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Comments on


Sustainability Appraisal report/ incorporating the report of the Strategic Environmental Assessment, known also as the Environmental Report.

(this document report may differ slightly from that submitted, due to the requirements of the format of the on-line response method which also required summaries of points.)

CPRE has concerns over a number of issues in relationship to this report first of all it is acknowledged that the process is for preparation of the SEA falls a little short of that required by the directive. However, given the special circumstances of the delay to the RSS and the late stage of this addition of an SEA to the process it is perhaps to be expected. However we feel we must point out where this process falls short for future reference and because we have major concerns with the East of England Plan.




Failures of the process:


As the report itself point out the “process was in the wrong order” (p12)  There was  a lack of time to do the work and so the consultants were unable to do a comprehensive trawl of all the background papers.  The SEA wasn’t started until the process of developing RSS14 was well advanced. The scoping stage therefore was very late.

Also it is stated that the “growth areas identified in government documents, and for which predictions and analyses have been carried out, do not clearly correlate with those that will receive the most housing” (page 12 S.A report)


Of particular concern is the fact that as the Report states, with regard to transport only the strategic policy proposals are examined not the individual schemes.


We believe this is a major failing with the SA/SEA as the RTS is very good on demand management, reducing the need to travel and so on in the  transport policy but when examined in the light of the transport schemes proposed it is quite clearly  roads driven and public transport and alternative modes are a poor relation.


We are also concerned that in fact the SA has been taken as being supportive of the RSS in terms of its potential to move forward on sustainability when in fact it clearly states on page 13 (final draft October 27 2004) that the “appraisal cannot be precise, and it is positively misleading and a waste of every ones time and money to put more detailed comments into matrices than the uncertainties make meaningful


We are also concerned that (3.2) Whilst the section on ‘sustainability characteristics of areas likely to be significantly affected’ is under the SEA directive to focus on environmental considerations it also focuses on social and economic issues which we believe may skew the results in a way detrimental to the SEA for example several of the tables refer to the “need to balance economic need to various objectives. (e.g. 3.1d, 3.1e3.1f).


We do not believe that seeking a balance (between sustainability objective) is what the SEA is about, but rather pointing out the environmentally unsustainable aspects of policies.  We believe this perpetuates the misunderstanding about the term sustainability which is not about balance between the different parts where one part (economic/social/environmental or resource use) loses out to another overriding aim, but rather it is about achieving win-win situations. We must not forget that the environment is in a deficit situation hence global warming.


The SEA is supposed to be a parallel process from the start and involve options, in trying to retrofit the SEA the report looked at the four options put forward in the Options Consultation document and endeavoured to examine them in retrospect. This is a flawed part of the process and really added nothing to the SEA and whilst the “sustainability implications” were examined at the time of the Options consultation none of the Options considered were in themselves based on environmental considerations. Or considered the full environmental impact of each option, therefore spatial choices based on a full understanding of the environmental implications of the spatial options could not be made. In fact the Report does point out that the fourth Option of a new settlement was dismissed where in fact it may have been a sustainable option.


The report also goes on to say (p64) That though the sustainability implications were discussed at the Options stage  “this strategic level of discussion was then set aside, and through most of the RSS development process the preferred spatial option evolved implicitly as a result of other decisions and negotiations rather than being consciously decided”! (Para 4.3 S.A Final draft Oct 2004)


It goes without saying therefore that the underlying assumptions of growth, jobs etc were not therefore considered.


Perhaps the greatest concern we have is on the way that SA recommendations have or haven’t been taken into account in the final Plan. It is quite obvious that the Plan is unsustainable from reading the report even when it is trying to be positive it doesn’t quite make it!  


“As the appraisal in Chapter 5 show, the topic chapters of RSS are largely concerned with achieving economic and social objectives while mitigating the negative environmental impacts of the growth. The appraisals include a large number of detailed comments and suggestions, but overall the policies are generally highly beneficial for the environment. Provided they are fully and consistently applied, they will significantly reduce the negative environmental impacts of growth”. It is quite obvious that this implies that there will be negative impacts that will need mitigation.


We want to see environmental damage avoided or limited. This would be far more in the true spirit of sustainability.


How this statement in fact can be reconciled with the statements in 4.2 Comparison of options Para 3 “As a broad generalisation, therefore the ‘banked’ RSS level of development is significantly worse for the environment than the ‘business as usual’ options (RPG6 & 9 continuing trends)  and the ‘Rooker’ level of development even worse”. (p63) Apart from district housing numbers there is little difference between the ‘banked’ and the current draft.



Key issues and how they are taken into the Plan.


“The baseline assessment shows that a number of aspects of the environment are already seriously stressed by human impacts on water resources, biodiversity, , air quality, recreational access and congestion. The larger the volume of development the harder it will be to avoid increased flood risk, erosion of the quality and distinctiveness of settlements and the built environment, and landscape” (page17 Non-Technical  Summary SA report)


We are particularly concerned that recommendations from the SA/SEA have not been given enough attention in the final Plan.


How has the economic target been amended given that the report points out that GVA is not a good measure of quality of life and also now that the UK new Sustainable Development Strategy appears to move away from growth towards employment what was done to incorporate the changing emphasis.


We do not believe that demand management has been given enough emphasis bearing in mind  the very large number of road schemes in the RTS and there isn’t any policy of how demand management e.g road charging might need to be addressed over the next 10 years.


Also with regard to transport the continued acceptance of an “infrastructure deficit” particularly in terms of transport despite the SA pointing out that “we believe this concept is misleading in the context of transport because it implies there is some (higher) level of transport infrastructure which is in some sense objectively ‘correct’ and to which the region has some entitlement as of right” (Under Ch 8 Weaknesses p82). This needs to be addressed.


We do not believe the recommendation in the paragraph below has in fact been dealt with adequately.


Policies should have tougher conditions to ensure that development does not erode public goods. For example green field releases should be conditional on all important benefits (e.g. biodiversity, landscape, recreation, groundwater recharge, flood storage, cultural etc) being identified and substituted. This should include mechanisms for negotiating and securing savings of site as part of the development ‘package’ Where this is not possible (e.g. because an important benefit is inseparable from its location) development should not be allowed” (p89 Strengthening constraints and conditions, SA October final draft)


Nor do we believe that the imperatives within this next statement have been adopted.

The scale and pace of growth envisaged is likely to be highly environmentally damaging unless planning controls are combined with other measures to ensure that new development achieves a step change improvement in resource intensity, including approaching zero net climate change impacts, piped water demand, road traffic generation and loss of wildlife habitat (page 29 Non Technical Summary).


These comments reflect our concern that while most policies in the Plan are admirable in concept, the pressures are such that the outcome will be much less satisfactory in practice.


The water issue we believe is crucial and another issue which has not been dealt with adequately despite the SEA raising this as a serious issue. As the latest climate change predictions are even more alarming than what was known before. It underlines the recklessness of building hundreds of thousands of new homes in a region already facing a water supply gap and vulnerable to flooding.  Note also warnings from the insurance industry that they won't underwrite flood - vulnerable houses.


“Most of the region’ groundwater resources are broadly in balance, but no further resources are available and in some areas surface and groundwater abstraction already exceeds sustainable limits” Table 3.3. (Our emphasis in bold)


Summer surface water is fully committed to meeting existing demand with no significant further resources available” (Table 3.3 p34 and See figure 3a and 3b)


At the broad regional level, the baseline study shows clearly that availability of fresh water resources are already a constraint on development. Climate Change is likely to result in demand increasing, but supply decreasing. Without extra housing growth the Region is therefore likely to face a water supply deficit within a few decade” (p 43 SA Final Draft October 2004)


The Plan therefore should ensure that the minimum prudent sustainability standard for major developments should be carbon-neutral and water-neutral, i.e no net increase in greenhouse emissions or piped water demand.  We see no sign of any willingness to
recognise these standards or give the RSS or EERA more generally the teeth
to enforce them.

As the report acknowledged “growth areas identified in government documents, and for which predictions and analyses have been carried out, do not clearly correlate with those that will receive the most housing” (page 12 S.A report). This is perhaps why Tables 3.2h and 3.2n give a reasonable summary of the environmental issues for Stansted/M11/Harlow and Stevenage respectively, although a more location-specific analysis would have been useful.


But, for example, there is no mention of North Weald (the proposed strategic development site south of Harlow in Epping Forest District) in Table 3.2h or in the analysis of draft RSS Chapter 5.  For Stevenage, potential development on and over the ridgeline to the west of the A1(M) is not recognised under ‘Landscape’ in Table 3.2n.  On the other hand, some strong points are made about unsustainable water abstraction, potential development in floodplains, threats of coalescence of settlements and the need to protect sensitive river valleys.  The implications for traffic growth are mentioned, but the Report could have made much more of this (as the MK&SM SA Report did).


The Report does not explain how the Assessment is satisfied (if, indeed, it is) that peripheral development at Harlow and Stevenage will actually assist in regenerating those towns, and surprisingly does not call for actual mechanisms to link greenfield development to progress on regeneration. The SA report actually states that that “the assumption that major expansion of Harlow must depend on provision of a new bypass running east-west, whether north or south of the town, is on the face of it incompatible with the sustainability approach of the RTS chapter” p65, S.A Final Draft October 2004) yet the Plan has this “bypass” need still in.


The SEA report also points out the ambiguity of purpose – “enable housing to catch up with jobs to address problems of shortage, affordability and commuting or to develop balanced communities with jobs and housing broadly in balance”. (p59)


The report goes on to point out that  the same housing cannot do both and if RSS14 achieves balanced communities it will not redress existing  housing shortages and therefore government could seek yet more growth  “a policy vicious circle”. (p59)


How will the Plan address this clear dichotomy of aim which must be fundamental to any spatial plan to know where you are trying to get to?


“The objective of the SEA directive is to provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans with a view to promoting sustainable development” (p3 Report of the sustainability appraisal)


This is all very commendable but cannot work if the results of such an appraisal are not taken note of and acted upon, we hope to see further work on these issues.