Chapter 1: Overview

The draft Plan is honest in its stated objective to accommodate a "reasonable" level of development need. But because of the importance of the South East to the national economy, its interrelationship with London, together with the scale of its own housing needs, we do not consider this to be a sufficient response. (1.2)

The scale of housing growth proposed was the single most controversial issue within the representations to the draft Plan. (1.3)

Nevertheless we consider that the outcome has put too much weight on the results of consultation with existing residents. (1.4)

In e.g. the London Fringe (roughly Surrey as far South as Guildford and Reigate), we consider that proposed housing levels are inconsistent with meeting the needs of both the existing population and continued in-migration. (1.5)

Our recommendation is for an increase of 10%. We envisage 32,000 dpa (dwellings per annum, up from the Plan’s 28,900). It is precisely because we accept the strength of the Assembly’s (SEERA’s) arguments and much of its background work that we do not go higher. (1.6)

We are confident in apportioning our suggested increases to sub-regional level (e.g. to the London Fringe). But producing a district apportionment below this level, involves assumptions about capacity to accommodate new growth. (1.7)

This is probably the most difficult task we faced but it is inevitable that new green field land will have to be found, and we do not think it an appropriate yardstick that all land needs to have been identified before the Plan’s housing provision levels can be confirmed. (1.8)

The most sustainable solutions in some sub-regions will be for this new land to be found through selective green belt release. (1.10)

We do not consider that RSS (Regional Spatial Strategy, e.g. the Plan) housing levels in any sub-region or indeed the region can be made contingent upon the delivery of particular pieces of infrastructure. (1.19). (This breaks a fundamental theme of the draft Plan, that housing development be contingent on provision of essential infrastructure.)

Chapter 3

Other sources of underperformance against RPG9 (the present regional plan) are:

Continued growth in vehicle flows on the strategic road network, although overall traffic levels on the entire road network have remained broadly static;

Failure to provide necessary infrastructure in association with development. (3.4)

The topics we suggest are covered in the RSS objectives are:

Improve alignment between jobs and homes (this is a new objective)

Housing (substituting sufficient for reasonable)

Timely infrastructure provision (… but excluding mention of a dialogue with government) (3.20)

Clarify the vision by including social equity (ReH 3.1) (e.g. by balancing the needs of home seekers with the wishes of home owners.)

Chapter 4: Spatial Strategy

The 21 regional hubs are also intended to be a linchpin of the spatial strategy. (4.9)

We have later recommended a selective Green Belt review associated with at least two regional hubs (Oxford, Guildford) and possibly Woking. (Oxford has its own Green Belt.) (4.14)

The role of London Fringe would be strengthened under our recommendations. Our recommended spatial strategy would also highlight those hubs and other growth points intended to support significant residential development. In recommending a higher regional housing level, we see the hubs as the logical place for much of this higher growth to be accommodated. (4.39)

Acknowledge in the spatial strategy where a review of Green Belt may be necessary to accommodate major development. (Rec 4.2)

Indicate in the spatial strategy that the regional hubs offer significant advantages for sustainable development, particularly those within the inner South East, which are the logical place for much of the recommended higher growth to be accommodated. (Rec 4.4)

Chapter 5: Cross-Cutting Policies

We believe that the key role of the 21 hubs should be set out more explicitly as centres for:

investment in transport and other infrastructure

economic activity and employment

new housing development

rebalancing travel patterns by behavioural change. (5.49)

The opportunities for existing urban areas in the South East to accommodate ever increasing numbers of dwellings in a sustainable manner are very limited. (5.60)

There are particular tensions for the hubs within the Green Belt in fulfilling a development role. (5.61)

We recommend elsewhere, significantly more residential growth should be directed to some of the hubs, including Guildford and Oxford and we consider that selective review of the Green Belt at Guildford and Oxford, and possibly at Woking, is likely to be the most sustainable solution. (5.62)

Policy CC5 makes the scale and pace of development dependent on adequate infrastructure capacity. It states that development will not proceed until the infrastructure required to serve the development is available or will be provided in time. (5.77)

Participants are clearly divided between those who feel the principle is essential to the Plan and those who consider it to be wholly unrealistic. (5.79)

This is the number one issue for residents. (5.80)

Such conditionality is neither sound in concept nor realistic in practice (5.83). We therefore recommend that Policy CC5 iii should be deleted. Policy CC5 should stress the close relationship between development and infrastructure, the importance of timely delivery of infrastructure in relation to new housing, and the necessity of a joint approach (5.83)

Better management of existing infrastructure and behavioural change must be achieved if the strategy is to be sustainable. (5.92)

In Policy CC5: delete the reference to the conditional approach, and instead emphasize the close relationship between development and infrastructure; refer to a more proactive approach to pooling, tariffs and local delivery vehicles; delete the reference to a Concordat (with government) and replace it with a reference to the need jointly to develop forward funding mechanisms; and refer explicitly to the role of demand management. (Rec 5.5)

Amend Policy CC8b to give more weight to the relationship between the roles of hubs as a focus of accessibility and economic activity and the location of housing development. (Rec 5.10)

Expand the supporting text to Policy CC8a to include four identified roles of hubs (Rec 5.11)

Amend Policy CC10b to make clear that the designation of strategic gaps should only be necessary where gaps between settlements could not be protected by other landscape and countryside policies. (Rec 5.14)

Chapter 7: Housing Provision Levels

However any small differences in longevity, fertility and household size assumptions pale into insignificance in relation to the effect of migration assumptions (in assessing household projections) (7.17)

We cannot say whether there would be any discernable benefit at the regional level on affordability from our recommended increase in housing levels. This is not the primary driver behind our recommendations. (7.41)

The regional housing level that we recommend at the end of this chapter equates to that recommended by SEEDA for the short term (32,000). SEEDA also recommended that post 2011 this should rise to nearer 35,000. We do not go as far as this. (7.46)

Many individual local authorities maintained that their support for the draft Plan housing level for their district was "conditional" upon timely delivery of the necessary infrastructure. While we understand these concerns, we do not think that an RSS can proceed on this basis. (7.56)

There are undoubtedly real infrastructure challenges to be faced in the South East, e.g. it has the most congested road system outside London, and some radial rail lines are running at or near capacity. (7.57)

The draft Plan rightly puts the focus on a twin track approach, and it may be that a higher housing level will require a greater emphasis on demand management, particularly in relation to the transport system. (7.58)

We hope that Government and the Regional Assembly will see the delivery of infrastructure necessary to achieve higher housing as a shared challenge. (Wishful thinking?) (7.59)

We consider that the draft Plan’s housing provision of 37,360 (1,868 dpa) (for the London Fringe) is significantly too low because demographic and economic factors have been given insufficient weight, while too much weight has been given to urban potential estimates and avoiding any adjustments to the Green Belt:

There is a considerable misalignment between the forecast number of new jobs and expected labour supply. (7.77)

We consider that there should be sustainable solutions for accommodating a higher housing level taking account of public transport accessibility benefits of the regional hubs. It may well be that Greenfield development may require selective or small scale reviews of Green Belt boundaries. (7.78)

From Table 7.1: Recommended Housing Provision at Sub-Regional Level

London Fringe. Draft Plan 1,868 dpa. Panel recommended additional dpa: 438

Panel total increase as % of 2006 housing stock (draft Plan equivalent): 13 (10)

The most difficult task that we have faced is to apportion our recommended increase to particular districts to produce a revised district apportionment. We have no doubt that it will be very challenging for some local authorities to know how to accommodate this additional growth. Nevertheless new land will have to be found. (7.106)

From Table 7.2: Recommended Housing Provision at District Level

Guildford. Draft Plan dpa 322 Panel recommended addition dpa 100

(notes: Guildford has approx 55,000 dwellings. 422 X 20 is an increase of 15%

Guildford is one of seventy districts listed in Table 7.2.)

Increase the regional housing provision by 10% and revise levels for the sub-regions… in accordance with Table 7.1. (Rec 7.1)

Increase the district housing provision levels in accordance with Table 7.2. The largest increases should be in the economically more buoyant parts of the region. (Rec 7.3)

Chapter 8: Affordable Housing and Other Housing Policies

The density of new residential development has averaged over 38 dwellings per ha (dph) in the South East for the last two years. This has increased from just over 31 dph in 2001/02, when the region was first subject to a Density Direction requiring schemes at less than 30 dph to be referred .(8.35)

We also support the level of 40 dph for the regional target in Policy H5. In our view this presents the right degree of challenge at least in the short term. (8.37)

The initial emphasis of this policy (H5) should be on seeking high-quality design.

A cross reference would set the encouragement of higher densities within the context of design solutions which build on local character, distinctiveness and sense of place, and the use of development briefs and master plans as ways of achieving them.

There are significant opportunities for development in excess of 50 dph in many urban and suburban areas which "benefit from good public transport and existing higher levels of development density" (quote form para 6.2 of D3 of Plan). We consider that this guidance would be strengthened by exemplifying the opportunities for such high density development particularly in the centres of the regional hubs. (8.41)

Amend the supporting text to Policy H5 to note that local authorities may set higher or lower density targets than 40 dph, giving examples where higher densities are appropriate, cross referencing to Policy BE2 (Urban and Suburban Intensification) and acknowledging that lower densities may be appropriate in rural areas, and to clarify that the target relates to densities expressed in terms of net developable area (Rec 8.6)

Chapter 9: Transport

There is also a perception on the part of most county councils and unitary authorities and many other participants that congestion and traffic difficulties are symptoms of an "infrastructure deficit" which needs to be remedied before the accommodation of new growth is acceptable. But this perception is not shared by most environmental groups. (9.3)

In our view, while there are undoubtedly some transport corridors where highway improvements are required, it is inevitable that part of the answer to worsening congestion, to growth and future movement needs, and to the challenge of climate change must be that dependency on travel by cars has to be reduced. We believe that it is unrealistic to achieve an absolute reduction in traffic within the life of the plan. However we consider that there is scope for strengthening the message about demand management in the Plan. (9.4)

In relation to Policy T6 (Charging) our concern is whether the region is providing sufficient leadership on approaches to road user charging (RUC). (9.8)

The Regional Assembly and virtually all local authorities are looking to Government to give a lead on RUC. We agree that RUC is an issue on which leadership is necessary from Government and that local authorities cannot realistically be expected to take action to implement a charging regime without a national policy framework. (9.10)

Strengthen messages about demand management (Rec 9.1)

Amend Policy T5 (Mobility Management) to require LDDs and LTPs to include mobility management policies, reorder the list of measures, and add a reference to car clubs (Rec 9.2)

Amend the supporting text to Policy T5 to say that the likely mix of demand management measures in individual sub-regions will be indicated in each sub-regional strategy (Rec 9.3)

Amend Policy T6 on Charging to say that local authorities and particularly the hubs are strongly encouraged to make use of the Transport Act 2000 and Government funding to consider testing new charging initiatives jointly with other authorities as part of an overall strategy of demand management (Rec 9.4).

Add to the text at the end of the Transport section a list of regionally significant transport infrastructure (e.g. Airtrack) and indicate that full details of these and other schemes are in the Implementation Plan, and that key transport themes are identified in the sub-regional sections (Rec 9.12).

Chapter 12: Countryside and Landscape Management

We agree with many respondents who point out that under PPS7 AONBs and National Parks should receive the same level of protection. (12.13)

Chapter 13: Small Towns and Suburbs

Representations on the submission draft Plan revealed extensive concerns for "garden grabbing" particularly in suburban areas and the effects that incremental housing redevelopment can have in altering the character of neighbourhoods and towns 13.7).

We recommend that the policy (BE2: Urban and Suburban Intensification) is expanded to require the identification of suitable locations as a first step (13.8).

Amend Policy BE2 to require the identification of locations where intensification could assist wider planning objectives (Rec 13.1).

Chapter 14: Town Centres

The employment role of town centres that are designated as regional hubs needs to be more actively promoted. (14.2).

The policy should be used to highlight the hubs that will be the focus for significant growth. Ashford, Aylesbury, Crawley, Chatham, Guildford, Milton Keynes, Oxford, Portsmouth, Reading, Redhill-Reigate, Southampton and Woking should be identified as centres that are likely to undergo the most significant change. (14.11)

(Note: there are 21 hubs in the region.)

Amend the draft Plan to strengthen support for the employment role of town centres that are designated as Regional Hubs. (Rec 14.1).

Amend Policy TC2 (List of Strategic Network of 23 Primary and 26 Secondary Town Centres) to:

Identify that the centres that are likely to undergo the most significant change across the range of town centre uses and where pro-active strategies for town centre development will be particularly important are Ashford, Aylesbury, Guildford (see above list) (Rec 14.3)

Chapter 20: London Fringe

Out-commuting has increased but has been off-set by an even larger increase in in-commuting. (20.3)

But the sub-region’s main transport networks are already congested and the three regional hubs, Guildford, Woking and Redhill/Reigate are said not to have the capacity for major growth. (20.3)

The environmental interest groups generally are concerned that Policy LF1 (Core Strategy) gives insufficient recognition and protection to the environment, while the development sector is unanimous that the sub-region is not being asked to pull its weight. (20.12)

Policy LF1’s approach to the economy is restrictive and for the reasons set out in more detail below, we consider that it is unrealistic and would have harmful effects over a wide area (20.13).

Policy LF1 has started from the basis that no alteration of any substantive nature should be made to the boundaries of the MGB (Metropolitan Green Belt), but we consider that this is fundamentally wrong and in conflict with national policy guidance. As set out in more detail below, there is an overriding need to accommodate a higher level of housing provision in this part of the region, and this should be accommodated by limited alteration to the MGB boundary where necessary (20.15).

We have concluded that the hubs have more potential for sustainable growth than is permitted by the draft Plan. We also draw support from the Assembly’s description of the characteristics of the regional hubs which highlights the potential of Guildford in particular. Without offering some scope for physical expansion of the hubs beyond their existing boundaries if required, not only would the sub-regional and wider economy be likely to suffer, but fears of town cramming and loss of urban quality could be realised (20.17).

On the Assembly’s projections, the excess of jobs over labour supply (in the sub-region), which was around 13,000 in 2006, is expected to increase by an additional 22,000 or so between 2006-16 and by a further 29,500 between 2016-26 (20.22).

We have therefore recommended an increase in housing levels by about 23%, see Table 7.1 (20.27).

The selection of Guildford, Woking and Redhill/Reigate as regional hubs reflects the existing rail network. We accept that all three hubs require to be supported by additional infrastructure and particularly by public transport improvements to enable them to fulfil their regional role. If the Airtrack scheme is implemented it will strengthen the role of the Guildford and Woking hubs. (20.44).

On balance, we have concluded that the need for additional housing in this part of the region is so great that, taken together with all the other factors influencing the location of new housing, some alteration of the MGB boundaries is likely to be required (20.51).

Role of Hubs and Review of MGB (Policy LF4)

As referred to above, we consider that the hubs have more potential for sustainable growth than is permitted by the draft Plan. Guildford in particular is the home of the University of Surrey and is an important retail centre that serves a wide catchment in the sub-region and beyond. It is a significant employment location which is likely to grow in importance with the proposed expansion of the university and of the town centre’s shopping offer. It also fulfils other higher order functions, with a law college and a regional sports centre, and its transport connectivity, especially its rail interchange, enhance its sustainability credentials. In our view therefore, there is particular merit in seeking to target some additional growth towards Guildford (20.56).

There are significant environmental constraints to the expansion to the south, south-east or south-west. Expansion to the north is limited by SPA and other considerations but an area within the MGB to the north east of the town, as identified in Policy LO6 of the Surrey Structure Plan, could provide for sustainable growth. This location was identified after extensive comparative studies and we have found no evidence of a more suitable alternative direction for growth, if urban capacity in Guildford is insufficient to meet the housing requirement. Given this background and the need to facilitate housing delivery through the planning system, we do not agree with the Borough Council or the Assembly who would favour a criteria-based policy in regard to Green Belt review if required (20.57).

Expansion to the north-east of Guildford would be subject to SPA considerations, given its location within the 5km zone, albeit towards its outer edge. However, the strategic scale of development would enable adequate mitigation to be provided and it is also accessible to the attractive countryside of the North Downs on its eastern side. It appears that development in this location could accommodate about 2,000 dwellings as well as a sustainable mix of other uses. For all the foregoing reasons, we consider that selective review of the MGB boundary in accordance with Policy CC10a should focus on the area to the north-east of Guildford. (20.58).

In our view its (Guildford’s ) role should be strengthened by maximising potential for increased densities in the most accessible locations; this could yield greater urban capacity than currently assessed. While we accept that recent delivery rates in the Borough generally have only slightly exceeded the draft Plan provision, the setting of a more challenging target to encourage intensification and recycling of urban land would be appropriate in our view. As set out above, it also offers the potential for a sustainable urban extension to the north east, subject to the alteration of the MGB boundary. Taking all these factors into account we recommend that the apportionment to the London Fringe part of the borough should be increased by 2,000 dwellings for the Plan period (2006-26; i.e.100 dpy ) includes a stipulation that development will be contingent on the provision of timely infrastructure (20.90).

For the reasons given in Chapter 5 we consider that this idea is inappropriate and impractical (20.91).

Although we do not agree that the Implementation Plan should form part of the RSS we welcome the contribution it makes to the long term planning of infrastructure in the London Fringe (20.92).

We recommend that the following projects should be added to the text relating to sub-regional infrastructure in E5, para 2.15:

Improved public transport and interchange at regional hubs – Guildford, Woking and Redhill/Reigate

Other schemes to improve access to or relieve congestion in regional hubs (20.96).

Some participants including Guildford BC are also concerned that no clear structure or leadership (for tariffs on new development to finance infrastructure) has been identified and the necessary level of jointness among agencies has yet to be tested (20.99).

Amend Policy LF1 to protect the broad extent of the MGB in the sub-region but require where necessary selective and also some smaller scale local reviews of its boundaries (Rec 20.1)

Amend Policy LF2 to increase the housing provision for the Plan period for:

The total sub-region from 37,360 to 46,120

Guildford (part) by 2,000 (Rec 20.2).

Amend Policy LF4 to specify that, while the focus on the urban areas will be maintained, an urban extension of Guildford will be required, and on a smaller scale possibly at Woking, and to indicate the locations for selective review of the Green Belt (Rec 20.5).

Include a job growth estimate for monitoring purposes of 39,500 between 2006-16 (Rec 20.9).

Add the critical infrastructure themes listed to the text on sub-regional infrastructure (Rec 20.11).

Chapter27: Implementation

We recommend deleting the references in the draft Plan to what was termed at the examination the ‘conditional approach’ (27.3).

We agree that the Implementation Plan should not formally be part of the RSS. We recommend that a new section on Implementation, Monitoring and Review be added to the Plan (27.4).

We welcome the stated intention of the Regional Assembly and SEEDA to work towards a single Regional Implementation Plan as a means of improving the alignment of public sector investment (22.7).

Four main delivery mechanisms are identified in the Implementation Plan – behavioural change, regulatory intervention, management of existing assets, and investment in additional infrastructure capacity. The importance of behavioural change cannot be emphasised too strongly. We agree and we consider that this message should be central to the section on delivery mechanisms, particularly in relation to transport. However we also agree that in most cases fiscal incentives and regulatory change will need to be, and are being, initiated by central government to bring about the necessary changes in behaviour (27.8).

The Implementation Plan should be kept under review as a non-statutory region-wide document giving a comprehensive picture of strategic infrastructure requirements;

The main infrastructure priorities at regional and sub-regional level should be included in the RSS text (27.13).

We do not consider it right to include any costs in the RSS itself (27.20).

Add a new Section to the RSS on Implementation, Monitoring and Review (Rec 27.1)

Keep the Implementation Plan under review as a non-statutory document, but include the main infrastructure priorities in the Plan’s text. (Rec 27.4)