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8Bi.1 Does the sub-regional strategy provide a positive steer that will achieve the proposed increase in GVA of 3.5% per annum, while taking account of the environmental assets of South Hampshire and its surroundings?
1.1 The GVA increase of 3.5% pa envisaged by PUSH underpins the requirement for 80,000 dwellings. We agree with Hampshire County Council that this target is overly ambitious, especially with the threat of closure hanging over Portsmouth Dockyard, a major driver of the sub-region's economy. Therefore, some of the 80,000 dwellings should be held in reserve, pending monitoring over the first period of the plan, say 5 years.
1.2 Furthermore, the GVA can simply be raised by encouraging inward migration. Of the population forecasts for South Hampshire over the plan period, 6/7 of the increase of 74,000 is due to projected in-migration. By contrast, an increase in GVA per capita will tend to lead to, and can come from, an improvement in well-being, education, skills and employment prospects of existing residents. The Regional Economic Strategy's aim of a 3% GVA increase per capita - made up of increases in productivity per worker, increased activity rates and then in-migration - would seem a more rational ambition if the aim is also to improve quality of life. As the Sustainability Appraisal states, there needs to be a much clearer justification for this in-migration. Certainly, there has been a lack of public consultation on the extent of inward migration. It was not made clear in either Hants County Council's patchily-distributed and misleadingly-titled "Where Shall We Live?" document or the ICM phone poll.
1.3 It is claimed the sub-region has been “punching below its weight” in economic terms, and this is used as justification for putting economic growth hierarchically above the sub-region’s environmental assets, but assessment of the economic activity of the region is based on a large geographic grouping, NUTS level 3, that obscures the variation within the sub-region.
Figures from invest-in-southampton.co.uk for 2003 show that GVA per capita for Southampton (£18,237ph) and Portsmouth (£18,163ph) is not only above the Rest of Hampshire and IoW (£15,915) but the South East as a whole (£17,631). Discussions between SHUV and the Business School, University of Portsmouth confirmed that the cities, with Fareham, have outperformed the region. However, there are specific areas in Gosport (Rowner) and Havant (Leigh Park) and Portsmouth and Southampton that are amongst the most deprived in Europe.
1.4 The Rowner estate in Gosport is a prime example of an area where redevelopment of existing housing could renewe the neighbourhood renewal. photographs below show the centrepiece of the Rowner Estate, the derelict NAAFI , which is full of abandoned fridges, and areas of low quality housing and garaging. Any economic benefits from a north of Fareham SDA will not be felt here or in the rest of Gosport, which is isolated from the SDA by inadequate infrastructure. Gosport would be better served by measures to increase employment within the borough.
We cannot see how Leigh Park - where some families have not been employed for three generations - will benefit from the SDA or MDA. In fact, Leigh Park and Warren Park are examples of how large developments, segregated from urban centres by a lack of infrastructure, can struggle to thrive.
1.5 The diagram below indicates the effects on the most deprived communities of increasing GVA overall. If growth is achieved by encouraging significant in-migration into the already successful areas, disparities in income, skills and related factors, are likely to increase more sharply. The slope of the j-curve is steeper if there are extremes of wealth and poverty, whereas the slope is gentler, and the highs and lows less pronounced in a scenario where the worst performing areas are brought up towards the average.
It indicates that the effect of the current proposals will be that the deprived areas become even more deprived as they are geographically distant from the proposed better performing districts and are therefore unlikely to benefit from any "trickle down" of prosperity.
It also shows the alternative, but more difficult option of aiming for a distribution where the lowest performing wards are brought up towards the best sub-regional level, by concentrating development and infrastructure investment where it is most needed. The rate of increase is necessarily lower, but the principles are rooted in urban renaissance with consequent benefits for existing residents, and so better meets the aims of the overall plan policy.
1.6 A further flaw with the GVA figure is that it is workplace-based, so it does not take reflect the economic input of residents that commute outside the sub-region. Once again, this will lead to efforts being made to increase economic activity in commuter areas that already have high levels of economic participation and where additional development would impose a strain on the environment and infrastructure.
1.7 SHUV’s members, from across the entire sub-region, are of the view, that 80,000 dwellings exceeds the environmental capacity of the sub-region. This view is supported by the Sustainability Appraisal that states that the sub-regional strategies will increase the ecological footprint of the sub-regions in the absence of changes to central government policies. It also warns of water shortages for the South Hants sub-region.
1.8 The sub-region contains large areas of very rural character and significant landscape value. The Fareham SDA search area includes land that was designated as an “Area of Special Landscape Quality”. English Nature has stated that the extension to the Waterlooville MDA is an area characterised by attractive and ecologically rich landscapes.
1.9 The Appropriate Assessment lists a range of ways in which the planned development will impact on SPAs and SACs in the area, and states it was not possible to conclude that there would be no adverse effects due to increased water abstraction and effluent discharge and reduced air quality. Much more work, similar to that being carried out for the Thames Basin Heaths SPA, needs to be done before the scale, distribution and phasing of development can be determined.
2.0 In addition, we have not seen an assessment of the impact on the New Forest and the designated but yet to be confirmed South Downs National Park. It is likely that for employment purposes, a proportion of the SDA traffic would travel north-west towards Winchester and the A34 and similarly from the Waterlooville MDA north towards the Meon Valley. This will have a marked effect on villages such as Wickham and will increase traffic through areas designated as South Downs National Park. Employment sites would be better located within or nearer to the large urban centres to discourage additional traffic pressures through nationally designated landscapes and rural communities.
2.1 A Tranquillity Map has been prepared by CPRE (with red indicating least tranquil). There are areas of tranquillity to the north of the M27, which will be compromised by the SDAs and MDA.
2.2 The PUSH documentation states (Background Document 2) that: “the coastal margin is heavily urbanised and the remaining open spaces are highly valued, as in the retention of the separate identity of settlements”. It is true that separate identities of settlements are highly valued, which is one reason why we object to the SDA bridging the gap between Fareham and Wickham.
2.3 It is claimed that the SDAs have removed the need to consider urban extensions to Fareham and Eastleigh (2.22 PUSH Background Document 2). However, there has not been any comparison made of the relative sustainability of the sites, at least not one that has been made public. This is vital information that the public did not have when asked to participate in the PUSH consultation. There may be the possibility of more sustainable sites within the already “urbanised” curtilage.
8Bi.2 Is there sufficient guidance about what action needs to be taken by LPAs to assist the achievement of this GVA growth rate, in term of identification of employment land and of priorities for employment sites?
2.4 The overall aim of concentrating employment in or near to urban areas is well established, and we support the principle of continued urban regeneration and renaissance, wherever possible minimising land take and avoiding significant environmental impacts.
2.5 More emphasis should be placed on smart working; not always requiring additional premises. Insufficient regard has been placed on increases in productivity and longer working lives leading to intrinsic growth. Employment sites at Whiteley have been vacant for some time, some proof that the theoretical juxtaposition of new employment sites and housing does not always result in sustainable transport patterns and that the characteristics of individual sites must be studied closely.
2.6 The provision of employment growth and regeneration with a lower ‘environmental footprint’ would be a useful steer for South Hampshire. There is a great deal of expertise in the region’s universities and businesses to make this possible, and suggests that there should be a concentration within Southampton and Portsmouth for spin-offs associated with higher education.
8Bi.3 Does the proposed strategy adequately reflect the role and potential of Southampton and Portsmouth, including Southampton Airport and Southampton Port?
2.7 We note Southampton Airport plans include an increase in traffic by a factor of 4 over the plan period, and that the proposed extension to Southampton Port into Dibden Bay was, rightly, refused after an extensive public inquiry.
8Bi.4 Is there sufficient focus on the needs and potential of the city centres? Are the proposals for office development appropriate and properly justified, having regard to the guidance in PPS6 (Policy SH8)?
2.8 The Plan contains insufficient ambitions for making the centres pleasant, aspirational places to live and work. Southampton is currently closing secondary schools due to lower numbers of pupils. Announcements on the closure of Millbrook and Woolston Senior Schools have been made in the last month. John Denham MP was quoted as saying “Southampton could be a city without families”. Cllr Gerald Vernon-Jackson, leader of Portsmouth City Council, stated that Portsmouth schools are suffering from falling roles. This situation can only be reversed if city sites are not abandoned in favour of suburban living, a process that is unlikely to be helped by the provision of the SDAs.
2.9 The north of Fareham SDA is located some distance from the centre of Portsmouth, as is the Waterlooville MDA extension. The only direct means of transport to or from Portsmouth from either site is by vehicle, and there is already serious congestion on roads at peak times. The Hedge End SDA is likely to form a dormitory for commuters to London. The direct rail service is already popular with existing residents. The Hedge End SDA will probably act as new development at Chandlers Ford and North Baddesley already has: it will draw more residents out of Southampton.
3.0 Anne Powers, Professor of Social Policy, at the London School of Economics, with whom we have discussed the sub-regional plans, has said that the SDAs will almost certainly have negative effects on the deprived areas by attracting the more able-bodied and better off and will almost certainly have negative effects on the cities themselves because they will disperse population. Lord Rogers states in "Towards a Strong Urban Renaissance" that: “Done wrong, development can increase pollution, widen social and economic inequalities and deprive future generations of environmental assets.” We believe that the SDAs will damage the prospects for urban regeneration in the cities as well as areas outside the cities such as Leigh Park and Rowner, a point picked up by the Sustainability Appraisal.
3.1 Colin Buchanan's report stated that Gosport should be one of the first locations for new development. Certainly Rowner should be re-developed, but this has not been made a priority in the final SE Plan draft. We fear the SDA will actually make the regeneration of places like Rowner and Leigh Park more unlikely by drawing investment away to easier to develop greenfield sites.
8Bii.1 Is the proposed housing provision figure for the sub-region at the most appropriate level, taking account of social, environmental, economic and other factors (Policy SH12)?
1.1 Housing should be built to meet indigenous need, but only 57% of the planned housing is to accommodate local people. The remainder is to accommodate in-migration. To facilitate the inward migration from other parts of the country deprives those areas of the migrants' talent and energy. It wastes the infrastructure that already exists and puts additional pressure on a sub-region that is already struggling environmentally. It essentially gives up on long-term unemployed residents of south Hants.
1.2 The Sustainability Appraisal (SA) of the sub-regional strategies raises general concerns about their impact on flooding, water supply and treatment, the impact on SPAs/SACs sites, and the failure to address the link between waste management and development. It judges that without changes to central Government policies, the sub-regional strategies will increase the ecological footprint of the region.
1.3 The Appropriate Assessment (AA) has stated that the phasing, location and even overall numbers of housing may have to be revised for South Hampshire if it becomes clear that new effluent infrastructure is not in place prior to, or in step with, development. This is due to the additional volume of treated effluent that will be poured into the Solent and the possibility that this will lead to eutrophication of SPAs/SACs sites. The quantity may be such that, even with best available technology, the increase in volume may affect the integrity of these sites.
1.4 The AA also says that it is not possible to conclude that there will be no adverse effects on SACs/SPAs in the sub-region through increased water abstraction. The SA for the specific South Hampshire sub-regional strategy says that all the development options will result in water deficits in some areas without additional water infrastructure, and that air quality will worsen unless the sub-region attracts major government funding for public transport. Yet the recent announcement on transport funding for the sub-region makes that seem unlikely. We conclude that the proposed level of development is unsustainable.
1.5 The GVA increase of 3.5% pa envisaged by PUSH underpins the requirement for 80,000 dwellings. We agree with Hampshire County Council that this target is overly ambitious, especially with the threat of closure hanging over Portsmouth Dockyard, a major driver of the sub-region's economy. Therefore, some of the 80,000 dwellings should be held in reserve, pending monitoring over the first period of the plan, say 5 years.
1.6 A greater emphasis should be given to reducing the number of empty homes. This would reduce the amount of new-build required. According to the Empty Homes Agency, the SE region is one of only two regions in which numbers are rising. There are 5,858 homes in private ownership that have been empty for more than six months, of which 1,528 are in Southampton alone. These represent a significant wasted resource and a focus for anti-social behaviour.
1.7 We contacted Gosport, Fareham, Portsmouth, Havant, & Winchester councils with an Empty Homes Agency questionnaire about their approach to empty properties. Portsmouth did not reply. Winchester candidly replied that it did not have an empty homes strategy, although this was being considered. Winchester has an estimated 425 empty properties. Gosport and Havant's strategies had some omissions. Fareham's was better, but in all three cases there was much more that could be done according to the Empty Homes Agency's criteria. Targets for bringing empty properties into use were low for all three councils - between five and ten per annum. Expectations should be raised in response to the new Empty Dwelling Management Order power.
1.8 A survey was carried out to assess the availability of rental property based on adverts in the The News' weekly Property Guide and also contact with letting agents. It was estimated that there were 850 properties available every week. This is a considerable number, yet it does not seem to be reflected in estimations of housing availability.
8Bii.2 Is the level of affordable housing justified and capable of being implemented (Policy SH13)?
2.1 In a letter (3 August 2006) to us Baroness Andrews said: "As we made clear in the Barker response, in addition to increasing the rate of house building, more homes need to be made available for shared ownership and social rent. We have already made progress in meeting this need, providing funding to help deliver an extra 10,000 social homes per year by 2007/08 compared to 2004/05, which is a 50 per cent increase." Ten thousand homes nationally seems a shockingly low figure and shows the extent the Government is relying on builders to provide social housing through the quota approach. Permitting 80,000 homes South Hampshire in order to facilitate an adequate amount of affordable housing is not a sustainable mechanism for meeting local need.
8Bii.3 Are the proposals for the SDAs justified and appropriate (Policy SH2)? How will they contribute to meeting the need for socio-economic regeneration of parts of the sub-region, particularly in its urban centres? In the absence of detailed assessment, is the specificity about the SDA locations appropriate? Is the approach to phasing set out in paragraph 2.6 realistic and achievable?
3.1 To be specific about the SDA locations in the absence of detailed assessment seems illogical. No evidence has been offered to show how these locations will channel prosperity to areas in South Hampshire in need of regeneration. No plans for transport infrastructure have been produced. There has been no assessment about their sustainability in comparison with other sites. Employment acreage adjacent to Fareham has been offered by developers, but has not been the subject of public comparative evaluation.
3.2 The SDAs will compete with Rowner in Gosport, Leigh Park in Havant, and parts of Portsmouth and Southampton for the capital that is needed for regeneration. The deal to regenerate Rowner is proving a very difficult to put together and the north Fareham SDA will jeopardise its completion by providing an easier site on which to build.
The former NAAFI is full of abandoned fridges (bottom left) and some have spilled out into the car park under the threadbare "shopping centre".
3.2 It is impossible to see how prosperity will "ripple out" from the north Fareham SDA. Even though car ownership has rocketed, the poorest and most vulnerable people in our society are still reliant on public transport. Gosport would be at the other end of a notoriously-congested single carriageway road and two bus routes. Leigh Park is even more inaccessible by public transport. It is possible to reach Portsmouth by train from Fareham, but the roads between the station and the SDA are slow-moving at peak times. There are no guarantees that public transport funding will come forward and the indication from recent funding decisions is that it will not. Non-drivers will be effectively cut-off in and from the SDA.
3.3 The SDA will be linked to Portsmouth via a motorway. Increased use will create greenhouse gases and generate extra traffic on the threshold of the designated new National Park (English Nature raised concerns about the landscape impact of the SDA).
3.4 Therefore, paragraph 2.6 should be made stronger. It should state that the SDAs will not be developed while environmentally-sustainable brownfield sites remain undeveloped. Brownfield development increases the dwelling density of urban centres (see the Colin Buchanan and Partners study on self-containment in the PUSH Housing Background Document December 2005), making public transport and the provision of shops, leisure and public services within easy reach viable. Unused property and land in urban areas are also magnets for anti-social behaviour. The Ling report on previously-developed land suggests that the number of potential sites across the sub-regions has been under-estimated by 15%. If these sites are not utilised, urban regeneration will be threatened.
3.5 Under the current wording, it is easy to envisage that developers will hang back from developing brownfield sites as they are usually more costly to develop and save their capital for the SDAs. However, we accept that there will be exceptional circumstances where it is unsustainable to develop a brownfield site (e.g. because it is of exceptional wildlife value or is in a location inaccessible by public transport). These instances should be addressed through the Local Development Frameworks.
3.6 Neither the SDA nor any other development should proceed until the infrastructure is in place. There have been too many instances of communities waiting years for infrastructure. The 10,000 residents of Whiteley, near Fareham, began moving in 15 years ago. Until December 2006, the GP surgery was in temporary huts. As many as 40 children a year are rejected from the over-subscribed primary school. Commuters are still waiting for the completion of Whitely Way, the main access to the M27. This delay has led to another renown zone of congestion. Gosport was to have a cinema built by the developers of Clarence Yard.
3.7 The north of Fareham SDA is inappropriate because of the impact on the designated South Downs National Park. Section 62 of the 1995 Environment Act places a duty on all relevant authorities to have regard to National Park purposes when coming to decisions that affect the National Parks. Where there is conflict between the purposes, greater weight shall be given to conserving and enhancing natural beauty, wildlife and cultural heritage, so that the beauty and ecological qualities of the national parks may be maintained. The Push Housing Background Document states that “regard” has been paid to the purposes, and that there should be no undue adverse impact on the two National Parks adjacent to the sub-region. However, it is demonstrable that there will be increased traffic, noise, pollution, light spillage and visual impact, in particular from the SDA at Fareham, the Waterlooville MDA extension, and the allocation to East Hampshire as the CPRE tranquility map below shows.
Although the PUSH document states there are unlikely to be high buildings that affect views from the Park, the subsequent photograph shows the Fareham Civic Centre, taken from several miles inside the National Park, with the area of search of the SDA directly between. It cannot but affect the National Park.
8Bii.4 In all other respects, is the proposed apportionment of the overall housing provision figures to the Districts at the most appropriate level, taking account of the balance between brownfield/ greenfield, and other socio-economic and environmental factors?
4.1 The allocation to districts allows no flexibility for circumstances to change, such the closure of Portsmouth dockyard, which would have a huge effect on the sub-region's economy. At least the allocation to the SDAs and MDA should be held in reserve pending a review of site availability (and infrastructure provision) after the first 5 years of the plan period.
4.2 The Housing Background document published by PUSH in December 2005 says district councils generally feel that the figure of 38k homes to be build on previously developed land within cities and towns is too low. Eastleigh feels 50k is more appropriate. Havant and the New Forest support an increase and Winchester considers that there should be a target of at least 55k to reflect the greater sustainability of utilising this land. In the light of these opinions and the Ling report, we feel that the figures need to be reviewed.
4.3 If a target of 55k brownfield land was used in order to encourage more sustainable use of the land, this would be 68% of the 80,000 homes proposed, which is entirely reasonable given recent performance in the sub-region. A more ambitious target of 75%, which would comprise 60k dwellings, would mean that no large greenfield sites would be required.
4.4 PUSH's Housing Document states that the allocation to the three southern parishes of East Hampshire should have no detrimental impact on the designated South Downs National Park, since a population increase of only 300 was anticipated. This is disingenuous, since an allocation of 1500 dwellings is likely to lead to a significantly higher population increase than 300.
8Bii.5 How should the relationship between employment growth and release of housing land be managed (Policy SH5)?
5.1 Employment land should be located where employment is most needed. Similarly housing land release should be focussed on those areas requiring socio-economic regeneration, infrastructure investment and improvement. An annual evaluation, such as the Hampshire County Structure Plan H4 policy, should be utilised along with an additional policy to include levels of deprivation and targets for its amelioration, in order to ascertain where housing land should be released.
8Bii.6 Is the policy for Strategic Gaps properly justified (Policy SH3)?
6.1 The boundaries of the New Forest National Park and the designated South Downs National Park are contiguous with the South Hampshire sub-region. We support suggestions by Hampshire County Council and the Hampshire Wildlife Trust that Greenbelts be considered along the southern boundary of the South Downs to “secure adequate separation” of the National Park and the South Hampshire urban expansions.
1. ‘We were limited to 2000 words On housing strategy. There's a lot more that we could have said.’ Claire Smith 2. SHUV is PARTICIPANT No. 7140 in the South East Plan Enquiry