Proposed Changes to Draft South East Plan
CPRE South East
Campaigning to Protect the South East's Countryside
October 2008
CPRE South East has responded to the government’s latest proposals for the South East Plan. It told the government that "the environmental quality and quality of life of the South East will decline overall if this Plan is carried to its conclusion." In its comments on the Secretary of State's proposed revisions it criticised the government for a "dogged commitment to uncertain data and an unswerving determination to build housing in numbers beyond capacities or proven need in the region". The government's introduction of a plethora of initiatives (such as New Growth Points) alongside the SEP "creates an impression that the Government has little commitment to the planning system". CPRE SE questions "the level of attention given by government to the views of stakeholders and local people", especially in relation to subregions. The SEP imposes narrowly defined economic targets and housing policies with little or no regard for the implications on infrastructure and the environment. The role of Hubs has become confused and CPRE calls for a return to their original transport focus. 'Late additions' such as Bordon/Whitehill and Shoreham Harbour should have a 'provisional' status.
SDAs. CPRE SE said that the government should remove the Strategic Development Areas South of Oxford; East of the M1 at Milton Keynes; and at Shoreham, West Sussex. The SDA North of Fareham should be regarded as a 'reserve' and that at South West Reading should be subject to further testing, especially in relation to flood risk management.
Housing. Wording that suggests that housing targets in the plan are minimal levels should be removed. CPRE says that in current conditions "it is extremely doubtful that existing housing targets are deliverable - higher targets even less so" and to impose unachievable targets in planning authorities is unfair and inconsistent with national planning policy. It is calling for a phased approach with lower targets in the short-term.
Green space. At least 75% of all new development should be on previously developed land, not the 60% proposed in the SEP. CPRE SE does not accept the need for small scale local reviews of green belt, or a review of the green belt to the south of Oxford. " We vigorously object to major reviews that undermine the character of the cities the green belt aims to protect." CPRE also objects to the removal of the policy on strategic gaps. The new policy on green infrastructure is supported. There is an over-emphasis on the role of environmental scheme funding to maintain landscape quality; CPRE says this alone cannot be the basis of a vibrant and well-managed countryside.
Rural areas and communities. CPRE says that the statement that "extensive parts of the region are largely undeveloped" is symptomatic of the planning mindset in the South East and demonstrates an approach that views urban as superior to rural. Where development is necessary in smaller towns and villages, CPRE says it must be located "where it will increase local self-sufficiency and tackle identified deficiencies, whilst protecting, and where possible, enhancing the quality and character of the wider countryside".
Infrastructure and transport. CPRE says the new policy wording goes some way to ensuring the timely delivery of infrastructure, but it is concerned that the proposed emphasis on behaviour change and demand management to free up capacity is unlikely to free up sufficient capacity in infrastructure to meet the needs of new development. CPRE supports demand management in rural areas and says that actions such as traffic calming are important to the character, tranquillity and safety of the countryside in the South East. The environmental impacts of airport expansion, including noise, emissions, and increased demands on infrastructure, and how they might be mitigated, should be acknowledged.
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