South East Forum For Sustainability

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The South East Plan – Chapter 8 Transport

Chapter 8 of the South East Plan is based on but replaces the Regional Transport Strategy (RTS).

From the publication of the draft RTS, prior to its approval by the Secretary of State in 2004, through its incorporation into the South East Plan and the subsequent consultation processes, SEFS has consistently supported many of its policies.

SEFS is pleased that these have been retained in the approved version of the South East Plan. We support in particular those policies which -

• aim to achieve a rebalancing of the transport system in favour of sustainable modes.
• foster and promote an improved and integrated network of public transport services.
• encourage development that is located and designed to reduce average journey length.
• include measures to minimise negative environmental impacts of transport and where possible to enhance the environment and communities through such interventions
• support and develop the role of regional spokes by developing a complementary and integrated network of rail and express bus/coach services.
• reduce the environmental impact of surface access to airports increasing modal share in favour of public transport and sustainable modes.
• include a rural dimension to transport and traffic management policies, including looking for opportunities to improve provision for cyclists and pedestrians between towns and their nearest villages.

 SEFS is particularly pleased that the Secretary of State has agreed that policies which promote demand management should be prioritised and that the transport system should play its proper role in tackling climate change.

SEFS continues, however, to have serious concerns over a number of schemes included in the list of programmed interventions, the delivery of which would not only tend to work against policies to rebalance the transport system in favour of sustainable modes but would add to the difficulties in achieving reductions in CO₂ emissions in line with the Climate Change Act requirements.

Having reached  this point with a document that has involved many hours of work over several years for those associated with its production it is imperative that its status not only as a legal but a living document is recognised at all levels. 

The Transport Chapter of the South East Plan provides the context within which local authorities (transport and/or planning) will review their local transport plans (LTPs) and their local development frameworks (LDFs).  SEFS is confident that local campaigners and local groups will do their best to ensure that this happens. 

The South East Plan has finally been published and to much relief includes lower housing figures than originally proposed. This is a welcome move, however the region still produces more carbon emissions than any other in the country and reducing this will be a major challenge even with these housing levels.

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Introduction
The South East Forum for Sustainability is the environmental network for the South East Region. We welcomed the opportunity to comment on the Secretary of State‟s Proposed Changes to the South East Plan, and the associated independent Sustainability Appraisal and Habitats Regulation/Appropriate Assessment Report produced by the consultants Levitt-Therrivel.

SEFS and our members have engaged in all stages of the development of the South East Plan and we view it as essential that the plan has proper regard to the environment and is consistent with the principles of Sustainable Development.

Comments
Many of our members have put in detailed responses to this consultation (further details are available from the SEFS Secertariat on Request). However, SEFS would like to bring the following points to the attention of the Secretary of State.

Support
SEFS supports a number of the proposed changes. We welcome (with some comments):
* Chap 5(6) CC2 – The retention and policy wording changes in relation to this policy on Climate Change.
* Chap 5(10-11) CC3 – The retention and clear definition of Ecological Footprint and reference to the need to reduce the impact of further growth in the region
* Chap 5(24) CC8 – and support in principle the inclusion of the new policy on green infrastructure but suggest that the wording of the policy is amended as follows:
Proposed Amendment
SEFS would like to see this excellent policy expanded to recognise that Green Infrastructure is not only beneficial in Biodiversity terms but also brings other environmental, social and economic benefits. In particular we would like to see the policy adjusted in line with the recommendation in para 6.8.5 of the SA&HRA/AA report to ensure strategic Green Infrastructure planning for regional hubs.
* Chap 8(9-12) – The recognition of the importance of demand management and the significance of climate change as a driver of transport policy, and the changes to policy T5 on Mobility Management with the following policy change:
Proposed Amendment
SEFS would like to see the wording in Chap 8(12) amended to be consistent with other changes where “should” is replaced with “will” – Local Transport Plans will include policies…
* Chap 9(14) NRM4 – The amendments to this policy but we are concerned that given the higher levels of housing allocation set by the Secretary of State this policy will fail to be implemented.
* Chap 9(19) NRM5 – The expansion of this policy on Biodiversity but we are concerned that the conclusions set out in the text of Chap 9(22) render it incapable of being implemented. The requirement to protect nationally and internationally designated sites conflicts with other policies in the plan.
* Chap 9(23) NRM6 – The inclusion of a policy relating to Thames Basin Heaths. However, we would expect comments made by the South East England Biodiversity Forum to be fully taken into account.
* Chap 9 (26) NRM8 – Amendments taking on board findings of the Appropriate Assessment on Coastal Management.
* Chap 11(2) – The introductory text to the chapter on countryside and landscape management. However SEFS would like to point out that, it is regrettable that the EiP Panel‟s recommendation to provide a description of the regions‟ landscapes using landscape character areas has not been included as a change.
Proposed Amendment SEFS would welcome a change to the introductory text needs to include a description of the regions‟ landscapes as recommended by the EiP Panel.
* Chap 11(4&7) C1 & C3 – Recognition of the character of the New Forest and appropriate development and ensuring that the high priority of protection given the New Forest is mirrored in the policy on AONBs
* Chap 11(15) C7 – The inclusion of this policy on the River Thames Corridor though SEFS would like to see consistency in the introductory wording as in other parts of the plan where “will” is used instead of “should”.
Proposed Amendment Change “should” to “will” after “Local Authorities” in each place this occurs.

Oppose
SEFS is concerned about the overall sustainability of the Plan and these concerns are outlined in a separate section below. Specifically we oppose a number of key proposed changes as they contribute to weakening of the sustainability of the Plan. We object to: #
* Chap 3 (3) Core objectives – The weakening of the objective relating to the environment and the insertion of a new objective of 3% GVA growth. SEFS suggest the following amendments to the Core Objectives:
Proposed Amendment
Core Objectives i) The right balance A sustainable balance between planning for economic, environmental and social benefits – based on the principles of sustainable development – will be sought, to help improve the quality of life for everyone in the South East ii) Sustainable Eeconomic growth and competitiveness in the region will be maintained and sustainable improvements in economic performance will be promoted sustained, with Gross Value Added (GVA) in the region increased by 3% over the period 2006-16 viii) Adequate infrastructure will be provided in a way that keeps pace with development, tackles existing and avoids future „infrastructure deficits‟ xv) The best of the region‟s historic, built and natural environment assets will be safeguarded and enhanced, both for their own sake and to underpin the social and environmental cohesion and economic development of the region
* Chap 5 (5&6) CC1 – The lack of emphasis of the need to deliver on all of the RSF objectives to achieve sustainable development. SEFS request that there is a clarification in the text
Proposed Amendment Clarify that all of the 25 RSF objectives should be addressed to achieve sustainable development
* Chap 5 (12) CC4 – The weakening of the requirement for the highest standards of sustainable construction beyond national requirements
Proposed Amendment
SEFS suggests there is a need to set regionally specific high design standards beyond national policy in order to mitigate the impacts of growth as identified in the SA
* Chap 7 (1&2) H1/H2 – The fact that environmental impacts do not appear to have been taken into consideration in the setting of higher levels of housing.
Proposed Amendment
SEFS requests the reinstatement of the housing levels set out in the draft Plan until further cumulative impacts of higher levels are carried out.
* Chap 8 (28-30) – The proposal to safeguard land at Gatwick for a possible new runway after 2019. We are opposed to an additional runway here or anywhere in the South East and believe this would be unsustainable and adversely affect the high quality of the environment of the region. Increasing air travel should not be supported in any way as the contribution of aviation to climate change is well documented. SEFS requests the following change
Proposed Amendment SEFS requests that the previous text should be reinstated
* Chap 8 (45 & 58) Policy T14 and list of transport schemes – The fact that some schemes in the current list may not fit with the revised aims of the transport section and emerging national transport guidance. Currently committed schemes which are unlikely to promote sustainable travel and a shift to sustainable modes should not be progressed until further reviews are carried out.
* Chap 9 (4) NRM1 – The weakening of the Plan by removal of regionally specific water efficiency standards.
Proposed Amendment SEFS requests the reinstatement of a regional requirement for high standards of water efficiency in order to mitigate the impacts of planned growth. This should cover non-residential buildings as well as refurbishments.
* Chap 9 (40) NRM11 – The weakening of the Plan by removal of regionally specific energy efficiency standards.
Proposed Amendment
SEFS request the reinstatement of a regional requirement for high standards of energy efficiency in order to mitigate the impacts of planned growth. This should cover non-residential buildings as well as refurbishments. * SA&HRA/AA para 16.2.4 – the adoption of the South East Plan in view of the clear evidence from the independent Sustainability Appraisal and Habitats Regulation Appropriate Assessment, as summarised in this paragraph, “that in its present form this regional spatial strategy fails to meet the overarching objective of “.contributing to the achievement of sustainable development” as set out in the Planning and Compulsory Purchase Act 2004 and as further elaborated in Planning Policy Statement 11: Regional Spatial Strategies (2004).
* SA&HRA/AA report, para 16.3.1 – the implication (based on the recommendation in the SA) that a “more environment constraints-led approach” can be delayed until the next review of the Plan.

Overall Concerns – Sustainability of the Plan as a Result of the Secretary of State’s Proposed Changes
Whilst as outlined above we support and welcome some of the policies and wording in the Secretary of State’s Proposed Changes to the South East Plan, SEFS’s overriding concern and hence opposition to the Plan in its current form is because of the likely damage to the environment as outlined in the Sustainability Appraisal and Habitats Regulation Assessment. Sustainability Appraisal The Sustainability Appraisal concludes in 2.19.1 of the Non Technical Summary that whilst the plan will deliver economic benefits and some community benefits this is at “significant environmental costs “, “to the point of breaching environmental limits”. It is impossible for SEFS to endorse a plan which will “increase air pollution emissions”, which will lead to the continued rise in greenhouse gas emissions (SA NTS 2.94), “impact biodiversity and the landscape” (SA NTS 2.19.2 short to medium term impacts) and increase “risk of flooding from climate change” (SA NTS 2.19.2 medium to long term impacts).
We are disappointed at some omissions in the Sustainability Appraisal in terms of assessment of impacts. For example it does not look at the potential impacts of all the infrastructure that is likely to be required to support the growth levels identified in the Plan. The impacts of infrastructure such as new roads and sewage treatment works will evidently have a range of impacts in their own right. This is why further assessment of the direct and indirect and cumulative region wide impacts of the plan is required.
Finally with regard to the Sustainability Appraisal we are very concerned that environmental capacity is seen as something that can be considered at a later date and only in relation to the “distribution of future growth in the region” (SA NTS 2.24.1). The current Plan should be based on the environmental limits of the region in order for it to be sustainable.

Housing Provision – Chap 7(1), 7(2)
In the full Sustainability Appraisal/HRA/AA it is acknowledged that “Although we recognise the need for increased housing provision, it is clear that this level of housing growth will place considerable strain on the region’s environment. Zero carbon housing developments are unlikely to be a reality before 2016 and a considerable volume of new housing will be built between now and then which will contribute to CO2 emissions as well as to increased pressure on water and other resources.” (3.8.8) And “The level of housing provision under Option 2 will also place considerable strain on the region’s infrastructure.” 3.8.10
SEFS has been consistent in acknowledging that housing development is necessary for the purposes of social cohesion (to help tackle homelessness, overcrowded households, natural population growth and changes in the structure of households), but that the level and distribution of such growth must still be tested for sustainability.
Core Objective (i) – Chap 3 (3)
SEFS would also argue that the conclusions of the SA will lead to the breach of Core objective (i) of the Plan which is “to get the right balance between planning for economic, environmental and social benefits …”

Housing Provision Set as A Minimum Level – Chap 7(4), 7(7)
The further assessment of the Sustainability of the Plan is also called into question by the setting of the housing levels as a minimum. The Sustainability Appraisal highlights the fact that this cannot be assessed for its implications (SA 3.8.11) so meaningful sustainability tests are impossible to undertake.
Weakened Policy on Environmental Design Standards Chap 5(12, 15 &16), Chap 9(4 & 40)
We are particularly concerned that where the Plan has tried to take a regionally focussed strategic lead on increasing environmental design standards to encourage the highest possible level of water and energy efficiency in new buildings, the Secretary of State has proposed to weaken these policies. Given the high growth levels planned for the region and the acknowledged environmental impacts of this, it would seem appropriate to set a regionally specific policy in these key areas which might mitigate some of the negative impacts of other policies.

Conclusion
Despite what is to be recommended in the Plan, the points on which we oppose the Secretary of State’s Proposed Changes and the further concerns listed above suggest that this is not a blueprint for Sustainable Development and as such the Plan cannot be supported. Indeed it could potentially be viewed as unsound, not fit for purpose and open to legal challenge.
It is clear that further work needs to be carried out to assess the cumulative impacts of the Plan as amended before it can be adopted.
The Secretary of State has an opportunity to remedy the failure of the South East Plan to meet both legal and policy objectives to contribute to achieving sustainable development. The information necessary to re-cast the Plan to achieve this is presented in the suite of sustainability appraisal and appropriate assessment documents that have been produced at key stages in the preparation of the draft South East Plan.
SEFS strongly recommends that the Secretary of State should take the time necessary to adjust the South East Plan prior to adopting this RSS taking these comments and the conclusion of the Sustainability Appraisal fully into account in the final published version of the South East Plan.