To: Housing consultation, Transport and Environment – C2, East Sussex County Council, Freepost (LW43), Lewes, East Sussex. BN7 1UE
13/10/2005

Dear Sir

RE: Consultation questionnaire on new homes for East Sussex 2006 - 2026

Thank you for sending me a copy of the above consultation document and questionnaire. I have completed the questionnaire but would also like to make some additional comments on behalf of the Sussex Wildlife Trust.

The Trust appreciates the work done by ESCC to find ways of satisfying government aspirations for development levels in East Sussex, and we understand that these levels have been set in the South East Plan. Our response to the South East Plan was, however, extremely critical. We see it as a very contradictory document, with policies promoting sustainable development and environmental enhancement but with actions promoting levels of growth and development that will inevitably compromise any pretensions towards sustainability. Our view is that the current South East Plan will not last the full 20 years without a major change in direction towards a more sustainable approach. This will have inevitable repercussions on future development strategies in the Counties. In other words we see this as a temporary document, that will not stand the test of time and, and when changed it will significantly alter the approaches required of County Councils.

The current South East Plan puts ESCC in the impossible position of having to deliver an unsustainable level of house building in a county that is already very environmentally stressed. The traditional approach to development promoted in the South East Plan also diverts attention away from more fruitful discussions that should be taking place regarding sustainable development. Old presumptions therefore remain and unfortunately these are evident in the construction of the questionnaire. Traditional development consists of a treadmill of: more people – more homes – more jobs – more development – needing more people – and hence more homes again. A spiral of development that is unsustainable and environmentally damaging.

Our response to “new homes for East Sussex” is therefore relatively negative in that most of our answers express the view that house building figures are too high in all areas. We therefore do not offer alternative ideas for where they should go (as we do not accept the overall figure). We also do not accept some of the leading questions, for example Q9b, which implies acceptance of the level of housing growth.

Three issues expose the unsustainablity of the current approach: water resources, transport problems and waste. Others will undoubtedly follow within the next 20 years (energy, resources and the effects of climate change as well as the long-term consequences of biodiversity losses and ecosystem damage):

Water is a limited resource that is putting a constraint on development. It is the resource that is constrained, investing in more infrastructure will not solve the problem (one can not exploit what is not there).
Transport congestion is a well-known problem. Again this will not be cured by investment, most forms of investment simply driving more transport and more congestion.
Recycling figures are getting better but waste remains an intractable problem. More development will add to the problem in a constrained environment with little potential to solve its waste problems.
These issues are leading to environmental damage with threat and actual loss to wildlife and wildlife habitats.

These issues mean that the Sussex Wildlife Trust does not accept the overall levels of housing proposed for East Sussex. We realise that the proposal is for a lower rate of average build than in the past, but this is of little help. The “easy” decisions have been made, there are few places left to build that would not have a damaging effect, there are few places left to in-fill – as the restricted opportunity on brown field land would indicate. The building levels of the past have effectively brought the county up to (and probably beyond) its environmental limits.

Question 7 in the questionnaire is another leading question that seems to accept the old fashioned presumptions referred to above. House building alone will deliver none of the benefits listed, the situation is far more complex. Each one of the issues listed may need to be addressed through a particular plan, but house building may or may not be part of that plan. An example may be social housing. Building more homes will simply add houses to the market, which will then be bought by people who can afford them, not the people who require social housing. It is unlikely even to bring house prices down, and hence make houses more affordable, because to do so would require a flooding of the second and third homes market first. Providing social housing is far more complex than just building houses. It is incorrect for a questionnaire to lead people into selecting amongst unproven presumed benefits.

A major area of concern is absent from the questionnaire. This may be deemed outside the realm of study but is, nonetheless, fundamentally important to the acceptability of any level of house building. This is the quality of the design and build of any development. A main reason for the objections to current housing plans is the extremely low environmental quality of house building to date. Any future plan for housing should expect far better build quality than we have had to accept in the past. New housing must be expected to incorporate a positive environmental plan with on- and off-site mitigation measures that deliver major contributions to biodiversity. Major environmental enhancements should be expected as a matter of course alongside new development. Furthermore the houses themselves should be far better than in the past. For example, best available technology should be used for energy conservation, energy generation measures (solar cells, solar panels and wind generators) and water efficiency (low water use systems and grey water recycling) and so on. New development should, of course, be integrated with planning and transport options so that the need to travel is reduced as much as possible. We are unable to point to any examples in East Sussex of houses that are built to adequate environmental standards.

To summarise therefore, although we recognise that ESCC is in a position of needing to find locations for a housing allocation we do not accept the need for such high levels of house building forced on the county by the South East Plan. We consider that the South East Plan has not adequately addressed the need for sustainable development. The practical implication of this may be that, in its plans, ESCC may have to allow for a significant change of direction in a future South East Plan that far more adequately addresses sustainable development. In the meantime very great attention needs to be paid to the environmental quality of all new development.

I hope these comments are useful. Please do not hesitate to contact me if I can be of any further help.

Yours truly,

Dr A Whitbread