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ASSOCIATION OF HAMPSHIRE AND ISLE OF WIGHT LOCAL AUTHORITIES
29 January 1999
DRAFT REGIONAL PLANNING GUIDANCE FOR THE SOUTH EAST: CONSULTING THE PUBLIC
Joint Report by Tim Greenwood, Hampshire County Planning Officer and Robin Smith, Chief Executive, Havant Borough Council.
In May 1998, the London and South East Regional Planning Conference (SERPLAN) published, for consultation, a draft development strategy for the south east covering the period up to 2016. Comments on the draft strategy were sought by 24 July 1998. The Association considered the matter at its meeting on the 24 July 1998. Whilst supporting the general thrust of the strategy various changes were recommended which would, in the opinion of the Association, make the translation of the proposed regional framework into structure and local plans more straightforward.
SERPLAN considered proposed amendments to the draft document at its meeting on the 29 October 1998 and approved a final version which has now been submitted to the Secretary of State for the Environment. The Strategy has now been formally placed on deposit. Comments are sought by the 12 February 1999.
The Regional Planning Guidance will help to steer the future of the South East over the first fifteen years of the new millennium. The Draft aims to promote a sustainable pattern of development, movement and conservation in the region. In seeking to find a suitable balance between development and conservation, the Guidance has had to address crucial matters such as:
transport and land use solutions which reduce the reliance on the car;
The Strategy proposes a distribution of dwellings , by county, for the period 1991-2016. The figure for Hampshire of 130,300 additional dwellings provides the justification for the figure of 42,000 dwellings being considered for the Hampshire County Structure Plan (Review) for the period 2001-2011.
This report considers the draft Guidance in the light of the Association's response to the earlier consultation document and recommends a response.
That the Panel appointed to examine "A Sustainable Development Strategy for the South East" be advised that the Association:
(i) reaffirms the points raised in its earlier response on the consultation draft document, attached as Appendix 1;
(ii) supports the identification of South Hampshire, including the two cities of Portsmouth and Southampton, and the Isle of Wight as Priority Areas for Economic Regeneration;
(iii) supports the inclusion of the South Hampshire Rapid Transit System; the identification of the south coast corridor (Southampton- Folkestone) as a priority corridor for multi-modal transport investment; and the improvement of ferry services to the Isle of Wight;
(iv) considers that the proposed housing distributions 1991-2016 are a reasonable interpretation of the strategy and the needs of the sub regions in Hampshire and the Isle of Wight;
(vi) is concerned that the draft Strategy should more closely reflect the needs of the Association's area in relation to the following matters and requests that these should be addressed at the public Examination:
(a) that the draft Strategy, both in its form and content, should provide clearer and less ambiguous guidance for development plans, particularly in relation to levels of development and conservation priorities at the sub-regional level;
(b) that the significant areas of countryside comprising central Hampshire, the New Forest and the Isle of Wight should be identified and protected as having significance in the Regional context;
(c) that the 'plan, monitor and manage' approach to housing provision should be examined to assess whether it is workable in practice or if there are more appropriate mechanisms for ensuring that plans do not over-commit authorities to development in the short to medium term but are able to respond quickly to changing demands in the medium to long term;
(d) that the important north/south transport corridors through Hampshire for road and rail, passenger and freight and centred on the A3 and M3/A34, should be recognised and identified for improvement, including the resolution of the A3 bottleneck at Hindhead;
(e) that more specific recognition should be given to the role of regional airports, including Eastleigh Airport, in reducing the pressure on the three London Airports;
(f) that more specific recognition should be given to the importance of the long-term vitality of the ports of Southampton and Portsmouth; and
(g) that the policy advice for car parking needs to be more explicit to ensure a consistent approach across the Region and should be included within a headline policy in the light of its significance to sustainable transport.
1.1 Over the last four years SERPLAN has been evolving a new land-use transportation strategy for the region. The intention is that this new strategy would be recommended to Government as a replacement for the existing regional planning guidance (RPG9). During the time that the new strategy has been in preparation, changes have taken place in the way that government becomes involved in the process. In the past translating the advice offered by regional planning conferences into formal regional planning guidance has been criticised for the lack of open and widespread consultation on the process. The situation has now changed. The guidance devised by SERPLAN is now on deposit for a period of six weeks. The comments on the Guidance will be scrutinised by an independent Panel which has already been appointed by the Secretary of State. The Panel will identify a number of key issues which it believes warrant close public examination and organisations which it believes have ideas and opinions which would help that examination. These organisations will be invited to attend a public examination where differences on matters of substance will be aired and debated
1.2 The public examination is scheduled to begin on the 18 May 1999 and last for four weeks. It is not clear what role, if any, individual local authorities will have at the Examination. It is expected that the Panel conducting the Examination will report to Government in the autumn. The revised Regional Planning Guidance (essentially the deposit Strategy amended in the light of government's reaction to the Panel's report) will be published towards the end of the year.
2.0 SUMMARY OF ASSOCIATION'S RESPONSE ON THE DRAFT SERPLAN DOCUMENT
2.1 The Association considered SERPLAN's draft revised regional planning guidance last July. A copy of the Association's response to the SERPLAN draft is attached as Appendix 1. While welcoming the emphasis on urban renaissance and the closer integration of housing, employment and transport it made numerous detailed comments. These comments were aimed, on the one hand at improving the ease with which the strategy could be translated into local development plans; and on the other hand enhancing regional support for proposals of particular concern to Hampshire and the Isle of Wight.
2.2 In summary these comments sought:
a clearer geographic interpretation of the Strategy, with greater clarity on the "core area" policies;
more explicit details of the scale and priorities for jobs, homes, transport and other infrastructure in the sub-regions identified in the strategy;
the highlighting of regionally significant areas of countryside such as central Hampshire, and particular recognition to the New Forest and the Isle of Wight;
more research on how best to meet housing need, including fiscal measures to support the re-use of urban land rather than greenfields;
support for a variety of local transport schemes and initiatives; and
more explicit policies for seaports, airports and car parking.
3.0 THE DEPOSIT STRATEGY
3.1 Although there have been numerous minor amendments to the text and layout the deposit Strategy is, for the most part, similar to the consultation draft. The main chapters and sections where significant alterations have been made are summarised in Appendix 2.
3.2 Comments have been sought by the Panel which has been appointed to conduct the consultation on the draft Strategy. The comments will be used to frame the issues to be discussed at the public examination.
3.3 In the knowledge that individual authorities may wish to comment on some of the detail in the draft Strategy, these comments focus on the matters of principle raised in the Association's earlier comments. These comments are summarised in paragraph 2.2
3.4 Greater clarity in the core area policies and the priorities for homes, jobs and infrastructure. The core objectives of promoting an urban renaissance and concentrating development to help the development of balanced communities and promote a switch from the use of the private car to other, more environmentally friendly forms of travel should continue to be supported. They chime with the policies that the planning authorities in Hampshire and the Isle of Wight have been pursuing for many years. The challenge is now for local planning authorities to implement the draft Guidance.
3.5 Nevertheless, the concern remains that, as drafted, it would prove difficult to translate the worthy aims of urban renaissance, economic regeneration and sustainable development into detailed development plan policies at a county and district level. Although some changes have been made, particularly to the Spatial Implications Chapter, the draft Strategy still fails to give a clear direction about how particular development or conservation matters referred to in the Strategy should be interpreted at the local level. Most importantly there is no clear guidance about the strategies for the areas dealt with in the Spatial Implications chapter. How, for example, are the policies for economic regeneration in South Hampshire or for coping with economic pressure in northern Hampshire to be interpreted in terms of the limits (if any) to be placed on development?
3.6 The Panel should therefore to examine the provision of clearer and less ambiguous guidance for development plans, particularly in relation to levels of development and conservation priorities at the sub-regional level.
3.7 Significant areas of countryside, central Hampshire, the New Forest and the Isle of Wight. The Spatial Implications chapter deals simply with the economic strands of the strategy. Although the important influence of economic policies in shaping the future pattern of development in the region should not be under-estimated, it is equally important that broad environmental policy areas which also have spatial implications warrant an explanation in the Strategy. Beyond the Green Belt and Areas of Outstanding Natural Beauty there are broad areas of coast and countryside between major built-up areas which warrant protection for their own sake. There are also areas with a unique importance for nature conservation and landscape which warrant special treatment, if only to stress the impact that these areas will have on future decisions about growth and development. These areas of coast and countryside remain as significant to the future of the region as urban renaissance is to the urban areas and economic development to the priority areas for economic regeneration.
3.8 The Panel should be asked to examine the highlighting and protection of regionally significant areas of countryside beyond the green belt including central Hampshire, the New Forest and the Isle of Wight.
3.9 Meeting housing need and supporting the re-use of urban land. The draft Strategy includes a new section on 'Meeting housing needs'. This section deals with more than simply the question of overall numbers and distribution. It also sets out the measures that SERPLAN believes are vital to ensure that the housing provision policies, including those for affordable housing, are fully effective; and how the 'plan, monitor and manage' approach will be applied to ensure that appropriate levels of development take place in the right place at the right time.
3.10 It is the headline housing distribution figures that always seem to grab the centre stage in any debate on strategic planning. Despite the government's much heralded conversion to a "plan, monitor, manage" rather than a "predict and provide" approach to strategic planning, it is the housing numbers which, once again, look as if they might steal the headlines to the detriment of the debate on the basic development strategy.
3.11 The methodology used by SERPLAN to devise the housing distribution would not appear to be based on a consistent methodology across the region. Nevertheless, from a narrow Hampshire perspective the figure proposed for Hampshire (including Portsmouth and Southampton) is generally consistent with contemporary projections of need. The figure, 130,300 additional dwellings 1991-2016, provides the justification for the figure of 42,000 being considered in the Hampshire County Structure Plan (Review) for the period 2001-2011.
3.12 The measures identified by SERPLAN to ensure the successful implementation of housing provision are either the subject of existing research by the DETR or require changes in legislation and/or planning policy practice. All the measures are worthy of support. However, there are potential difficulties with the 'plan, monitor and manage' approach when considering how to 'manage' the situation if and when monitoring demonstrates that there is a problem with part of the plan.
3.13 SERPLAN suggests that all structure plans and UDPs should be reviewed and adopted within thirty months and all local plans within fifty four months of the Strategy being approved by Government. However, by their nature, changes identified through a monitoring process are sudden and unexpected. They either re-inforce the policy packages which are in place or require immediate changes to prevent unwarranted outcomes. It is a moot point as to whether the present planning system is capable of reacting in the manner that the SERPLAN approach requires.
3.14 Another issue for the Panel should therefore be to consider if the 'plan, monitor and manage' approach advocated in the Strategy can be delivered effectively and if there are other measure which might be more successful in ensuring that plans do not over-commit authorities to development in the short to medium term but are able to respond quickly to changing demands in the medium to long term.
3.15 Support for selected transport schemes and initiatives. The Association offered two lists of transport improvements that it would wish to see included the draft Guidance. The first list contained a number of schemes aimed at easing congestion and facilitating movement within the sub-regions in Hampshire and the Isle of Wight. The second list dealt with improvements to links between sub-regions and the rest of the Country.
3.16 One of the limitations of the theme-based approach adopted in the Strategy is that it is sometimes difficult to gauge the full extent of policies dealing with particular subjects. Transport is a case in point: with "policies" included in the core strategy chapter, the sustainable transport chapter, the opportunity and equity chapter and the spatial implications chapter. The corridors identified as of national and regional priority, although shown on the key diagram, are only referred to in the supporting text.
3.17 Some of the proposals specifically mentioned by the Association in its response to the consultation document appear somewhere in the text (e.g. the South Hampshire Rapid Transit, improved ferry services to the Isle of Wight and transport links eastwards to the Channel Tunnel). Others are picked up in the broadly-defined priority transport corridors (e.g. public transport access to Heathrow and Gatwick). There is, however, no mention of improving the A3 at Hindhead and the improvements to rail freight links from Southampton to the Midlands is relegated to a reference to an on-going study.
3.18 The Panel should be asked to examine the inclusion of the important north/south transport corridors through Hampshire for road and rail, passenger and freight and centred on the A3 and M3/A34. These should be recognised and identified for improvement, including the resolution of the A3 bottleneck at Hindhead.
3.19 More explicit policies for airports, seaports and parking. The draft Strategy provides little additional detail on these matters. Policy ST4 recognises the benefits to local and regional economies from seaport expansion and "their potential role in many of the priority areas for economic regeneration". There is, nevertheless, no specific references to either Portsmouth or Southampton: either the role that they play now or the role that they should play in the future.
3.20 The Panel should be asked to examine giving more specific recognition to the importance of the long-term vitality of the ports of Southampton and Portsmouth in view of their regional and national significance.
3.21 While seeking to reduce the demand for air travel (and avoiding prejudicing the case of SERPLAN authorities at current and future public inquiries into specific proposals airport expansion) the strategy also recognises that there may be "considerable effects on the regional and national economy if demand (for air travel) is unmet". There is no recognition of the possible role of the regional airports in reducing the pressures on the three London airports.
3.22 The Panel should be asked to examine the need to give more specific recognition to the role of regional airports, including Eastleigh Airport, in reducing the pressure on the three London Airports.
3.23 The role of car parking policies in managing the demand for car-based trips has been deleted from the headline Policy ST8. References to managing parking demand have been relegated to a "policy point" for action by local authorities.
3.24 The Panel should be asked to examine giving more explicit policy advice for car parking to ensure a consistent approach across the Region in the light of its significance to sustainable transport.
3.25 Key Diagram. There are a number of inconsistencies between the policies contained in the various policy themes and their representation on the key diagram: for example the south coast corridor (Southampton-Folkestone) (multi-modal) appears to extend westwards across the New Forest. While recognising that the Key Diagram is purely diagrammatic, it is important that such glaring anomalies are rectified in the final Strategy document.
3.26 Finally, it would be helpful for the Panel to be provided with a copy of the Association's report and resolutions on the consultation draft. The report would provide the Panel with the background context to the Association's comments on the deposit Strategy. The report was concise and should not overburden the Panel with paperwork.
1. A Sustainable Development Strategy for the South East: Public Consultation (SERP 400), SERPLAN, May 1998.
2. A Sustainable Development Strategy for the South East: Public Consultation, Report by Robin Smith, Chief Executive Havant Borough Council, Association of Hampshire and Isle of Wight Authorities, 24 July 1998.
3. Draft Regional Planning Guidance for the South East, A Sustainable Development Strategy for the South East (SERP 500), SERPLAN, December 1998.
Appendix 1 available on request
SUMMARY OF DEPOSIT STRATEGY
Although there have been numerous minor amendments to the text and layout the deposit Strategy is, for the most part, similar to the consultation draft. The main chapters and sections here significant alterations are:
The Introduction, which provides a guide to the whole document and incorporates text which was previously in the Core Strategy. This change means that the introduction is now quite lengthy, but the Core Strategy section is slimmed down and concentrates on policy matters.
The Core Strategy which has been expanded to give more details about the key elements of the strategy (particularly countryside aspects and the rural economy) and now reflects a revised housing distribution for the region. The Strategy proposes a base-line dwelling provision of 861,700 additional dwellings 1991-2016 and a county distribution of this figure. The Strategy also proposes an additional provision within an indicative range 892,000 - 914,000 dwellings to meet any unsatisfied demand to be identified later through the regional monitoring process. There is no distribution of this additional provision of between 30,300 and 52,300 dwellings. Strategic planning authorities are expected to indicate how this figure would be achieved as part of the reviews of existing structure plans.
Sustainable Transport, which has been substantially re-written to reflect the Transport White paper and the completion of work on regional transport priorities.
Spatial Implications, a new chapter intended to provide greater clarity for selected parts of the region on how the regional strategy should be locally interpreted.
Monitoring, a more detailed monitoring framework to help put into effect the philosophy of "plan, monitor and manage".
As far as the geographic area of Hampshire is concerned, the main effects of these changes are:
a housing provision figure of 130,300 additional dwellings for the period 1991-2016; and
the identification of the south coast corridor (Southampton- Folkestone) as a priority multi-modal transport corridor.
The deposit Strategy retains the highlighting of the special needs of South Hampshire, including the two cities of Portsmouth and Southampton, as a priority area for economic regeneration. The strategy as it applies to north-east Hampshire remains the same, although the area is now described as an "area of economic pressure" rather than an "area for economic consolidation". The description has been changed in response to comments on the draft strategy from the business community that "consolidation" gave the impression of negative, anti-growth sentiments. However, there is no special mention of either the New Forest or the Hampshire Downlands: references to the New Forest are simply to its status equivalent for planning policy to a National Park, and as a possible constraint on the development of the Southampton City region.
The deposit Strategy retains the special references to the Isle of Wight from the earlier version. Text and diagrams make its status both as a priority area for regeneration and a Rural Redevelopment Area more clear. The Island has a section of its own in the Spatial Implications chapter.
|Author:||Nick Goulder, Policy Manager|
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