BSCF's Response to EERA's "Online" Consultation on the East of England Plan

14 November 2009

Your on-line consultation response form is so inaccessible that I have given up the unequal struggle to persuade your host to reveal it and I am emailing you this response instead.

Q1 Are the growth scenarios right?

A1 No. The scenarios chosen are undesirable and unrealistic. East of England is one of the most prosperous regions in the country and in Europe. Most of the population growth projections on which the scenarios are based result from substantial inward migration. This will lead to a growing disparity in economic prosperity between this region and the midlands and the north from where many of the migrants will come, and whose own regional objectives no doubt include catching up with us. You should at the very least have included a scenario which restricted housing growth to a number sufficient to meet the rising demands of the indigenous population, with supporting policies to assist a faster rate of development in other regions of the country.

It is also likely that much of the population growth projected for Herts and Essex is to provide more dormitory accommodation for London commuters – again not something that the plan should be encouraging.

Finally, the whole tenor of the plan is to confuse economic growth and population expansion with the well being of communities. Some communities in our neighbourhood, notably Harlow, need regeneration and new job opportunities. For many others such as my own town of Bishop's Stortford current development pressures are leading to the destruction of the community which people find so attractive at present.

Q2. Comments on the 4 Scenarios

A2. Neither the plan nor this review acknowledge the contrasts in the region which combines some sparsely populated counties such as Norfolk with the most densely populated county outside London - Herts. Large areas of Herts have already been obliterated by development – like Middlesex and Surrey in previous centuries - and the existing plan and these scenarios do not address and do nothing to curb the expanding urban sprawl of London.

The housing numbers proposed in all the scenarios substantially exceed current rates of delivery or indeed the numbers which are likely to be capable of being built through current delivery agencies. Even if these numbers were deliverable they would form a fairly marginal increment to the total housing stock and would be unlikely to have a material effect on house prices.

All the scenarios assume significant continuing rates of house building in East Herts without any assessment of the capability of the district to absorb such increases sustainably.

Q3. Preferred Scenario

A3. None of them – for the reasons set out in answers to previous questions. I note that East Herts has the lowest figure for housing in Scenario 4 but the overall housing total for the region is the most unrealistic of all.

Q4. Have all the regional impacts been identified?

A4. No. The existing plan conspicuously fails to provide any means of accelerating infrastructure provision to overcome the deficit, particularly in transport, water and sewerage, or to keep pace with the projected growth in housing and jobs. This review ignores the probability that the deficit will increase unless housing provision is constrained below the existing plan targets to a level which existing facilities can support.

Q5. Vision and Objectives

A5. The following objectives need to be reviewed

• * ‘A step change in the delivery of housing.’ It hasn’t happened, shows no signs of happening and should be encouraged not to happen in order that we do not become victims of another unsustainable house price led boom.
• * ‘Ensuring adequate and sustainable transport infrastructure’ The plan does not do this. On the contrary, in the case of Harlow North for example, it simply dumps housing on an unsustainable location and tells planners to go away and find a solution, even though the government’s own Inspectors struck it out of the plan because there was no solution to be found. More generally, the plan is housing led with the problems of demands on infrastructure being left for later decision – wholly incompatibly with a plan led approach to development.
• * ‘Reducing the demand for and use of water and other natural resources and reducing waste.’ The plan patently makes not the slightest attempt to achieve this objective – Harlow North again being a case in point.

Q6. Updating of Policies

A6. E7. The Air Transport White Paper 2003 is increasingly irrelevant as a guide to the future of airports in the region – particularly Stansted where traffic has reduced substantially and its ownership and hence future development are in doubt. As it is the major employer in the area, this calls into question both the sub-regional employment projections and housing requirements.

T1. ‘Reducing the rate of road traffic growth’ is a wholly inadequate transport objective and was indeed watered down from what previously appeared in the plan by the government in its review. A much more robust statement is needed, reflecting the impact of road transport on climate change and giving a clear steer to the design, growth and location of settlements.

H1 and HA1. For the reasons set out above the housing totals in the plan, in general and with particular reference to East Herts need to be adjusted downwards to reflect realistic levels of house building, realistic expectations about infrastructure provision and an understanding of the adverse impact of further increments of housing on the quality and sustainability of existing settlements. Harlow North should be removed from the plan. The infrastructure cannot support it and its presence will simply undermine the much needed efforts to regenerate Harlow New Town.

Yours faithfully