. In the absence of such policies, it is impossible to plan housing and employment in an integrated way, and impossible to assess and deal with the traffic impact on the strategic transport network. Experience in Hampshire shows the difficulties of promoting a strategic employment site in a Local Plan unless already included in the strategic planning document. For these and other reasons, Hampshire district councils called for such policies to be included in the erstwhile roll forward/review of the Hampshire Structure Plan.

21. The fact that within the `Economy and Tourism' chapter there are seven policies on tourism but only four about the economy, bears testament to the economic policy deficit. Expanding and strengthening the economic component of the Plan would help dispel the impression that the document is largely a strategy for housebuilding, and would provide a coherent and robust basis for a strategy-led South East Plan.

Strategy options and housing

22. The housebuilding target for Hampshire, including Portsmouth and Southampton, should be no more than 6,000 new homes per annum up to 2026, which is a large share of any likely region-wide total and provides for significant in-migration as well as meeting all indigenous household growth. The draft Plan's target for 35-40% of new homes to be affordable is supported, but its achievement will require a substantial increase in Government funding.

23. In the year 2003/04, some 6,700 new homes were built in Hampshire and, thanks to the proactive actions of the local authorities, the county is on course to meet its RPG target of 6,000 new homes per annum 2001-2011. This is the highest rate of housebuilding of any county in the South East. In the last two decades, Hampshire's population grew by 16%; a higher rate than most other parts of the Region.

24. This represents a substantial contribution towards meeting the Region's housing requirement. Indeed, it could be argued that it is a disproportionately high share of the Region's total housebuilding. Continuing this rate of housebuilding would provide for all of the forecast increase in Hampshire's indigenous household growth and also provide for net in-migration. Therefore the County Council considers that 6,000 new homes per annum in Hampshire, including Portsmouth and Southampton, is the appropriate rate to incorporate in the South East Plan. This reflects the view of the majority of Hampshire people (65% in the ICM poll for the South East counties) that the amount of new housing should be limited to that needed by the existing population.

25. The County Council calls for the following rates of housebuilding in the South East Plan:-

(i) South Hampshire Sub-region: 3,600 per annum;

(ii) Hampshire part of Western Corridor and Blackwater Valley Sub-region: 1,400 per annum; and

(iii) Rest of Hampshire: 1,000 per annum.

26. The three figures above constitute a `sharper focus' on the two sub-regions with a slight shift in housebuilding to them from the rest of the county. The proposed figure for South Hampshire is a 12.5% increase on the rate of housebuilding (1996 - 2004). The proposed figure for the Hampshire part of Western Corridor and Blackwater Valley Sub-region is about the same as the sub-region's estimated Regional Planning Guidance figure but would mean a 22% increase on the recent past rate of housebuilding.

27. The proposed figure of 1,000 per annum in the `Rest of Hampshire' is a slight reduction in the recent past rate of housebuilding. It would strike a balance between providing sufficient affordable housing on the one hand, yet avoiding unacceptable environmental impacts on the other.

28. In all three areas, additional land would need to be earmarked for development over and above existing allocations and expected urban capacity.

29. The 20 year housing figures in the current draft Plan need to be split into phases of, say, five years. The release of each phase in each part of the Region would be dependent on infrastructure provision/funding commitment (see paragraph 16) and economic growth. Such a mechanism would also enable the principles of `Plan Monitor Manage' to be applied, such that the release of greenfield sites in each sub-region can be triggered or deferred to take account of emerging urban capacity. Whilst each individual local planning authority will do this within its own administrative area, a mechanism is needed within the South east Plan to enable unexpected urban capacity in one authority to obviate the need for greenfield land release in a neighbouring authority. Such an arrangement is a requirement of PPG3.

30. Rapidly rising house prices (up 60% in Hampshire 1999-2003) mean a growing need for affordable housing. In six Hampshire Districts, a first time buyer on average wages needs a mortgage of 7-8 times their annual income to buy an average-priced property. This is well above the regional average of 6.

31. Hampshire local authorities have estimated that over 35,000 people are in need of affordable housing: at current rates of affordable home construction (2,000 per annum) it will take 18 years to provide affordable homes for all these people.

32. The importance attached by the draft South East Plan to affordable housing provision and the regional target of 35-40% of all new house construction being affordable, is therefore strongly endorsed. Achieving this target will however require a substantial increase in Government funding for affordable housing provision.

Environment and quality of life issues

33. Countryside, biodiversity, climate change and coastal policies need to be further developed, and there is insufficient attention in the draft Plan to quality of life issues.

34. It is disappointing and a matter of concern that there are no policies in the Cross Cutting chapter on the character of the environment, local distinctiveness and importance of quality of design in development. Such matters are fundamental to the quality of life in the region and contribute significantly to the region's economy and its attraction as a place to live and work. Instigation of such a policy would help raise the standing of environment related issues to its proper place in the plan.

35. The draft Plan rightly protects the countryside for its nature conservation and landscape value, and as a means of preventing the coalescence of settlements. However, it gives too little attention to the countryside as a recreational resource and to the benefits that countryside and other open spaces provide to people's quality of life and an area's attractiveness to business inventors. It also has too great a focus on designated landscapes and nature conservation sites at the expense of other areas which do not have such status.

36. The importance of biodiversity is recognised in the contextual text, but the draft policies need further development and additional detail. In particular, there is a lack of clarity on how the new concept of `Area of Strategic Opportunity for Biodiversity' will be implemented.

37. Similarly, although the draft Plan identifies climate change as a cross-cutting issue, the policies and supporting text need strengthening.

38. The document focuses heavily on housing, employment, transport and other traditional land use planning issues, with too little attention given to the other topics which should be dealt with in a spatial plan, including social, cultural and health matters. Unless this balance is redressed, the County Council fears that too little consideration will be given to wider quality of life issues and the realisation of truly sustainable communities.

(Key conclusions from the quality of life research commissioned by HCC from Chris Blandford Associates to be inserted here, once available).

Implementation Plan

39. Examination of the Implementation Plan reveals it is not a draft Implementation Plan as such, but merely describes the scope of the eventual document.

40. Much of the proposed content would appear to address some of the most pressing concerns about past under investment, inconsistencies between Government policy and advice, timely future investment, the balance between public and private investment and so on. It is not possible, however, to come to a view on how effectively the Implementation Plan will deal with these matters without a draft of the Implementation Plan itself. Although what has been provided is a useful first step, it would have been more helpful if the Assembly had indicated how it proposes to deal with the issues rather than simply stating that these will be published at a future date. The County Council intends to comment further on this when a draft Implementation Plan is available.