To: Planning Services
Environment and Development West Sussex County Council
The Grange Tower Street Chichester West Sussex PO19 1BR
26/10/2005

Dear Sir

South East Plan: employment, housing and infrastructure in West Sussex

Thank you for sending me a copy of the above consultation. I have read this and would now like to make the following comments on behalf of the Sussex Wildlife Trust.

The Trust appreciates the work done by WSCC to find ways of satisfying government aspirations for development levels in the sub region as directed by the South East Plan. Our response to the SE Plan was, however, extremely critical. We see it as a contradictory document, with policies promoting sustainable development and environmental enhancement on the one hand, but with actions promoting levels of growth and development that will inevitably compromise any pretensions towards sustainability on the other. Our view is that the current SE Plan will not last long into its 20-year term 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 the SE Plan is a temporary document, that will not stand the test of time and when changed it will significantly alter the approaches required of County Councils.

The current SE Plan puts WSCC in the impossible position of having to deliver an unsustainable level of house building in a county that is already environmentally stressed. Old presumptions for development predominate in the SE Plan. These consist 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. This traditional approach to development diverts attention away from more fruitful discussions that should be taking place regarding sustainable development.

Environmental appraisal.
The SWT considers that decisions regarding the distribution of housing and the location of employment land should be made on the basis of an appropriate sustainability appraisal. Among other sustainability considerations, therefore, decisions on the location of housing and employment should be based on minimising the impact on biodiversity, especially where that impact would be on:

Sites of international or national importance;

Species of international importance (e.g. Habitats Directive Annex 1 species);

Species of national importance, particularly UK Biodiversity Action Plan (BAP) priority species for which site protection is considered to be critical;

Habitats of national importance, particularly UK BAP priority habitats;

The interconnectivity of habitats at a wider landscape scale.

Such an approach is identified as necessary in PPS9, which states the following, as a key principle:
‘In taking decisions, local planning authorities should ensure that appropriate weight is attached to designated sites of international, national and local importance; protected species; and to biodiversity and geological interests within the wider environment.’

PPS9 further states that the information necessary to inform such an approach should be made available, including at a sub-regional level, viz:
‘Regional planning bodies should liaise closely with regional biodiversity forums or equivalent bodies, English Nature or its successors and the Environment Agency to identify the current regional and sub-regional distribution of priority habitats and species, internationally and nationally designated areas, and broad areas for habitat restoration and re-creation.’

It is therefore clearly the responsibility of the relevant planning authority to secure and assess the necessary data to ensure that decisions are evidence-based. Furthermore, such information should be presented so that consultees can make properly informed responses to consultations. It is, however, not clear that such an environmental appraisal has been integrated into the development of the proposed scenarios in “Housing, Jobs and infrastructure in West Sussex”. Even if it has, the environmental implications of the proposed scenarios are not clear, hence consultees are unable to judge the environmental repercussions in their responses to questions in the questionnaire. .

Sustainability
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, the effects of climate change and 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.

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 already 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 beyond its environmental limits. Thus in question 2 we have agreed that as much housing as possible should be accommodated in existing urban areas, but this should not be translated into urban cramming. Many brownfield sites are very valuable to nature conservation and as actual or potential greenspces for people to enjoy (eg Keymer Tile works in East Grinstead and Shoreham Cement Works in Upper Beeding).

Levels of house building
It is inherent in the tenure of the consultation that there is a presumption that house building is needed in order to answer various social needs. This seems to have unquestioningly accepted the views of the house building lobby. House building alone will not answer any social needs; the situation is far more complex. Each social issue must 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 them. It will not bring house prices down (house prices are far more sensitive to other issues than the numbers being built), and hence will not make houses more affordable. To achieve this would require a flooding of the second and third homes market first. Providing social housing is far more complex than just building houses. The South East Plan and the sub-regional strategies coming out of it seem to play a numbers game rather than addressing the issue.

Our response to “Housing, jobs and infrastructure in West Sussex” is therefore relatively negative. We do not support the level of proposed development, do not consider that it has been properly environmentally appraised and do not consider that it sets a sustainable strategy for the future.

Quality of development
A major area of concern is absent from the consultation. This may be deemed outside the realm of the 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 minimised. We are unable to point to any examples in West Sussex of houses that are built to adequate environmental standards.

Infrastructure
In most people’s minds infrastructure means transport, usually roads. Hence the demand for more damaging roads in order to satisfy perceived needs from more damaging development. The nature of future transport infrastructure is very much open to question with increasing costs of energy and increasing congestion, yet current plans are very much based on an extrapolation of past trends. WSCC endeavours to achieve a more sustainable approach to transport have achieved some success. However, the basic driver behind unsustainable transport remains – there is a presumption in favour increasing travel to ever more distant locations. Indeed this is often deemed an economic good that must simply be delivered in perhaps the least environmentally damaging way. A far wider discussion is needed regarding infrastructure approaches in a constrained environment where localisation and reduced travel is favoured rather than the current emphasis on ever increasing and distant travel.

Green infrastructure
There is a major omission in question 4 of the questionnaire regarding green infrastructure (presumably allowed for under “other” in the questionnaire). This is required under policy NRM4(iv) of the SE Plan and should be a major consideration in any sub-regional strategy. Interconnectivity of habitat throughout the landscape is essential for the long-term conservation of biodiversity. It is also essential for long term environmental adaptability, the provision of future ecosystem services and for the sense of well-being of people living in and visiting the area. This sub-regional strategy should be led by an environmental vision for the county that highlights, protects and enhances its environmental assets. The lack of an environmental vision and the absence of a significant reference to green infrastructure are major and unacceptable omissions in “Housing, jobs and infrastructure in West Sussex”.

To summarise therefore, although we recognise that WSCC is in a position of having to find locations for a housing allocation, we do not accept the need for such high levels of house building forced on them by the SE Plan. We consider that the SE Plan has not adequately addressed the need for sustainable development. The practical implication of this may be that, in its plans, WSCC may have to allow for a significant change of direction in a future SE 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, including housing, employment development and built infrastructure and, more fundamentally, the strategy should be far more clearly led by an environmental vision.

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