Royal Commission on Environmental Pollution

I do not propose to respond to every question raised by your letter of 27 March. Instead, I would like to focus on two issues, which are the unsatisfactory way that Regional Planning Guidance is translated into development on the ground and the lack of a national spatial and economic strategy for how the different regions can contribute to the overall national objectives.

Dealing first with the issue of how RPG gets translated into development on the ground, I would draw your attention to Professor Crow's report on the Public Examination into Regional Planning Guidance in the South East and his comments in paragraphs 12.78 to 12.92. He is highly critical of the fragmented way the Blackwater Valley has been allowed to develop in the past and I would suggest to you that the problems have arisen because of the way neighbouring structure plan authorities have "dumped" unwanted housing requirements on the boarders without any joined up thinking. The Blackwater Valley is the size of Leicester or Coventry and yet is covered by two counties (Surrey & Hampshire), one unitary authority (Bracknell - formerly part of Berkshire) and six districts (Hart, Rushmoor, Waverley, Surrey Heath, Wokingham). The report is on:

http://www.go-se.gov.uk/infor/publications.htm

From a Hart perspective, we are upset at the way Hampshire County Council has dumped extra housing on us well in excess of the housing level recommended by the Structure Plan EIP Panel. This is despite the fact that Hart is an extreme dormitory area in the South-East context and Government Guidance in PPG13 seeks a better balance between housing/population and jobs. It is also worth pointing out that the structure plan has taken nearly 4 years to complete.

In the light of this experience, I do not believe that the current structure plan process is delivering the fine words and objectives of RPG and other Government Guidance to the local level. Once we get to do our local plan, the best we can do is make the best of a bad job. We have to apply the sequential test at the local level but I suggest strategic authorities/bodies should have to do the same.

I do not have a mandate from my local authority to say that the creation of city regions would be a better alternative to county councils and structure plan authorities. That must be a matter for a separate debate. However, I do believe that housing numbers in RPG should be distributed at sub-county or sub-regional level to achieve a finer grained approach to housing distribution that more closely matches regional objectives.

Turning now to my second issue, there is a general feeling among elected Members that we have no national plan by which to judge the appropriateness of RPG. What is the Government's overall policy and why has there not been a national debate/consultation? For example, is it Government Policy to let other regions whither on the vine (rather than throw good money after bad by way of regional initiatives) and leave the South East to support the national economy? Is the drift of workers into the South East desirable in terms of national objectives? I am surprised that the Government has not addressed these issues more openly by way of public consultation.

I hope you find these brief comments helpful.

I enclose a copy of my letter to GOSE setting out Hart District Council's response to draft RPG9, together with my report to Committee on draft RPG9.

Enquiries to David Paine
Date 7 June 2000

Dear RPG Team,

RESPONSE TO DRAFT REGIONAL PLANNING GUIDANCE FOR THE SOUTH EAST

The Council's Planning and Infrastructure Committee considered this matter on 6 June and resolved as follows.

1)       The Council objects most strongly to the fact that housing development rates proposed in draft RPG9 are above the planned rates in current RPG (up by 8% in ROSE and 32% in London). Even if 60% of housing is built on brownfield sites, yet more countryside will still be lost.

As a constructive way forward, the Council would wish to see a two-tier approach taken to the housing numbers along the lines taken by the Hampshire Structure Plan. This would involve a "baseline" figure for the region and each area, plus a reserve figure that would only be triggered where monitoring of agreed criteria would indicate the need. The Council also believes that the overall figures should not exceed those put forward by SERPLAN.

2)      It appears to this Council that in general there is a policy vacuum at the national level with regard to the role of each region within a national economic, population and household framework. The Government is urged to take a lead rather than follow trends and to carry out proper research and public consultation about the national planning context for population, households and economy that sets the scene for regional planning.

3)      The Council objects to the proposed housing distribution and the increased rate of development proposed for Hampshire because that may lead to unsustainable development pressures in the District as a result of the recently adopted Hampshire County Structure Plan Review.

4)      A finer grained approach to housing distribution is needed at the regional level to prevent inappropriate distribution of housing within Counties and to properly secure the requirements of PPG3, paragraph 6. At the very least, RPG should require Structure Plan Authorities to undertake a strategic sequential test first, to secure an optimum distribution to the districts that is most likely to meet RPG objectives.

5)      Policy H4 should be modified to include a requirement that Strategic Planning Authorities should undertake a strategic sequential test so as to secure an optimum distribution to the districts that best meets RPG objectives.

6)      Policy H6 should address the issue of "market affordable" housing by requiring control by a covenant that would restrict occupation to people employed, or last employed in a job located no more than 5 miles away from the dwelling.

7)      Under monitoring policy MON1, the Council objects to use of the ratio of house prices to wage levels. Misapplied, this ratio could be used to accelerate development in unsustainable dormitory area when the need is in fact to seek a better balance between jobs and housing. This ratio needs to be replaced with one relating to the balance between jobs and workforce at district level.

8)      The Council welcomes in principle the sub-division of the Region into separate policy areas, but has the following detailed observations.

1. South Hampshire, Southampton and Portsmouth should be given a separate housing target from the rest of Hampshire because this area has a sufficiently large population and is important enough to justify that. Failure to do so could undermine regional strategy. It is difficult to balance housing distribution across such a large county when there is a large conurbation with economic concerns at one end of the county and a buoyant area at the other end with problems of fragmentation and long-distance commuting by car.

2. With regard to the Blackwater Valley, the advice in RPG is welcome, particularly the suggestion of a sub-regional study and the recognition of the work of the Blackwater Valley Network. The sub-regional study should involve not just the Network but also English Nature, given the issues of internationally designated areas for nature conservation. A thorough study of commuting patterns is called for to identify areas where local job opportunities are lacking and where, as an alternative, sustainable public transport options are not available or are not used. Indeed, there is a need to revitalise transportation to address existing deficiencies and enable the area to "catch up". It is not reasonable to expect developers to pay to redress past deficiencies. However, the Council remains concerned as to how the results of a sub-regional study will be addressed in a sustainable way through the structure plan process, given that housing requirements are distributed at county rather than district or sub-regional level. The anomaly of distribution at the County level has the potential to undermine the outcome of sub-regional studies.

1. In Chapter 6, particular regard should be had to the setting of rivers, streams and other natural features because of their intrinsic amenity value. This is in addition to the welcome provisions of Policy INF2 included in Chapter 10. It is a pity that such advice is not covered in PPG25 as well. Also, coastal areas could be a sustainable location for further development if supplied from desalination plants.

2. In Chapter 7, to address the issue of social exclusion, Policy RE3 should add the point that local planning authorities should also make provision for "low-tech" employment sites to secure employment opportunities for those elements of the workforce who have below average skills potential.

3. Cohesive guidance is also needed about how to deal with country club style developments, either in chapter 6 or chapter 7 because current guidance does not help address this legitimate outlet for people's recreation needs. Furthermore, there is a case for a separate chapter on sport, recreation and culture.

4. To address tighter parking standards in Chapter 9, there is a need for better co-ordination and co-operation from Highway Authorities to predict and address potential problems relating to anti-social parking on residential streets before they occur rather than after the event.

Yours sincerely

David Paine
Principal Strategy Officer

A.1      Quality of Life in Town & Country (Chapter 5)

A.1.1      Policy Q1 states that urban areas should be the prime focus for new development. It requires urban capacity studies, sets an overall target for ROSE (rest of the South East) of 60% of new development on previously developed land and requires new development in and around urban areas to be consistent with the overall strategy for urban renaissance and sustainable development. The 60% target is repeated in Policy H4 of the housing chapter.

A.1.2      Policy Q2 seeks to raise the quality of life in urban areas and encourages mixed use developments.

A.1.3      Policy Q3 echoes the requirements of PPG3 in seeking densities of at least 30 dwellings per hectare with greater intensity in places with good public transport accessibility.

A.1.4      Policy Q4 seeks enhancement and better management of the urban fringe plus the re-use and redevelopment of redundant hospital sites, airfields and other major sites on the fringe of urban areas.

A.1.5      Policy Q5 emphasises the need to apply the sequential test in PPG6 in developing strategies for retail and leisure development.

A.1.6      Policy Q6 requires health, education and other social infrastructure requirements to be taken into account fully.

A.2      Environmental Strategy And The Countryside (Chapter 6)

A.2.1      Policy E1 requires priority to be given to protecting areas designated at international or national level either for their intrinsic nature conservation value, their landscape quality or their cultural importance.

A.2.2      Policy E2 states that there is no regional case for reviewing Green Belt boundaries in the light of regional strategy.

A.2.3      Policy E3 covers biodiversity and requires development plans to give priority to specific species and habitats of international, national and sub-regional importance as identified in Biodiversity Action Plans.

A.2.4      Policy E4 seeks to maintain and enhance the quality and character of the rural environment, while securing the necessary change to meet the economic and social needs of local people and visitors. The policy seeks good quality development, which contributes to local distinctiveness and requires the location and scale of development in rural areas to reflect guidance in PPG7. It also seeks to safeguard the setting and character of small historic towns and villages.

A.2.5      Policy E5 addresses the coastline, Policy E6 addresses woodland habitat, Policy E8 addresses air quality and Policy E9 addresses soil and land quality (including best & most versatile agricultural land and unstable land).

A.2.6      Policy E7 seeks opportunities to provide leisure and recreation in and access to the countryside in ways that retain and enhance its character. Amongst other things development plans should maximise the use of highly managed areas (country parks, cultural attractions, sports facilities etc) and maximise the positive benefits of sport, leisure recreation and cultural development for the rural environment, local communities, local economy and visitors.

A.2.7      My comments on this section are as follows.

In listing international and national nature conservation designations separately, the drafting of Policy E1 overcomes concerns I had about the SERPLAN version.

A.3      The Regional Economy (Chapter 7)

A.3.1      Policies RE1 to RE4 deal with economic success and human resources.

Policy RE1 seeks to support and further develop the regional economy to ensure that it contributes fully to national growth and follows the principles of sustainable development.

Policy RE2 deals with human resource development and requires development plans to include policies which ensure that sufficient and accessible premises are available for training and education purposes.

Policy RE3 seeks a long-term holistic approach to economic development activities. Economic development strategies incorporated into development plans and economic policies should be integrated with spatial planning and with social and community development policies.

Policy RE4 encourages business to adopt the principles of sustainable development. Development plans should include policies to reduce business related travel and encourage forms of development which maximise environmental and social benefits. Travel plans would be required for all substantial new travel-generating developments.

A.3.2      Policy RE5 seeks to make the best use of land resources, with the emphasis on re-using developed land in sustainable locations.

A.3.3      Policies RE6 to RE9 deal with economic distribution in the region. Policy RE6 gives special priority to securing economic development in the Thames Gateway.

Policy RE7 requires particular attention to be given to actively supporting economic regeneration and renewal in Priority Areas for Economic Regeneration (PAERs).

Policy RE8 deals with the "Western Arc" where positive strategies should be developed for areas where congestion or labour or land shortages are constraining economic growth. "Hotspots" should be identified and specific policies developed to tackle local problems. Examples of policies might include:

Earmarking a reserve supply of land which would only be taken up by developments which make a special contribution to the economy of the area or assist an existing or developing cluster;

Re-allocating land where necessary to secure a better balance between housing and employment;

Tighter traffic management and parking policies including a co-ordinated approach to travel plans;

Additional investment in public transport provision and facilities for walking and cycling (a point also raised in paragraph 9.50 of the transport chapter); and

Greater emphasis on affordable housing based on local needs assessment.

A.3.4      Policy RE10 encourages the grouped location of high value-added activities in business clusters backed by development plan policy. Such policies might include:

Identifying science and technology parks that are well served by sustainable modes of transport and close to universities or research facilities;

Identifying networks of sites linked by telecommunications;

Proposing sites for incubator units;

Proposing sites for small and growing businesses;

Identifying potential locations for corporate headquarters.

Policy RE11 seeks to facilitate small and medium enterprises and support growth in a variety of economic sectors including manufacturing.

Policy RE12 encourages tourism, arts and culture.

A.3.6      Policies RE8 and RE10 are of particular strategic relevance to Hart. I have no adverse comments to make about these policies and the Council has been supportive of strategic business initiatives up to now. However, because we are a dormitory area that started with a very low employment base, we should not be penalised by having to find more open market housing just because we have been successful in attracting new business. It is to be hoped that the sub-regional policies for the Blackwater Valley will reduce that risk.

A.4      Regional Transport Strategy (Chapter 9)

A.4.1      Policy themes include minimising the need to travel (Policy T1), raising travel awareness (T2), maximum car parking standards (T3), walking & cycling (T4), public transport (T5), integrated freight distribution (T6), sea port facilities (T7), sustainable airport growth (T8).

A.4.2      Paragraphs 9.40 to 9.52 deal with the regional programme of transport investment. Investment priorities will include proposals which:

Serve the Region's role as the gateway to the continent,

Improve the regional transport links between Priority Areas for Economic Regeneration, Thames Gateway, other major urban areas, ports, airports and the Channel Tunnel Rail Link and

Facilitate access to the areas of growth.

A.4.3      Members' attention is drawn to Policy T3 and the requirements for new car parking standards set out in the policy.

Generally, for housing they should be more rigorous than those set out in PPG3, to support urban renaissance. (The PPG3 standard is 1.5 spaces per dwelling maximum).

Similarly, for non-residential uses they should be more rigorous than those set out in (draft) PPG13.

In particular, the maximum parking standard for B1 land use (office, research & light industry) should be within the range 1 space per 35m² and 1 space per 100m².

A.4.4      Members need to be aware of the car parking issue when dealing with planning applications for new development and in seeking additional sites through the local plan. Members may like to know that the final ratio for the DERA Hub Project will meet the new standards at 1:36m2. On that basis, I do not foresee any great problems in implementing the new standards for business development, provided each development is accompanied by a staff travel plan.

A.4.5      On the other hand, if residential car parking standards are more rigorous than the average standard of 1.5 spaces per dwelling in PPG3, I suspect that it may make larger new dwellings in rural areas such as Hart less attractive to purchasers. At the same time it will necessitate stricter parking controls on surrounding streets and better design in general to prevent parking from becoming a nuisance to others.

A.5      Supply And Development Of Other Infrastructure (Water, Waste, Energy) (Chapter 10)

A.5.1 Policy INF1 deals with areas at risk from flooding and says that development should be steered away from such areas. It requires development plans to:

include policies to protect flood plains;

provide criteria for redevelopment proposals in flood plains to minimise their cumulative adverse impacts and secure enhancement of the flood water storage & ecological role of flood plains;

consider the need for managed retreat from costal areas; and

encourage the adoption of sustainable urban drainage practices.

A.5.2      Policy INF2 deals with the water cycle - supply and quality and requires new development to be located so as to allow for sustainable provision of water services. Redevelopment should identify and make provision for rectification of any legacy of contamination and drainage problems. Development plans should seek to avoid sites where water supply and/or drainage provision is likely to be unsustainable. This raises the thought that coastal areas may provide a more sustainable location for development because of the potential to build desalination plants to meet local water supply needs.

A.5.3      Policy INF3 deals with management of the Region's waste within its own boundaries and Policy INF4 gives priority in planning future development to energy conservation and maximising use of renewable energy resources.

A.6       Minerals (Chapter 11)

A.6.1      This chapter deals with the production and supply of minerals, managing the demand for minerals (including Policy M1) and environmental effects of extraction and recycling (including Policy M2).

1.0       Introduction

1.1       Draft RPG9 has been published by Government Office for the South East (GOSE) for consultation until 19 June. It can be viewed on the GOSE web site at http://www.go-se.gov.uk/whatsnew/index.htm and a copy has been placed in the Members' room.

1.2       When RPG9 is finally adopted, it will have a significant impact on strategic planning, which in turn will impact on planning at the local level. For that reason, this is an important consultation and I welcome the opportunity to comment. This report provides Members with an overview of the draft RPG9 and supporting documents, and suggests an appropriate response.

2.0       Background

2.1       The draft RPG for the South East deals with the period up to 2016 and provides the regional framework for development plans in the South East. It follows on from SERPLAN's "A Sustainable Development Strategy for the South East" published in December 1998 and a Public Examination held by an independent Panel, whose report was published in October 1999 (referred to as the Crow report).

2.2       I reported SERPLAN's version of submitted draft RPG9 to this Committee on 19 January 1999 (Minute 64 refers). The Council was given a place at the Public Examination to address the Blackwater Valley issue. This new version of draft guidance is sufficiently different from the SERPLAN version to require careful consideration of its contents.

2.3       The overall objective of the RPG is to achieve a sustainable pattern of development whilst conserving and enhancing the environment. It promotes the appropriate development of the regional economy. The RPG focuses on trying to ensure that people live in settlements that have good services and where employment can be found locally. The aim is to maintain and enhance the existing infrastructure of the regions' towns and cities so that people actually want to live, work and run their businesses in them.

2.4       The 12 main principles that should govern the continuing development of the Region are:

1. Urban areas should become the main focus for development through making them more attractive, accessible and better able to attract investment;
2. Greenfield development should normally take place only after other alternatives have been considered, and should have regard to the full social, environmental and transport costs of location;
3. The pattern of development should be less dispersed with more sustainable patterns of activity, allowing home, work, leisure and community services to be in closer proximity and minimising the amount of land required in all new developments;
4. London's World City role and the South East's international connections should be enhanced as a basis for the enhancement of the Region's attractiveness in Europe and the world;
5. Economic opportunities should be increased, by measures to improve the performance of poorer parts of the Region and by reducing or surmounting bottlenecks to sustainable growth;
6. Sufficient housing should be provided for all who need to live and work in the Region, to avoid social exclusion and pressure for housing in adjointing regions;
7. The development of housing should be more sustainable, providing a better mix of sizes and types, having regard to the structure of households and people's ability to access homes and jobs;
8. Better use should be made of the Region's natural resources, its capacity to deliver essential water, energy and minerals, and its capability to handle its waste;
9. There should be continued protection of the Region's biodiversity, internationally and nationally important nature conservation areas and enhancement of its landscape and built and historic heritage;
10. The life of the countryside and rural areas should be sustained through rural diversification, respecting the character of different parts of the Region;
11. Access to jobs, services and leisure should be less dependent on longer distance movement and there should be increased ability to meet normal travel needs through safe walking, cycling and public transport with reduced reliance on the car; and
12. Transport investment should support the spatial strategy, maintaining the existing network, enhancing access as part of more concentrated forms of development, overcoming bottlenecks and supporting higher capacity and less polluting modes of transport.

Housing Numbers, Distribution And Other Housing Issues;

Sub-Regional Areas And The Blackwater Valley;

The Rest Of The Policy Framework.

3.1       Regional Housing Requirement

3.1.1      Overall housing numbers are set out in Policy H1.

The requirement for the rest of the south east outside London (ROSE) is 43,000 dwellings per annum, an increase of 3,333 dwellings (8%) over the annual requirement in current RPG of 39,667. (The Crow report had recommended a figure of 54,925 for ROSE).

The requirement for London is 23,000 dwellings per annum, an increase of 32% over current RPG requirements of 17,333.

3.1.2       Government Office has prepared a Housing Technical Note to justify this figure and demonstrate why it should be lower than that recommended by Professor Crow. I have placed a copy in the Members' Room. The following points are worth noting.

A key consideration is the ageing of the region's population that may lead to a shortfall of workers compared with jobs. This could lead to increased in-migration and/or commuting into the region or even impede economic growth.

The Regional Development Agencies are expected to adopt strategies for sustainable economic growth, ensuring that growth in the more buoyant parts of the region is based on high value-added, knowledge-based sectors rather than labour-intensive activities. (See also section on regional economy).

1992 based household projections indicated an annual growth of 44,000 households per annum. 1996 based projections indicate a figure of 47,000.

The bulk of this growth is generated internally within ROSE or by net in-migration from London (with a net outflow from ROSE to the rest of the country).

Projections imply significant household growth in the capital up to 2016 - much of it linked to international in-migration.

3.1.3      Members may at first glance be relieved that the Government is not proposing to accept the level of housing proposed in the Crow report. However, I am still concerned that the Government should be indicating the need for an increase in the annual rate of dwelling provision in London and the South East that is above current RPG requirements. That represents an acceleration in the rate of development that must be cause for concern, even though the claim is that less land will be required because densities will be higher. I can appreciate the desire of the Government that everyone should have a decent home, but even if only 40% of new dwellings are to be provided on greenfield sites that still means an ongoing loss of the countryside.

3.1.4      Members may feel that in general there is a policy vacuum at the national level with regard to the role of each region within a national economic, population and household framework. It may appear to some that the Government is simply following trends (such as international inward migration) rather than leading them. I suggest that this is an area that should be properly researched by the Government and put out to public consultation. The land-use implications are such that people ought to be consulted about the national planning context for population, households and economy that sets the scene for regional planning. I have recommended accordingly.

3.2 Distribution

3.2.1      Distribution between the Counties will be included as Policy H2 in the final version of RPG9. In the meanwhile, a draft distribution is set out in a covering letter to SERPLAN and reproduced on the next page. I have shown the requirements of current RPG for comparison. The draft distribution has been scaled up from SERPLAN's baseline distribution.

3.2.2       I am concerned to see that Hampshire's requirement would be increased by 7% from current RPG although the average for ROSE is 8%. This would have implications for triggering Policy H4 of the Hampshire County Structure Plan (1996-2011) that in turn might increase Hart's housing requirements by up to 1,500 dwellings. Members will wish to object to this level of growth for Hampshire.

3.2.3      Against the background of an accelerating rate of growth in the south east, I would also point out the following. Although Kent and Essex include growth areas (Ashford and the Stansted/M11 Corridor respectively) plus the Thames Gateway, the level of growth proposed in draft RPG9 is only 11% and 1% respectively. On the other hand, Hampshire is expected to see a 7% increase in its rate of growth even though it does not include a growth area.

3.2.4       Of course, if the urban area of South Hampshire, Southampton and Portsmouth is intended to take an increased level of growth, I suggest RPG should make that clear. Indeed, London is taking a 32% increase in the rate of growth. In the Hampshire context I would expect the urban centred approach of draft RPG to lead to a shift of development pressures to the cities and urban areas of Hampshire. Indeed, advice in PPG3, paragraph 6 says:

"In some regions or sub-regions there may be concentrations of previously developed land within one authority and a lack of it in neighbouring authorities. In such circumstances, the RPBs and structure planning/UDP authorities should work together to focus new housing development in areas where previously-developed land is available (or where there are existing dwellings suitable for re-use or buildings suitable for conversion) in preference to developing greenfield sites".

3.2.5      Certainly, I fail to see how Hart can be a sustainable location for further housing development in the regional context, when the district acts as a dormitory for long-distance car-born commuters and lacks a meaningful supply of brownfield land in sustainable locations. Nevertheless, the recently adopted structure plan review potentially sets us up for substantial housing growth, subject to the outcome of the RPG process. In dormitory areas the argument that local employment growth means the area should take more housing simply leads to perpetuation of an unsustainable pattern of development.

3.2.6      For that reason, I maintain my view that a finer grained approach to housing distribution is needed at the regional level to prevent this sort of thing from happening again and to ensure that the objectives of Regional Guidance are not undermined.

3.3      Other Housing Issues

3.3.1      Policy H3 sets out the basis of "Plan Monitor Manage" enshrined in PPG3 (Housing) and PPG11 (Regional Planning). An annual monitoring report prepared by the Regional Planning Body would form the basis for decision on the timing of review of this guidance.

3.3.2      In line with the requirements of PPG3, Policy H4 requires a sequential approach to the allocation of land for housing and seeks to achieve at least 60% of all new housing development on previously developed land. These are laudable aims, but I fail to see how Hart can both meet these requirements AND meet potential structure plan requirements of 4,750 dwellings baseline PLUS 1,500 dwellings (policy HCSP: H4) between 1996 and 2011. That is not a criticism of draft RPG but rather a criticism of the structure plan process. To overcome this criticism, I suggest that RPG should require Structure Plan Authorities to undertake a strategic sequential test first, to secure an optimum distribution to the districts that is more likely to meet RPG objectives. Better still of course would be for RPG to take a finer grained approach to housing distribution and I have recommended accordingly.

3.3.3      Paragraphs 8.10 to 8.16 and Policies H5 & H6 deal with housing need and affordability. Policy H5 seeks a range of dwelling types and sizes to meet the needs of all sectors of the community and to plan for balanced communities. Policy H6 seeks the provision of sufficient affordable housing to meet locally assessed needs. Paragraph 8.16 suggests that some 18,000 to 19,000 affordable homes are needed each year. That is some 42-44% of the total housing requirement of 43,000 dwellings per annum required in ROSE (and almost double Hart's current rate of 20-25%). I note that Policy RE8 dealing with the "Western Sector" seeks a greater emphasis on affordable housing based in local needs assessment. Whereas mechanisms already exist to deal with shared ownership and rented housing, I am concerned over the issue of how to deal with "market affordable" housing. If one of the Government's objectives is to meet local workforce needs, I suggest that market affordable housing should be controlled by covenant, restricting occupation to people employed, or last employed in a job located no more than 5 miles away from the dwelling.

3.3.4      Members' attention is drawn to the monitoring policy MON1 and the potential indicators and types of indicators relating to the target of "sufficient housing" and "sufficient affordable housing". They are:

Housing need according to waiting lists and registers of statutory homeless;
Ratio of house prices to wage levels;
Mix of type and size of dwelling;
Number of affordable homes completed each year compared with provisional regional indicator of18,000 to 19,000 affordable units per annum in ROSE.

3.3.5      I am concerned about the ratio of house prices to wage levels. In dormitory areas, will the ratio relate to local wage rates (which may be low) or to the wages earned by the population working elsewhere (say in London)? Misapplied, this ratio could be used to accelerate development in unsustainable dormitory area when the need is in fact to seek a better balance between jobs and housing and to raise the proportion of affordable dwellings built. Put another way, fashionable areas with high house prices may not be sustainable locations for further development because it will add to car based commuting. I believe this ratio needs to be replaced with a monitoring ratio relating to the balance between jobs and workforce at district level.

4.0      Sub-Regional Areas And The Blackwater Valley (Chapter 12)

4.1      The region has been subdivided into the following areas:

The Thames Gateway;
Priority Areas For Economic Regeneration (PAERs);
Western Arc;
Potential Growth Areas

4.2      The Thames Gateway

4.2.1      This area is in need of large-scale regeneration and RPG identifies it as a regional and national priority for regeneration and growth with the potential to make a major contribution to the Region's economy. Many of the main opportunities for development are currently outside existing urban areas.

4.3      Priority Areas For Economic Regeneration (PAERs)

4.3.1      There are 8 identified PAERs.

South Hampshire, Southampton and Portsmouth;
The Isle of Wight;
Sussex Coast and Towns;
East Kent;
Harlow;
East London/Lower Lea Valley;
Luton/Dunstable/Houghton Regis;
Tendring Coast.

4.3.2      Members attention is drawn to comments by RPG on South Hampshire, Southampton and Portsmouth in paragraphs 12.7 to 12.11, given that this area is covered by the same structure plan as Hart. I have summarised the key points described by these paragraphs.

Locational mismatch has developed with the main areas of lower cost and affordable housing being primarily in the inner areas and peripheral estates of Portsmouth and Southampton while growing employment focal points are primarily at decentralised locations along the M27.

As the largest urban area in the Region outside London, the sub-region has sizeable needs and opportunities for urban renewal including additional housing. The main focus for development should be within existing urban areas. However, some new development will have to be on land outside the main urban areas and the need here is to avoid the perpetuation of post-war patterns of car-based suburban development.

It would be preferable to see more affordable housing in the more prosperous suburban areas where a need is being created and not met, and from where it is also easier to access the new employment areas.

4.3.3      I question how these objectives will be achieved through the structure plan process in Hampshire. This area is second in size to London but has no separate housing target from the rest of Hampshire, whereas London has its own housing target. Once again, I suggest that a finer grained approach to housing distribution is needed to ensure that regional policy sticks at the local level.

4.4      Western Arc

4.4.1 This is the area west and south of London (and so includes Hart). In order to achieve sustainable development, RPG says further growth needs to occur in a form which minimises the additional pressures on land and labour resources, particularly in "hotspots" where positive action is required. The area is further sub-divided between the Western Wedge, Blackwater Valley and the Crawley/Gatwick/M23 area.

4.4.2 The Western Wedge covers the Berkshire Unitary Authorities, Oxfordshire, North Hampshire and parts of West London, so it is adjacent to Hart. It is of considerable significance to the national economy and is one of the most prosperous in the UK. The area is characterised by concentrations of business service employment and high tech, knowledge based industries and by increasing pressures on local infrastructure, land resources and house prices.

4.4.3 The Blackwater Valley encompasses all or parts of the administrative districts of Surrey Heath, Waverley and Guildford in Surrey, Bracknell Forest and Wokingham in Berkshire and Hart and Rushmoor in Hampshire. The following points are covered in paragraphs 12.53 to 15.56 of RPG and are important.

Whilst the initial impression is that the area quite well served by the transport system closer analysis reveals that there are shortcomings in the rail network, particularly the poor relationship between north-south and east-west links. Evidence also indicates that there is no significant capacity in the rail network to serve additional commuters, with the likely consequence that any new development would increase levels of car-borne commuting. There is therefore a need for improvements to the public transport system and, in particular, the rail network, which should be addressed through local transport plans.

The Blackwater Valley experienced significant expansion in the 1960s and 1970s and is now under pressure for further residential and employment development yet is partly constrained by the Green Belt and environmental designations of international importance. The area has been specifically identified in RPG to assist the process of ensuring that future development is carried out in a co-ordinated manner.

The area has a buoyant and thriving economy that should be encouraged to grow. However, if future economic growth is to take place, it should occur within an acceptable pattern of development having regard to environmental constraints in the area. For this reason, the local authorities should work together to ensure the adoption of a co-ordinated approach to transportation and land-use planning, and to avoid problems associated with more fragmented cross-boundary initiatives. This will build upon the existing Blackwater Valley network of local authorities. Making best use of existing urban areas and enhancing their quality as part of an urban renaissance will be important for the sustainable development of the area.

The Regional Planning Body may wish to consider a joint study to provide a framework for local authorities which will ensure that future economic growth in the area is fully optimised. Such a study could clarify the extent of the Blackwater Valley sub-region and identify the best locations for economic growth on the basis of taking advantage of local potential. It should help to identify areas where labour supply is constraining growth and take positive measures to relieve this problem, either by the provision of more housing or by the improvement of public transport. Any agreed strategy fo rthe area should be reflected in development plans, and local authorities should incorporate improvements to the transport infrastructure for the area in their local transport plans.

4.4.4      The advice in RPG is welcome, particularly the suggestion of a sub-regional study and the recognition of the work of the Blackwater Valley Network. I suggest that the sub-regional study should involve not just the Blackwater Valley Network but also English Nature, given the issues of internationally designated areas for nature conservation. I also suggest that a thorough study of commuting patterns is called for to identify areas where local job opportunities are lacking and where, as an alternative, sustainable public transport options are not available or are not used. Indeed, there is a need to revitalise transportation to address existing deficiencies and enable the area to "catch up". It is not reasonable to expect developers to pay to redress past deficiencies.

4.4.5      Members may question how the results of any such study will be addressed in a sustainable way through the structure plan process, given that housing requirements are distributed at county rather than district or sub-regional level. The anomaly of distribution at the County level has the potential to undermine the outcome of sub-regional studies.

4.5      Potential Growth Areas

4.5.1 These are Milton Keynes, Ashford and the Stansted/M11 Corridor.

5.0      The Rest Of The Policy Framework

5.1      Policies also cover:

Quality of Life in Town & Country (Chapter 5);
Environmental Strategy & the Countryside (Chapter 6);
The Regional Economy (Chapter 7);
Regional Transport Strategy (Chapter 9);
Supply & Development of other Infrastructure (water, waste, energy) (Chapter 10);
Minerals (Chapter 11).

5.2      The general policy framework appears to be well drafted and will, I believe, provide useful support for the preparation of structure and local plans. There are too many policies to comment on each one individually, but Appendix A sets out those that are worth noting. I have boxed my comments where I believe a formal response is needed.

6.0      Resource Implications: None

7.0      RECOMMENDATIONS

That GOSE be informed:

1. The Council objects most strongly to the fact that housing development rates proposed in draft RPG9 are above the planned rates in current RPG (up by 8% in ROSE and 32% in London). Even if 60% of housing is built on brownfield sites, yet more countryside will still be lost.

2. It appears to this Council that in general there is a policy vacuum at the national level with regard to the role of each region within a national economic, population and household framework. The Government is urged to take a lead rather than follow trends and to carry out proper research and public consultation about the national planning context for population, households and economy that sets the scene for regional planning.

3. The Council objects to the proposed housing distribution and the increased rate of development proposed for Hampshire because that may lead to unsustainable development pressures in the District as a result of the recently adopted Hampshire County Structure Plan Review.

4. A finer grained approach to housing distribution is needed at the regional level to prevent inappropriate distribution of housing within Counties and to properly secure the requirements of PPG3, paragraph 6. At the very least, RPG should require Structure Plan Authorities to undertake a strategic sequential test first, to secure an optimum distribution to the districts that is most likely to meet RPG objectives.

5. Policy H4 should be modified to include a requirement that Strategic Planning Authorities should undertake a strategic sequential test so as to secure an optimum distribution to the districts that best meets RPG objectives.

6. Policy H6 should address the issue of "market affordable" housing by requiring control by a covenant that would restrict occupation to people employed, or last employed in a job located no more than 5 miles away from the dwelling.

7. Under monitoring policy MON1, the Council objects to use of the ratio of house prices to wage levels. Misapplied, this ratio could be used to accelerate development in unsustainable dormitory area when the need is in fact to seek a better balance between jobs and housing. This ratio needs to be replaced with one relating to the balance between jobs and workforce at district level.

8. The Council welcomes in principle the sub-division of the Region into separate policy areas, but has the following detailed observations.
   1. South Hampshire, Southampton and Portsmouth should be given a separate housing target from the rest of Hampshire because this area has a sufficiently large population and is important enough to justify that. Failure to do so could undermine regional strategy. It is difficult to balance housing distribution across such a large county when there is a large conurbation with economic concerns at one end of the county and a buoyant area at the other end with problems of fragmentation and long-distance commuting by car.

   2. With regard to the Blackwater Valley, the advice in RPG is welcome, particularly the suggestion of a sub-regional study and the recognition of the work of the Blackwater Valley Network. The sub-regional study should involve not just the Network but also English Nature, given the issues of internationally designated areas for nature conservation. A thorough study of commuting patterns is called for to identify areas where local job opportunities are lacking and where, as an alternative, sustainable public transport options are not available or are not used. Indeed, there is a need to revitalise transportation to address existing deficiencies and enable the area to "catch up". It is not reasonable to expect developers to pay to redress past deficiencies. However, the Council remains concerned as to how the results of a sub-regional study will be addressed in a sustainable way through the structure plan process, given that housing requirements are distributed at county rather than district or sub-regional level. The anomaly of distribution at the County level has the potential to undermine the outcome of sub-regional studies.

9. The Council would like to see the following additions to the remaining policy framework.
   1. In Chapter 6, particular regard should be had to the setting of rivers, streams and other natural features because of their intrinsic amenity value. This is in addition to the welcome provisions of Policy INF2 included in Chapter 10. It is a pity that such advice is not covered in PPG25 as well. Also, coastal areas could be a sustainable location for further development if supplied from desalination plants.

   2. In Chapter 7, to address the issue of social exclusion, Policy RE3 should add the point that local planning authorities should also make provision for "low-tech" employment sites to secure employment opportunities for those elements of the workforce who have below average skills potential.

   3. Cohesive guidance is also needed about how to deal with country club style developments, either in chapter 6 or chapter 7 because current guidance does not help address this legitimate outlet for people's recreation needs. Furthermore, there is a case for a separate chapter on sport, recreation and culture.

   4. To address tighter parking standards in Chapter 9, there is a need for better co-ordination and co-operation from Highway Authorities to predict and address potential problems relating to anti-social parking on residential streets before they occur rather than after the event.

Cost Code: 195

Background Papers: Draft RPG9 (GOSE, GOEE, GOL), Housing Technical Note: Housing Need And Capacity In The South East - April 2000 (GOSE, GOEE, GOL), Hampshire County Structure Plan (HCC), PPG3 (Housing).

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