Memorandum by Surrey County Council (PGP
23)
THE PLANNING GREEN PAPER
INTRODUCTION
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.
THE SURREY
CONTEXT
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.
THE CURRENT
PLANNING SYSTEM
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.
THE GREEN
PAPER'S
PROPOSALS
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.
SURREY COUNTY
COUNCIL'S
PREFERRED APPROACH
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.
CONCLUSIONS
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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