Abolition of Regional Spatial Strategies: a planning vacuum? - Communities and Local Government Committee Contents

Written evidence from Southern Water Services (SWS) (ARSS 108)

Government needs a planning system that encourages, not defers, private sector investment in water and sewerage infrastructure, which typically spans more than one local authority boundary.

Regional spatial strategies have usefully informed Southern Water's investment plans on the likely level of new development in the region and the location of strategic development sites. They have also provided planning policy support for the delivery of major investment.

In contrast, Local Development Frameworks have failed to provide the planning certainty required by the private sector to plan and deliver infrastructure investment.

The proposed "duty to co-operate" is an inadequate substitute for regional spatial strategies. There remains a need for strategic regional plans that have been tested via public examination.

Taking over matters formally covered by regional spatial strategies may be a role that could be undertaken by Local Enterprise Partnerships.

An example is provided of the planning support required for delivery of major infrastructure investment. The Committee is invited to use it to test the effectiveness of future proposals.

Southern Water Services (SWS) provides water services to about two million customers and sewerage services to over four million customers in Kent, Sussex, Hampshire and the Isle of Wight. SWS is a major investor in water and sewerage infrastructure in the south east and welcomes the opportunity to comment on the abolition of regional spatial strategies.

Government needs a planning system that encourages, not defers, private sector investment in water and sewerage infrastructure. Water and sewerage infrastructure has boundaries that do not coincide with those of local authorities. Major infrastructure often serves either a group of local authorities or is located in a strategic location within a region that serves all of them. In some cases infrastructure required to serve communities in one local authority has to be located in another local authority because of environmental or planning constraints. Regional spatial strategies that have been tested via public examination provide the private sector with the planning policy necessary to support delivery of major investment in infrastructure that extends beyond neighbourhood or district boundaries. Abolition of the South East Plan has left a strategic planning gap.

SWS is neutral on the issue of the abolition of regional house building targets for levels of housing development. However, the regional house building targets have been useful in informing SWS' long term investment plans on the likely level of new development in the region and the location of strategic development sites. Although future housing targets are not an issue on which SWS can comment, planning certainty with respect to the location, scope and timing of development is essential for infrastructure investment. Adopted Local Development Frameworks (LDFs) should provide this certainty by informing the water industry what, when and where additional infrastructure is needed. However, the LDF process has failed to meet his need as very few local authorities have progressed their plans to adoption.

The proposed duty to co-operate is considered to be an inadequate substitute for regional spatial strategies. An overarching body is needed to take responsibility for strategic planning at regional level and set out investment priorities and solutions that extend beyond individual local authority boundaries. Regional Planning Guidance and county council Structure Plans provided policy guidance before the regional spatial strategies were developed. Whilst SWS is not advocating a return to either of these models, planning policy at this level is still required. Local Enterprise Partnerships may have a role to play in this process, which SWS would support if the strategic or regional plans were tested via public examination.

Water resources are planned regionally through statutory Water Resources Management Plans (WRMPs). A regional approach is necessary because the south east is designated a water stressed area and water resources are not available locally to supply major centres of population. Balancing water demand with supply relies on the coordinated use of strategic resources across the south east and the transfer of water from areas of surplus to areas of deficit. The South East Plan set out the long term strategy for housing development across the region and included planning policies which supported the development of additional strategic water resources. House building targets, broken down by local authority, usefully informed the WRMP because they had been tested via examination in public. The abolition of the South East Plan and the failure of the majority local authorities in SWS' area to progress LDFs to adoption presents a major gap in planning policy across the region.

The following example is provided to illustrate the planning policy support Southern Water requires to deliver major investment in additional water infrastructure.

Bewl Reservoir, on the county border of East Sussex and Kent, is a major regional water resource that is shared by water companies in the south east. Water from the reservoir is used to supply drinking water throughout Kent and East Sussex. The South East Plan recognised the need for development of new strategic water resources in policy NRM3 and provided support for their delivery. Abolition of the regional spatial strategy leaves the decision on future water resource development to the local authorities. Bewl Reservoir falls within three local authorities, Rother DC, Tunbridge Wells BC and Wealden DC. The scale of increased demand for water locally in these three local authorities will never trigger a requirement for investment to enlarge the reservoir. However, increased demand from development further afield in Thameside, Medway and Thanet will certainly drive the need for additional resources and reservoir enlargement at some point in the future. The reservoir enlargement will require planning permission from the three local planning authorities.

The Communities and Local Government Committee are invited to use the above example to consider whether future planning policy proposals would support the three local authorities facilitating the delivery of a major water resources investment scheme within their areas that is required to meet the needs of development that falls outside their areas.

September 2010

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Prepared 31 March 2011