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The future for the South East is written in considerable detail in the publication ‘The South East Plan – The Secretary of State’s Proposed Changes to the draft Regional Spatial Strategy (RSS) for the South East of England – Schedule of Changes and Reasoned Justification – July 2008’. In this article, we refer to this document as the ‘Changes’. This outlines a regional planning strategy that the Government wants to implement over the period 2006–2020. It is spelled out in 532 pages carrying statutory force. The draft RSS prepared by the South East England Regional Assembly (SEERA) 2003–2006 was examined in public by a Panel of Inspectors in 2006–2007, who recommended changes. The Secretary of State then proposed further changes which are now published for consultation.
Nine sub-regions are identified, all of which will focus on growth or regeneration. In these sub-regions, there are 22 ‘Regional Hubs’, aimed to concentrate investment in multi-model transport infrastructure, new development in health, education, social infrastructure and public services. In the Hubs, general economic growth, market and affordable housing, plus new retail and employment initiatives, will be concentrated. Within Surrey, there will be an emphasis on an urban focus and renaissance. The part termed ‘The London Fringe’ will have 3 Hubs: Woking, Guildford and Redhill/Reigate. To the south, Gatwick/Horley is the ‘International Gateway Air Hub’. Of the 3m national target of homes, 662,500 (22%) will be found in the region. Allocated to Surrey is an absolute 59,000 dwellings, up from 35,400 in the draft RSS. If this pattern of growth is achieved, consequential, unsustainable pressure will be loaded onto the space in Surrey.
Attack on the Green Belt
On top of the channelled growth and pressure, a detailed pattern of development has to be squeezed into the populous acres of Surrey, which contains 73% of the land subject to the safeguarding policy of the Metropolitan Green Belt (MGB). The Changes to the RSS retains Green Belt policy, its continuation and support is emphasised, although allowance is made to permit selective reviews of the MGB to the NE of Guildford, and smaller scale reviews to other locations in Surrey through the Local Development Framework (LDF) process. The contradiction implicit in the retention of the Green Belt policy, with also the promotion of widespread housing development, is to be seen in the emerging Mole Valley LDF. This has to provide 3,760 homes, or 188 per annum, to be delivered over the plan period. Out of the 307 dwelling units proposed on the Strategic Housing Land Availability Assessment (SHLAA), around the margins of Dorking, the Society has identified site development for 185 dwelling units (60%), which are within designated Green Belt or the extant AONB’s/AGLV’s.
At the heart of the argument in the ‘Changes’ is a less than convincing case to show why so many new dwellings are needed. The reasoned justification seems merely to conjure up numbers by a simplistic arithmetical exercise to determine allocation at district level. The query is whether these homes would realistically meet social as well as economic demand in terms of affordability. In the document, complicated reasoning is obscured by simple statements. There are reservations as to the limitations of the bottom-up, ‘evidence-based underpinning’, used in the allocation arithmetic. For example, the assertion that long term affordability is worsening draws on average house prices nearly being trebled, and average first-time buyer deposits rising from £5,134 to £42,930 in the 10 years from 1995. Despite the admitted limitations of the available technical data, and the absence of reasoning for a downturn in the market housing circumstances, the document goes on to state that long-term affordability must be based on increasing the supply of homes, on “commonsense grounds if nothing else”. Further exaggeration is evident when the document states that Policy H1 numbers are to be treated as a minimum.
The extraordinary increase in the housing target has been rejected by many who are versed in the planning of the region, and these are summarised in the words of the past Chairman of SEERA – Keith Mitchell – who (referring to the increase to 662,500 of new dwellings planned for the region) states that the increase “has no credibility”, especially at a time when the current disruption of the house building industry is in full play. Keith Williamson, of the National Housing & Planning Unit, set up by the Government to ensure that regional and district dwelling targets are substantially raised, states that his unit’s advice offers a minimum and maximum spread of numbers of homes which must be contemplated for delivery if affordability is to be stabilised. The Government drive to manipulate the planning process has been revealed, however, when the spectacular decline of the housing market has shown up the fragility of assumptions based mainly on demographics. Matters of sustainability and adequacy of infrastructure are not properly dealt with. The impact of this volume of homes to be delivered in the region will be felt in every district, and will inevitably lead to the broad excision of land in the Green Belt and protected landscape areas.
This centralised edict to deliver homes using the planning process must be challenged. Space and density of use is a major consideration of sustainability. Of the pressures on the region, the projected growth in population, economic activity and car ownership will generate demand for more road space. Within and around the margins of Dorking, the proposed identified sites in the SHLAA add to potential points of severe traffic congestion in the future. It is already very evident that the local road structure is overloaded with parked cars, mainly from incommuting, significantly reducing road space. A widespread burden of this kind applies across the region, because a diverse pattern of employment is a reflection of today’s economy. The SE Plan has to deal with the pulling power of the region in attracting net migration, which seeks destinations that have been concentrated there. The national homes targets now imposed do not deal with this segment of demand which, in a forecast rise of a 10 million increase in the UK population by 2028, has a migration component of 7 million.
Even allowing for uncertainty in accurately forecasting population growth for planning purposes, the very exercise of setting down a national target of new homes, then projecting this to subregions and districts is laden with inaccuracy.
To further place pressure on individual districts, the Government has announced the ‘National Housing and Planning Delivery Grant’ which will be doled out to reward those councils which deliver more homes and the land to build them on. A good proportion of these Grants will be dependent on the Local Development Framework (LDF) Core Strategies and Development Documents being issued and adopted, and will only be allocated if at least 2,000 new homes are delivered in the future. The way the Government will act is to ensure that the Planning Agency’s Inspectors, in ruling on the soundness of LDF Core Strategies in their enquiries, will make clear that an adequate housing provision has been given priority if the LDF is to be found to be sound.
These centralised processes will lessen the democratic influence of the electorate to decide the form and detail of residential development in their districts. It is a damaging measure for the Government to override this responsibility and, in doing so, will end up causing great damage to the long standing protection offered to our countryside that has been essential in saving and maintaining its beauty and character. The Society has opposed the emerging Core Strategy of the Mole Valley LDF, and will have prepared the evidence to support this opposition at the statutory inquiry when this convenes sometime next year.
Derek Rowbotham
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