Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by Surrey County Council (PGP 23)



  1.  Surrey County Council has made detailed comments to the Department of Transport, Local Government and the Regions (DTLR) on the proposals set out in the Planning Green Paper and the daughter documents concerning planning obligations, major infrastructure projects and amendments to the Use Class Order. This memorandum does not repeat these comments, but rather attempts to set out, by reference to the issues of housing allocations and local transport planning, Surrey County Council's concerns with the proposed changes and an alternative approach which would better address the needs of local authorities in Surrey and across the south east region. The memorandum considers the way in which housing allocation and transport planning would be considered under each of the following three scenarios:

    —  The current planning system.

    —  The Green Paper's proposals.

    —  Surrey County Council's alternative approach.


  2.  Surrey adjoins the south west side of London. It covers an area of 167,000 hectares and has a population of about one million. It has the highest population density of any shire county in England. Heathrow and Gatwick Airports abut the county to the north and south. It is crossed by the M25, M3 and M23 motorways. Much of the southern part of the county falls within the Surrey Hills Area of Outstanding Natural Beauty.

  3.  Historically, Surrey has experienced some of the highest rates of population growth of any county, reflecting the outward pressure from London. This has now stabilised, with the advent of the Metropolitan Green Belt. Surrey is no longer a dormitory to London, but makes a major contribution to the regional and national economy and the GDP per head is one of the highest in the country.

  4.  Yet, because of its popularity, the pressure to develop in Surrey is intense. As a result, Surrey has some of the highest house prices in the country. Many families can no longer afford to live here, while companies eager to grow and those providing a public service are experiencing recruitment problems. The relative prosperity and the density of activity in Surrey is reflected in the fact that many roads carry more than twice the national average of vehicles a day.

  5.  Surrey presents a particularly complex mix of planning problems. It is impossible to consider planning at the local level without addressing the regional context and, particularly, the position in adjoining areas in London and also in Hampshire, Berkshire and West Sussex. It is also impossible to consider land use issues without a close relationship to transportation issues, given the levels of congestion. For many years planning policies have sought to balance the control of further urbanisation and also environmental protection, against the need to support a successful economy and meet local needs. Recently, the need to consider the affordability of housing across the entire county has become a significant issue.

  6.  Surrey County Council has taken the lead in addressing these difficult problems through the preparation of the Surrey Structure Plan Deposit Draft, 2001. This draft plan sets out a radical new land-use planning framework for Surrey, seeking to balance the need to protect and enhance the environment with the need to provide more homes for those who need them, and at a price they can afford, and which enables business and commerce to prosper. The draft plan itself has attracted national recognition through the Royal Town Planning Institute's annual Awards for Planning Achievement for its innovative and strategic approach to land use planning. It has also been recognised by ROOM, the National Council for Housing and Planning, as an example of best practice in positive planning.


  7.  The current planning system in Surrey comprises national government guidance, non-statutory regional planning guidance for the South East (RPG9) and the statutory development plan, comprising the Surrey Structure Plan and the eleven borough and district local plans.

Housing Allocation

  8.  Housing requirements for Surrey are established through the preparation of regional planning guidance (RPG). The County Council represents the views of the borough and district councils on officer and member working groups within the South East England Regional Assembly (SEERA) and, previously within the London and South East Regional Planning Conference (SERPLAN). The County Council was specifically invited to represent the interests of Surrey at the South East Regional Public Examination in 1999.

  9.  Current RPG9 requires the local authorities to undertake a number of sub-regional studies, two of which affect the Surrey area—the Crawley/Gatwick Sub-Regional Study, which covers an area in Surrey and West Sussex, and the Blackwater Valley Sub-Regional Study, which covers an area in Surrey, Hampshire and Berkshire. Both of these studies are considering future requirements for new housing in relation to economic pressures and the results will inform the next review of RPG. Within Surrey, the County Council is taking the lead in progressing the studies and is working closely and effectively with neighbouring counties on their development.

  10.  The County Council also has the responsibility, through the Structure Plan, to distribute the regional housing allocation between the borough and district council areas. The County Council has taken the lead in preparing a joint county/district strategic assessment of urban capacity across Surrey to inform this distribution and is working with districts to prepare a common methodology for more local capacity studies. The County Council is also able to take on board detailed local knowledge of issues that would affect the distribution of housing, such as transport and infrastructure provision, and provide a direct link into the County Highway Authority, Education, Social Services and other key county-wide services.

  11.  RPG9 requires the south east region to provide an additional 39,000 dwellings per year in the period 2001-06. This figure will be reviewed before 2006 to provide a requirement for the period up to 2016 and beyond. Where development plans extend beyond 2006, local authorities are required to continue to provide housing at the pre-2006 annual rate until such time as a review has been adopted. Surrey's share of this housing requirement is 2,360 dwellings per annum, equivalent to 35,400 dwellings over the period 2001-16. This requirement is approximately 13,000 dwellings above the estimated urban capacity of the county, raising difficult planning issues which will be addressed through the Surrey Structure Plan.

  12.  The distribution of housing is subject to county-wide public consultation and scrutiny through the Structure Plan Examination in Public before being confirmed in the Structure Plan. The Structure Plan then provides strategic policy guidance on housing requirements and locations for the borough and district councils. Individual site allocations for housing are made through the local plan process and again subject to statutory public consultation and local plan inquiry before confirmation.

  13.  Through this process, the County Council is able to take strategic decisions about the location of major new (often greenfield) developments, which affect several districts and may have sub-regional implications beyond the county boundary.

The Local Transport Plan

  14.  The County Council is the Highway Authority for Surrey and has responsibility for the preparation and implementation of the Local Transport Plan (LTP). The LTP is prepared alongside the Surrey Structure Plan (although the timescales for preparation and implementation are different). Officers preparing the LTP attend and directly comment on land use proposals being developed through the Structure Plan and vice versa. Through this process, any proposals for major development (housing, employment or other) set out in the Structure Plan will directly influence the future investment priorities set out for the county in the LTP.


  15.  Under the Green Paper, the current planning system will be replaced with revised national planning guidance, statutory Regional Spatial Strategies, prepared by Regional Assemblies, and statutory Local Development Frameworks, prepared by borough and district councils. The Regional Assemblies may require the preparation of sub-regional strategies to guide development, for example, across local authority boundaries, or to provide guidance on particular issues, such as housing allocations. The borough and district councils may also prepare detailed action plans for particular areas. The County Council would retain its role in preparing statutory minerals and waste plans, but would have no statutory role in other plan preparation. The Structure Plan would be abolished.

Housing Allocation

  16.  Under the revised system, regional and possibly county-level housing allocations will be determined through the Regional Spatial Strategy. The County Council accepts the need to strengthen strategic planning at a regional level, but it is unclear how the local authorities in the region will input into this process and, particularly, what the mechanism would be for co-ordinating borough and district input into this process. In the absence of such an input, SEERA will potentially have to consult directly and co-ordinate the input of 11 separate borough and district councils in Surrey, rather than one county council, and over 70 such district, borough and unitary authorities across the region.

  17.  The Green Paper hints that housing allocations may be made for sub-regions rather than individual districts. Housing and other planning issues in Surrey cannot be separated from adjoining areas, and a sub-regional approach could have advantages, but raises difficulties of co-ordination across local authority boundaries, with many small local authorities involved. Experience gained in the preparation of the current RPG suggests that all borough and district councils would wish to be involved in the preparation of such sub-regional studies.

  18.  The RSS would be subject to public examination, at which the housing allocation would need to be considered. Housing allocations are so controversial in Surrey and the rest of the south east that individual borough, district and unitary councils would demand to be represented at any such examination to present their own views. However, extending the examination to allow for representations from all borough, district and unitary authorities in the region, rather than working through the county councils, would make such an examination unworkable. Excluding these authorities will lead to complaints about the accountability of the system.

  19.  There is a further complication that by excluding the County Council from any direct involvement in the determination of housing requirements, the link between housing and other service priorities, particularly education and transport could be lost. This would add to the complexity of the process, requiring formal consultation between SEERA, the relevant services of the County Council and individual boroughs and districts.

  20.  Once housing is allocated via the RSS, it would be up to LDFs to identify potential sites and establish development criteria to meet the requirement. Within Surrey there would be eleven separate LDF inquiries and eleven separate consultations with County Council service departments and transportation planners.

Local Transport Plan

  21.  The LTP would have to be prepared in the light of the RSS and any sub-regional guidance prepared by the regional assembly. It would also have to be prepared in the light of the eleven LDFs for Surrey, each of which would identify its own transportation priorities. It is likely to be extremely difficult, if not impossible, for the LTP to adequately reflect the priorities of 11 authorities, plus the existing priorities of the County Council. It is difficult enough under the existing system to ensure local plans adequately reflect transport priorities and the allocation of resources to certain parts of the county, without the backing of statutory planning guidance is likely to be controversial.


  22.  In its submission to DTLR, Surrey County Council has set out an alternative approach to the review of the planning system. In essence, the County Council is advocating a system under which the Green Paper's proposals for the review of national and regional planning guidance are accepted. At a local level, a single LDF, or several LDFs, would be prepared covering the county, rather than 11 individual LDFs, one for each of the boroughs and districts. LDFs would be prepared jointly by the County Council and the boroughs and districts, or possibly with the County Council taking the lead. Boroughs and districts would then prepare detailed action plans as appropriate. Under this system, the Structure Plan would cease, but the County Council would retain a statutory role in the preparation of county-wide planning guidance. This is similar to the alternative model put forward by the County Council Network of the Local Government Association.

Housing Allocations

  23.  Housing requirements for the county of Surrey and possibly sub-regional areas, would be set through the RSS. The County Council would have a statutory role in co-ordinating input into this process from within Surrey and would represent the Surrey local authorities at any regional examination of housing requirements. This would lead to a much more workable system, remove the requirement on the regional assembly to individually consult and involve each of the borough and district authorities.

  24.  The County Council and the boroughs/districts would then prepare a county-wide LDF which would distribute the regional housing allocation to individual authorities, or groups of authorities within Surrey. Public discussion of these proposals would be dealt with through a single plan process (or a small number of plans), with a single enquiry into the proposals, rather than 11 different enquiries proceeding at different times. A single plan process would make it much easier to address cross-authority issues within the county, particularly the allocation of major new housing developments which may cross authority boundaries and which will certainly have impacts on more than one local authority.

  25.  The existence of a single process would enable the land use system in the county to more effectively co-ordinate with transportation planning and other service planning within the county. This would also remove the need for individual services to be represented at 11 different enquires. Such an approach could be carried out in the context of non-statutory sub-regional plans, or could be adopted to provide for development frameworks across county boundaries where co-ordination was particularly important.

Local Transport Plan

  26.  The proposed system would enable more direct working relationships and co-ordination of priorities between land use planning in Surrey and the preparation of the LTP. The quicker production and turn around of LDFs would more closely replicate that of the LTP, ensuring more effective integration. There would be no need to co-ordinate the LTP with 11 different LDFs, removing the need for additional resources, time and bureaucracy from the system.


  27.  Surrey is a county under immense pressure for development and faces very difficult issues around the need to protect and enhance the environment whilst making adequate provision for housing and economic development. To address these issues, an efficient land use planning system is required, one which can take the best elements of the current planning system and reform those elements that are currently not delivering.

  28.  Undoubtedly, a stronger national and regional framework would assist the delivery of planning within Surrey. Housing and transportation, however, are just two examples of issues where the bridge between the local level and the region is particularly important and there is a need to co-ordinate activities over a wider area than an individual district. The County Council's alternative scenario would take the benefits of reform and provide added value by building on the existing responsibilities, expertise and need for co-ordination across boundaries in Surrey.

March 2002

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