ERA response June 2006
A.
Climate change:
1. Agree with the basic premise, however, the objectives are unrealistic given the minimal resources allocated (£146,000 identified in HCC budget) and the token grants available. The issue needs to be taken much more seriously.
2. The section on page 10 should be modified since the Integrated Regional Framework Objective calls for us to address causes of climate change through reducing emissions of greenhouse gasses. There is no statement about reducing greenhouse gasses, only about reducing emissions from existing developments. Propose following change to the bullet point on page 10:
§ reducing
emissions from existing development and only adding new developments at a rate
that will avoid a rise in total Borough emissions; and …
B.
Biodiversity:
1. Six Local Nature Reserves are identified on page 12 but only four are given in Appendix 2, section 12. In addition, Gunners Point is given on page 12 and Gutner Point in Appendix 2. Gutner Point is given in the HBDWLP as an LNR. Both Gunner Point and Gutner Farm are on the OS map and about three miles apart but no ‘Gunners Point’ or ‘Gutner Point’. Also line 6 of the penultimate paragraph on page 11 refers to ‘Havant Island’, which is presumably meant to be ‘Hayling Island’. The facts need to be checked!
2. A paragraph should be added to this section to enlarge on some of the points made in the text:
·
Existing nature conservation areas will be
retained and enhanced in their existing locations whether they are SPAs, SACs,
or SSSIs. SINCs will also be supported as will local nature conservation areas
supported by volunteers. The open spaces which border these areas and/or form
wildlife corridors will be protected along with the areas themselves.
Consideration of planning applications for development outside the nature
conservation areas will take into account and guard against potential risks to the
biodiversity and biomass of the areas themselves.
C.
Landscape and townscape:
1. General street scene and townscape issues are not addressed, especially with regard to trees.
2. The summary in Table 3.1 page 9 states,
“There is a need to protect and enhance areas of important landscape character. This includes areas of open space as well as how built settlements relate to each other.”
There is hardly any mention of this in the detailed section. Reference should surely be made to the role of Strategic Gaps in separating distinct settlements and the relationship between townscape and landscape.
§ This will ensure that the small town
centres such as Emsworth retain their individuality and vibrancy.
4. The Integrated Regional Framework Objective calls for
efficiency in land use through the re-use of previously developed land. However
the policy that most gardens can be considered as ‘brownfield’ needs to be
considered in relation to the character of the surrounding area as evidenced in
the variations in planning guidelines now emerging from central government. A bullet point should be added saying:
§ maximise the use of brown-field building
sites, preferably at a higher level than the 60% guideline. Gardens in
residential areas however should not automatically be considered eligible for
such use.
D.
Countryside:
1. Map 3.2 is not very clear, especially with regard to ancient woodland. It would also be helpful if the coastline was drawn in around Hayling Island and Emsworth.
2. On page 13, the last paragraph should be extended as follows:
§
All gaps should be maintained and enhanced to
ensure wildlife corridors are retained between the Chichester Harbour AONB, the
Sussex Downs AONB and the East Hampshire AONB.
3. The hydraulic impact on parts of the coastline brought about through the actions of other local authority/developers along a different part of the coast is now well documented. It is therefore important that unilateral coastline developments should not be permitted. Consultation is not a sufficient tool to protect the coastline. There should be a mechanism whereby consent must be obtained from any local authority likely to be affected by the development proposals of another authority/developer along the south coast.
E.
Regeneration:
1. The proposals have attached themselves too closely to the idea that Havant must achieve the growth target of 3.5%. It is not essential for such a target to apply to all areas within the SE. Some areas will be more and others less and in any case the average is too high. A target closer to 3.25% by 2021-2026 would be preferable if the Borough insists on sticking to GVA. There should also be other factors considered such as quality of life.
2. Regeneration should be initially for the benefit of existing residents. This is a sustainable objective, not the provision of jobs for more highly skilled and affluent people from other parts of the country or world. On page 14 extend the last sentence of the first paragraph as follows:
§ …… and infrastructure support to ensure the
lives of existing deprived residents are improved.
3. Too often ‘regeneration’ is taken to mean growth expressed as a simple increase of Gross Value Added (GVA) or Gross Domestic Product (GDP) this is not sustainable. (See response to Q2).
F.
Housing:
1. On page 9 in the definition of housing, further examples should be added as follows:
(e.g.
schools, dentists, doctors, water supplies, drainage systems, waste disposal
and roads)
2. The PUSH plan being promoted by the Borough envisages unacceptably high and inconsistent levels of housing development over the period of the SE Plan. The document under review is about sustainability. Sustainability is a great word but the plans which envisage the sucking in of millions of people to the SE Region to chase employment in jobs that the current population cannot do, while these existing residents social conditions do not improve, is not a sustainable objective. This is not looking after the future this is chasing our tails and covering the country in concrete.
3. Housing development to provide homes for workers moving into the region will not increase the income of deprived communities within our area. (See response to Q2).4. The identified ‘need’ for a large number of houses is not compatible with other sustainability criteria.
5. The existence of the large area of social housing owned by Portsmouth City Council inevitably distorts the figures and therefore the statistics are unreliable. Until the run down parts of the Leigh Park and Wecock estates are upgraded and a real effort made to encourage a more diversified socio-economic mix the spiral of deprivation in those areas will continue.
6. The housing figures set out in the Key Baseline Data/Evidence (Hampshire Structure Plan) at 167 and the HBDWLP average at 199 are incompatible with those put forward by PUSH and recently endorsed by Havant Borough Council, i.e. 315 a year giving a total of 6301 between 2006 and 2026. These changes demonstrate how targets have been changed in recent months, first through the South East Plan and more recently added to by PUSH in order to “share out” the overprovision placed on Gosport and the later scheduling of the two SDAs proposed for South Hampshire (north of Fareham and Hedge End). The new level is an increase on the present level of 58% averaged over the 20 years and for the first 5 years an increase of 81%.
These targets are not justified by Havant Borough population figures. Population figures for the area have consistently declined since 1997 and this decline is predicted to continue to 2011 and beyond.
The uneven nature of this development will be difficult to manage and the whole plan appears entirely target driven and not driven by local needs. The Borough’s primary target should surely be resolving the needs of local people and then creating additional houses, if such an objective is sustainable and the infrastructure in place, for those demanded by the central governments directives. The following modifications to the bullet points listed on page 15 are therefore proposed:
§
Provide the homes needed for those present
residents in the Borough – This covers Havant Boroughs approach to local
housing market through planning, new housing provision primarily on brown-field
sites and use of existing housing stock on a need rather than a target led
basis.
§
A suitable home for everyone – This sets out the
Borough’s approach to the forms of intervention planned to meet the needs of
those present households that need specific help.
§
Building stronger communities – This maps out
Havant Borough’s approach to making sure that housing policy and practice
complements the efforts to improve neighbourhood management, promote urban
regeneration and create communities where people are proud to live.
§
Providing the infrastructure first – Following
the PUSH objective of ensuring that infrastructure is in place to meet the
needs of development, Havant Borough will allow development on a sustainable
basis that ensures the infrastructure and services are in place before or in
parallel with developments. This includes schools, dentists and doctors
together with sustainable water supplies, waste disposal, drainage systems and
roads.
G.
Employment:
1. This is an unrealistic aspiration as Havant Borough is part of a larger economic unit and we cannot control who has jobs and where they come from.
2. GDP is an over crude measure of prosperity.
3. Once again the baseline unemployment figures for the Borough are distorted by the number of people out of work on the large Portsmouth owned estates. Potential employers need to be encouraged, through effective incentives, to locate in or close to these areas. Greater incentives to provide training should also be offered, possibly via regional grant aid.
1. A real effort is needed here to match skills with jobs created without a massive influx of population.
2. The Borough may need to offer specific training packages to the unemployed in the Borough to suit them for the jobs to be made available by the employers being encouraged to locate in the area. Such training should be focused only on specific opportunities.
I. Resource efficiency:
1. Specification is unclear in that no base measure is given for the 30% reduction by 2010.
·
Reduce air pollution and ensure air quality
continues to improve.
3. The Integrated Regional Framework Objective calls for action on reducing the global social and environmental impact of consumption of resources by using of sustainably produced and local products and also the maintenance and improvement of water quality of the region’s rivers and coasts, and to achieve sustainable water resources management. It is therefore proposed adding the following paragraphs:
§ To
support the objective of using sustainably produced and local products Havant
Borough will ask developers to use sustainably produced and local materials and
will use them on its own development works and for other supplies. Wherever
possible these will be from within the Borough or at least the region and
developers will show how they will achieve this within their planning
submissions.
§ In
view of the sensitive nature of watercourses in the Borough, developers will be
asked to exercise extreme care to ensure that all developments are properly
designed to eliminate the risk of pollution.
3. Figure 3.5 on page 19 of the Sustainability Appraisal of the Core Strategy shows that the Havant area is over licensed for water abstraction. This is unsustainable and therefore an additional paragraph is suggested as follows:
§ Since
the figure shows a serious shortage of water in the area, a resolution to this
problem will be achieved before additional water usage is required by
substantial increases in new homes or other developments.
1. Not sustainable with the amount of growth planned, however, this growth itself is unsustainable.
2. After the paragraph on the bottom of page 19, the following should be added:
§
For this reason the Borough is opposed to the
importing of waste to the SE Region from elsewhere.
3. Most waste is not now sent to landfill – see question 2.
1. Primary Care Trusts are being
combined in a few months time and this document needs to be altered to reflect
this.
2. Add a paragraph in the bullet point list as follows:
§
Ensure that the “Care in Community” system being
introduced to replace in-patient treatment is measurably effective and has the
resources to provide a standard of care acceptable to the community.
3. The detailed map (3.8) which blocks in the harbour is very confusing as much of the area is water and therefore unpopulated. Surely it is possible to only shade parts of the area that are land and not sea! This map also suggests a negative perception in areas which are already identified as suffering social deprivation.
1. Different facilities are needed in different parts of the borough.
2. If the Borough Council wishes its Vision on Cultural Strategy to be taken seriously it ought to re-examine its recent decision to make large cuts in its contributions to Havant Museum (which now risks closure as a direct result), and the Leisure Centres at Havant and Waterlooville.
3. Youth projects across the borough especially in deprived areas are an essential part of building social inclusion. If grants from external bodies such as the lottery fund which are important for getting these projects off the ground are no longer available, the projects need to be funded from central resources. Failure to do this will result in future generations being disadvantaged. This has repercussions for community safety and crime and for the later employability of the young people involved as well as for the cultural and recreational value of the projects themselves.
Youth projects have an influence on socialising youth, see L3 above, and thus help with community safety.
1. More emphasis needs to be made on cycling.
2. Reduce road congestion & pollution levels by improving travel choice and reducing need to travel by car/lorry.
3. Statistics on injury, etc. are not useful without taking into account other variables such as land area and population.
4. Half fare and free bus passes will not encourage people to use public transport if the journey is like to be tortuous. HBC need to liase with HCC and the bus companies to provide through routes to link different parts of the Borough e.g., Emsworth to Waterlooville and other wards including Hayling Island. Given the increasingly ageing population action should be taken to avoid most travellers having to change busses at Havant in order to reach their destination.
The Environment Agency
are planning sea defence work along the Hampshire coast (Portchester to
Emsworth). Issues raised here are that land not built on (assets) will not have
sea defences reinforced unless the recreational use of the land is defined. The
Environment agency needs to be consulted regarding these plans which are in the
process of formulation.
There are complex issues about managed retreat for coastal farmland and balancing one aspect of nature conservation with another. Chichester Harbour Conservancy and English Nature are deeply involved here and not always in agreement. The above agencies should be fully consulted in this process.
B.
Biodiversity:
1. There are lists of Biodiversity Action Plan species for Hampshire (including endangered species) but the location of these species needs to be recorded and any changes monitored. There are many nature conservation groups in Havant Borough that keep records of the wildlife found on the various sites and these records should be made use of. In addition, many other organisations such as Butterfly Conservation, Hampshire Biodiversity Information Centre (Hbic), Hampshire Wildlife Trust keep records and should be consulted.
2. LNR status is being sought for Brook Meadow (SINC) in Emsworth. HBC internal documentation.
3. Farming for Wildlife initiatives are being taken by farmers on Hayling Island and other parts of Hampshire and West Sussex. This comes under the DEFRA England Rural Development Programme (ERDP) details are available from their website: http://www.defra.gov.uk/erdp/schemes/default.htm
The Emsworth Design Statement and the other local Design Statements should be treated as key documents when they are completed.
1. The guide “Environmental Quality in Spatial Planning” produced by the Countryside Agency, English Heritage, English Nature and the Environment Agency, makes it clear how planning authorities might achieve high standards of environmental quality in spatial planning.
2. The Forest of Bere Countryside project (Hampshire County Council) should be referred to and its proposals for access to the countryside incorporated.
1. The index of sustainable
growth should be considered as a target for plans rather than GVA alone.
Reference should be made to the UK Sustainable Development Commissioner Prof
Tim Jackson, of the University of Surrey, who has compared the increase in GDP
over the past 50 years with a number of other measures, including many that
have a direct bearing on our quality of life. The details are available from a
submission to SEEDA and can be found at: http://www.seeda.co.uk/news_&_events/event_reports/prosperity_&_sustainability/docs/TimJackson_files/frame.htm#slide0020.htm
2. The Market Town Initiative is currently being taken up in Emsworth and Hayling. Emsworth needs to be identified as a town centre in its own right. It already has a range of small, specialist shops run by independent retailers.
3. The definition of a town centre as having chain stores is too restrictive and has created a series of Clone Towns all looking very much the same. The ‘Clone Town Britain’ survey (New Economics Foundation survey 2004) acknowledged that Emsworth has fared better than most small towns in this respect being rated in the top 10 of the 103 surveyed as retaining most local identity.
4. Comments by SHUV (South Hampshire’s Unheard Voice) on the South East Plan express concern at the emphasis placed on the Gross Value Added economic target. They say that economic growth should not be a goal in its own right. The primary goal should be the well-being of society and the conservation of the resources and environment that sustain us. SHUV argues that an index, such as the ISEW, that measures changes in these things should replace the GVA target. These comments are supported. Reference: SHUV response to the Draft South East Regional Spatial Strategy.
This response supports comments made by SHUV (on the South East Plan that analyse the housing needs of the region as follows:
Paragraph 2.31 of the South East Plan states:
There is a requirement for new housing in south
Hampshire to cater for demographic changes (e.g. more one and two person
households and longer life expectancy). There is also a need to provide
sufficient new homes for workers helping the local economy to grow. This
strategy is to provide 80,000 dwellings during the 20 years to 2026. The type
of properties required in each district area should be informed by housing
market assessments.
“We cannot see how this will benefit people living in the deprived
communities of Rowner, Gosport, Leigh Park, Wecock Farm, and particular districts of Portsmouth.
Section D2, para 1.23iii of the SE Plan states that moving into the
region workers are likely to be better qualified than the workers already here.
Therefore, even if the unemployed are successfully upskilled, they will have
competition to attain the better-paid jobs that could lead to greater
prosperity.
A less optimistic outlook is that they will take on lower-paid jobs that
provide services to those with higher paid jobs, leading to the "hourglass
economy" described in the introduction to the Review of the Regional
Economic Strategy 2006-2016. This has a large number of high-earners (the top
of the hourglass), few middle-income earners (the waist of the hourglass) and a
large number of low-income earners (the base of the hour glass) providing
services for those at the top. We can't
see how this kind of economy will benefit reduce disparities within the region
- one of the goals of the SE Plan.
There is of course an even less optimistic outlook - given that the
"trickle-down" economic model has been discredited. That pessimistic
outlook is that the unemployed will remain so.
Encouraging workers to move to south Hampshire from other regions (section
E1 2.31) increases housing demand in an area that has already seen a great deal
of development. Our impression is that most people would say there has been too
much. Of course, the houses sold by private developers or rented out by private
landlords will go to the highest bidder. Attracting workers to this region -
particularly as they are likely to be better qualified - might lead to
indigenous workers being out-bid for the new homes that become available. So
people could see a further reduction in their quality of life due to
over-development for little gain in housing terms.”
Reference: SHUV response to
the Draft South East Regional Spatial Strategy.
The document from which these quotes are taken also has relevance for the following issues: G. Employment, N. Transport and O. Anti-Poverty as these are deeply interlinked.
The information on this seems to be outdated as the vast majority of non-recycled waste now goes for incineration (new waste incinerator in Portsmouth) rather than landfill. Incineration saves on landfill but acts as a disincentive to take recycling beyond the government minimum of 30%. The authors of this document need to confirm current status with HBC’s up-to-date statistics on waste in the Borough.
1. There are two areas which are not listed in the Draft SA Objectives. These are listed below and need developing with appropriate paragraphs:
·
Sustainable facilities for young people
·
Encourage increased engagement in cultural activity
2. The details in Table 4.1 could be modified as described below.
1. Housing. This should make reference to the priority need to solve the problems of existing residents before providing houses for unsustainable population increases. It should also make clear that the services and sustainable infrastructure are a prerequisite to development of further housing.
3. Equality and Poverty. It should be clear that the initial objective is to alleviate poverty for existing residents as the first priority.
6. Liveability and Sense of Place.
i. Since this is bound up with the opinions of those who live in the area, one of the key questions should be, “Will it be acceptable to the majority of residents?”
ii. It is especially the open spaces surrounding urban areas which separate them visually and physically from other areas, so add the question: “Will it maintain and enhance the separate identities of the different settlements which make up the borough?”
7. Accessibility/Transport: Add the question, “Will it reduce the level of air pollution?”
9. Regeneration and Land Use. In some cases the regeneration of land can destroy other neighbouring streets or areas. An additional question is proposed, “Will the renaissance destroy an existing area of acceptable and attractive houses or streets?”
13. Natural Landscape. Add a reference to open space within the urban areas with a question as follows: “Will it protect and enhance the open spaces within the urban areas, including resident’s gardens?”
14. Built and Historic Environment. Following through on the need to protect existing environments, add a question such as, “Will it avoid the destruction of attractive urban roads by infilling?”
16. Water Quality and Quantity. There appears to be no emphasis on creating more water availability which is necessary before any significant increase in population can be sustainable. Therefore add the question, “Will it increase the availability of water for a larger population?”
Although the new Habitat Regulations are still to come into force in September 2006, Development Plan Documents do have the potential to impact nature conservation sites of European importance. The sustainability criteria must be looked at as a whole since they all interact, especially with regard to sensitive ecological systems.
This impact could be caused by a combination of any the following:
· pollution of the many watercourses which run into Chichester Harbour AONB
· lower water flow in streams and rivers due to high levels of water abstraction causing for example increased salinity in the many semi-saline lagoons
· poorly or inadequately managed SuDS systems causing contamination of groundwater
· increased public access to the countryside without restriction causing destruction of wildlife and their habitats.