Examination in Public of the East of England Plan.


Below are the brief summaries prepared by observers during the Examination in Public of the East of England Plan. They are not verbatim reports, for these you need to contact the Panel Secretariat (see Government Office website on links page).


Week One: 1 - 4 November 2005 Week 10 (14 - 17 February)
Week Two: 8 - 11 November 2005 Week 11 21-23 February
Week Three  15 - 16 November Week 12  28 February - 1 March
Week Four Final notes
Week Five 6 - 9 December
Week Six By courtesy of Friends of the Earth, a full transcript of the hearing on 16th February
January 2006 Population Projections
Week Seven  
Week Eight  
Week Nine 31 Jan - 1 Feb: Cambridge sub-region  


The East of England Regional Assembly emphasised their position: until Government gives a clear commitment to fund and deliver infrastructure, EERA's endorsement of the Draft Plan remains in suspension.  However, its support for the other parts of the plan is not withdrawn and it represents the agreed spatial strategy for the Region.

In its opening remarks, the Government Office for the Eastern Region said no Government could make binding long term commitments covering the whole period of the plan (potentially up to seven spending reviews).  Long term funding uncertainties could not negate the need for effective spatial planning. Nor could the Panel make assumptions about long term funding or future policy measures such as Area Wide Road User Charging.


EERA stated the housing numbers in the plan (478,000) represented a 15% increase over previous plans. While they understand there will be very significant localised impacts, EERA believe on a regional scale these numbers are necessary for continued prosperity, given the historic under-delivery of new housing.

The Government Office commented that pressure on housing supply had worsened.  The 2002 ODPM household projections indicated a growth of 491,000 households between 2001-2021, equivalent to a need for around 507,000 dwellings.  Other projections suggest a need for 516,000 homes.  Not to be outdone, HBF (now known as the House Builders' Federation) stated they would be seeking between 500,000 and 600,000 new houses during the plan period.
Just as worryingly the East of England Business Group commented on the need for additional locations for growth because of the profile of the housing market and the consequent need to deliver houses more quickly.


All the main speakers commented on the importance of the environment and the effect of climate change.  However Friends of the Earth commented the plan was extremely weak on climate change. In particular they cited the effect of a possible second runway at Stansted: air transport is the largest single cause of greenhouse gasses.

Water availability was also discussed.  The Environment Agency said the region has two-thirds the average rainfall and a fifth lies below sea level. Climate change predictions suggest drier summers and wetter and stormier winters.  At least two infrastructure schemes would be critical (Rutland Water and Abberton
reservoir).  As importantly there would need to be a 25% reduction in water use in new housing and an 8% reduction in existing homes.

There was some discussion on how to measure environmental capacity.  The statutory environment and conservation agencies offered to present a paper to the panel on the subject next week.

EERA is introducing a new monitoring policy primarily to deal with the relationship between housing, employment and infrastructure but has offered to include environmental criteria.  They say this is to ensure environmental thresholds are not exceeded.


Week Two


The Association of Chief Police Officers Eastern Region Group told the EiP that crime and disorder have a tangible impact on economic growth, social exclusion and quality of life. They drew attention to the need to 'design out crime' from new settlements, by using well-established techniques. Given the scale of the region's proposed population increase, they predicted that an additional 18.2% crimes per annum would be committed across the region by the year 2021 solely as a result of extra development. This would represent an increase in crime of 32.5% compared with current levels.  

Additional policing would be needed. The capital and start up costs could be around £104 million, with additional annual salary costs of £110 million by 2021. It was likely that around 2150 extra officers and 1325 support staff would be needed. These estimates assumed that the secured by design principles were followed in all new developments. If they were not, ACPO feared yet more officers would be needed. 



EERA defended the jobs prediction in the Plan: an increase of 421,500 to 2021. There was some discussion about whether this included the effect of the possible 2nd runway at Stansted. Some contributors thought that it would, others believe the 2nd runway would make no difference.  

Cambridgeshire County Council pointed out the all the jobs forecasts were based upon the Annual Business Inquiry, which was unreliable. A new tool called the Annual Population Survey (accessed at www.nomisweb.co.uk.) was far more accurate but no historical data was available. EERA said the jobs targets in the plan would have to be recalibrated to APS.  

Whether the jobs figures in the Plan could be used as targets, reference points or simply for monitoring purposes at Local Authority level remains an open question. EERA said it anticipated doing more work with sub-regional authorities about the delivery of the job figures.  



The Home Builders Federation initially stated there were no environmental limits but under questioning admitted there might be one or two.


However a number of contributors suggested the plan should be more aspirational and recognise the need to live within environmental limits. Calls were made to make Climate Change the overarching strategic consideration. There was much debate on the effect of climate change targets, particularly the national 60% CO2 reduction. It was pointed out that all the emissions by aviation could only be balanced should by zero emissions from all other sources. 


In their opening address in week one, the Government Office commented that while they had sympathy with the desire to reduce commuting from the region they had not seen any evidence that this could be achieved.


The Panel returned to the commuter question in a discussion on the definition of sustainable communities outlined in the Government publication Homes for All. Chelmsford Council noted that some commentators suggested that communities with high levels of commuting were "sterile areas".

Whether areas designed to provide homes for commuters is in or outside the Government's definition of a sustainable community remains unclear.


Week 3

21 November 2005

The Examination in Public of the Draft East of England Plan opened in Ely on 1st November. Alan Richardson chairs the Panel.  The East of England Regional Assembly is issuing a daily briefing which you might find helpful. You can find these on the EERA website (www.eera.gov.uk)


The Panel has asked the Government Office and EERA to table a joint paper on the trend-based household projection for the plan period (until 2021). There remains some disagreement between the two as to what the figure should be. EERA’s question on what the Government Office would recommend on the level of London Workers (commuters) the Eastern Region should accommodate remains unanswered. The East of England Business Group believes you can’t wish away the region’s role in supporting London's Economy.


Roget Levett, whose consultancy produced the Sustainability and Strategic Environmental Assessment (SEA), appeared before the Panel at the invitation of Friends of the Earth. He commented that although the plan had good policies that moved it towards sustainability, the authors should not fool themselves as the plan was not sustainable. In particular he cited the effects of greenhouse gas emissions and climate change as being inadequately addressed. He added the amount of land vulnerable to flood risk was greater than he thought when he prepared the SEA.



During a debate on the use of brown field land, the Government Office pointed out that had the region increased its density by building at an average of 40 dwellings per hectare instead of 22, there would be an extra 16,000 dwellings by now.


There was general support for devolving as many locational decisions to Local Planning Authorities where any proposal crossed authority boundaries. This would be more democratic and provide more opportunities for public participation. The Government Office proposed more detail in the plan to provide greater certainty and to accelerate delivery. They feared protracted wrangles at a local level. One of the contributors pointed out that under the new planning system there was an incentive for Local Authorities to seek agreement between themselves now, as when the Inspector produces his report, his recommendations will be binding on them



A number of developers promoted small new settlements (population 3,000 to 5,000 each) which they claimed could be delivered early in the plan. Most Local Authorities thought small settlements were unlikely to be sustainable as they could not support an adequate level of local services and could undermine existing plans. A sustainable level would require a population of about 25,000. There was some discussion as to whether they should be located close to an existing settlement which it was planned to support, or sufficiently distant to deter commuting.

The Government Office stated the bigger the gap between the housing requirement and the plan, the greater the case for a new settlement. It suggested a number of alternative locations should be explored and if subsequently found not required or to be unsustainable, they could be abandoned.  EERA robustly defended its view that a new settlement was not needed in the current plan and this should be left to an early review.


There was much discussion on the question of compensatory Green Belt. The Government Office stated that the criteria set out in government planning policy guidance on Green Belts (PPG 2) should be soundly applied. CPRE commented there was little evidence of leapfrogging by commuters into towns in the Green Belt. Also the Metropolitan Green Belt should be examined in its totality and the effect of any release assessed not just regionally but also on London.

A number of developers pressed for a review of the Green Belt to allow for development to 2031. Several others, including CPRE, stressed this was not required and should be kept under review through the government’s new “Plan, Monitor and Manage” approach.


Week 4



The present system of funding infrastructure such as health services and the police has an inbuilt delay. Coupled with the failure to plan for growth in services, this leads to a shortfall in funding. South Essex Health Authority warned that the available capacity of the health service in its area was not clear: most were under strain and would not be able to cope with additional growth. 


Crime and population

The Association of Chief Constables told the EiP there was a clear link between growth in population and growth in crime. A 25% increase in population would lead to an 18% increase in crime. They cautioned that short-term cost compromise would lead to a long-term detrimental effect.


You can have too little sewage... and it'll cost you!

The water and sewage requirements for the new housing were discussed. It was explained that a water treatment plant capable of dealing with 2,000 houses does not work efficiently for 200 houses. There were important questions about when such plants should be built and how to phase them. The water industry said it was concerned that rising bills would be inevitable. Urban extensions were perceived by participants as being more manageable than new settlements for these purposes. 


A tax on your roof?


There was some support from developers and local authorities for a tariff or roof tax, despite concerns that it would not raise enough money. It would not deliver infrastructure in rural areas where the opportunities for developer contributions were limited. A number of houses had already been built or committed without any contribution to infrastructure costs.


No money, no growth

The East of England Regional Assembly had proposed a new policy that linked the provision of infrastructure to housing development. It said it would empower local authorities to resist inappropriate development.There was much support for this approach, although there were concerns that its intent was to stop development


Public transport - all by road?

Information from the Department for Transport and the rail industry made it clear there was little funding from new rail schemes. Public transport, therefore, seemed to be relying on buses. However, no bus operators were represented at the EiP or in the consultation. It seems that legislation makes co-operation amongst bus operators impossible. Quality buses may be the preferred form of public transport in the more heavily urbanised areas.   However, this was not always a satisfactory solution to transport for widely dispersed rural settlements.


Airport or car park?

The debate will consider airports next week. Stop Stansted Expansion told the EiP that Stansted airport generates the same level of traffic as Heathrow, despite being considerably smaller. Apparently one-third of the passengers travelling to Heathrow never leave the airport, but catch a connecting flight. Stansted has four times the number of parking spaces than the largest airport in the world.


Week Five 6 - 9 December


This week covered a wide range of subjects, starting with transport strategy (carried over from the previous week), then the environment (conservation, management and enhancement of), green infrastructure and energy and finishing with detailed discussion on the first of the sub-regions and sub-areas.

 Regional interchange centres: how do they work?  

The Newmarket to Felixstowe Corridor Study was submitted to the EiP on 6 December.   It has significant implications for the East of England Plan, the subject of the EiP. It proposes a regional interchange centre at Brentwood, whose implications were not clear.   Ipswich Borough Council asked key questions of EERA (the Regional Assembly): what was the function of an interchange centre and how was it intended to work?

There was agreement over other issues, such as the desirability of taking freight traffic off the roads and putting it on to rail. Network Rail said that it is looking at the future for freight, particularly between Felixstowe and Nuneaton, where larger containers might be appropriate. There was general agreement that improving the Felixstowe-Peterborough-Nuneaton rail link was a major priority.

Airports: who sets policy?

There was a disagreement between the Government Office (supported, not surprisingly, by the owners of Stansted airport) and the EERA and local authorities over whether the regional plan should provide for one runway or two at Stansted. EERA and the local authorities want to provide for maximum use of one runway. The Government Office argues that the Government’s White Paper on aviation provided for a second runway, and so the plan must provide for it too. 


Airports: how much CO2 do you want?

Stop Stansted Expansion pointed out that if a second runway were built at Stansted, and the first runway fully used with 85 million passengers a year, then the additional carbon dioxide emissions from Stansted would be equivalent to all the carbon dioxide emissions from present and proposed development in the region. 


Environmental protection

EEDA (the Regional Development Authority) conceded that environmental protection needed more weight and emphasis in the regional plan, and that it should also appear in the Vision Statement.

Green infrastructure: what is it?

There was some discussion about defining green infrastructure and environmental infrastructure, which were seen as being different. There was general agreement that policy in this regard should not be seen as purely urban. 


Energy policy: back to CO2 again

The discussion centred around reducing energy demand, and increasing energy efficiency.   The key point was that whatever targets were used, they did not deflect from the overall objective of reducing carbon dioxide emissions. 


 Why have sub-regions?

The panel had indicated that in their view sub-regions and sub-areas should only exist where there was a “strategic policy deficit”. This referred to those parts of the region where the regional policies did not provide enough guidance to district councils in drawing up their detailed local policies. The Government Office agreed that planning policy decisions should be taken at the lowest (i.e. most local) level possible. In the general discussion, there was a common view that the boundaries were wrong, albeit from different viewpoints.

Norfolk matters

There were detailed discussions about the Great Yarmouth-Lowestoft sub-region, and the Broads sub-area. Housing targets were above job creation and would therefore bring more people into the area. The proportion of development on previously developed land was disappointingly low at 30% (the national target is currently 60%).


Week Six

Peterborough: can we grow please?  

The city council would like the housing targets for Peterborough in the regional plan to be a minimum rather than a limit (or, to use housing lingo, a floor rather than a ceiling) - and the Greater Peterborough Partnership agreed. Neighbouring local authorities stated they were worried by the absence of a limit, and the adverse impact high growth in Peterborough might have on their own towns (worried it might 'suck the life out of them').

Affordable housing: what does Breckland want?

Breckland is the most rural of the Norfolk districts. Not long before the draft regional plan emerged, the district persuaded the regional assembly to increase housing provision from 11,200 to 15,200. The leader of the council publicly stated that reason for seeking the increase was as a route to an increase in affordable housing provision. At the enquiry, Breckland was asked to comment on the view that this approach was driving up the numbers of market houses and also skewing the numbers and distribution of affordable housing in rural areas. 

Hobson's choice

John Prescott's office wrote to local authorities last week and sent a copy to the panel. The letter says 'The case for increased rates of housing growth in the region has already been presented and it should be possible for the Panel to take account of the Government's response to the Barker review in that context... The conclusions of the Panel can reflect evolving policy and set in place arrangements capable of taking on board new requirements over the life of the plan eg by starting to identify how additional growth proposals might be developed beyond the scope of the current strategy.'
In telling people to take account of new draft policies (so new that they are out for public consultation until the end of February 2006) the Office of the Deputy Primer Minister is within its rights. However, it's important to stress that draft policies are just that, and have no statutory force. If the public are to have confidence in the regional plan it's vital that the draft they were consulted on is fully debated, not changed mid-stream. Neither the panel nor participants should be cowed by Government pressure.

EiP contributors may submit further comments on the Government's letter to the Secretariat, to arrive by 9 January.

Affordable housing: agreement and disagreement        
The EiP was reminded of the need to take account of the draft Government planning policy on housing (PPS3), mentioned in our last info bureau email. The 2003-based household projections from the Office of the Deputy Prime Minister will not be available until mid-February - rather too late to be of use to the EiP. The Government Office for the East of England restated its view that the key to affordability was increasing the supply of market housing.

There was significant concern expressed that the Government's response to the Barker report over-emphasised supply-side issues, and that demand was a significant driver of house prices - and was being largely ignored. There was additional concern that an unfeasible increase in housing supply would be needed to trigger a significant improvement in affordability, and that even delivering the existing planned housing levels would be challenging enough.

Developers said that they would be able and willing to deliver increased numbers of houses, although others questioned this.

It was suggested that a sufficient supply of affordable housing would tend to lower the price of all housing, something the house building industry was not keen on.


January 2006

The enquiry has reopened in its new venue.


Keep the sequential approach


The draft PPS3 departs from the sequential approach of developing land (that is, identifying and using brownfield sites for new housing first before looking to develop on greenfield sites). There was strong support for retaining a sequential element in the East of England Plan - although developers dissented.

There was no dissent to the idea that phasing of housing should ensure that adequate infrastructure was developed before the construction of any further housing which could cause problems.

(By the way, if you are interested in getting some help responding to draft PPS3, please email Estelle Taylor, CPRE's head of campaigns, and she'll send you a briefing we've prepared of our concerns with and desires for the policy.)

Waste: London sends rubbish to the region

The EiP was told that the region is required to take a proportion of London's waste. This turns into a game of 'pass the parcel' for a county such as Hertfordshire, which has minimal landfill capacity of its own. All the counties agreed that they needed to know what amount of waste they would be required to take from London in the future, and that there should be an 'equitable and fair process of distribution'.

A report on the region's needs concerning waste disposal had been produced by ERM, a consulting firm. It transpired that the firm had produced a second report, of which some participants were unaware. The regional assembly was in favour of ERM I but not ERM II (for unstated reasons).

The Institute of Chartered Engineers pointed out that only about one-third of waste is domestic; the rest is industrial. Around 65% of that industrial waste (43% of the total) originates from construction and demolition work.


Economic development - and casinos


Employment land was discussed, including the need to safeguard the existing stock, and the need for regionally distinctive criteria for identifying employment land needs. Were the policies in the draft plan adequate or too prescriptive a guide for local authorities when preparing their Local Development Documents?

On retailing, there was extensive debate about retail hierarchy, and whether the policies in the plan worked against a town developing. Flexibility was needed in the policies to accommodate the aspirations for regeneration at Stevenage and Harlow.

The discussion ended with consideration of whether a policy indicating suitable locations for casinos should be included in the plan, and where those locations might be. There were descriptions of the advantages of Great Yarmouth and Southend from interested parties, but acceptance that there may be other suitable locations.


Thames Gateway South Essex 

Job, Housing and Green Belt?

In general, the sub-regional policies were supported. Policy should be driven by areas of depredation and the need to develop jobs alongside any prospective development.
The jobs targets were seen as challenging, but achievable with significant interventions. Some authorities expressed a need for a cautious approach to jobs. The issue of out-commuting was raised and whether this could in fact be reduced, given the area's role in relationship to London.

Some developers pressed for Green Belt review to allow firms to expand. However, the Government Office representative implied there was ample land to achieve the jobs proposed - and, therefore, a strategic review of the Green Belt was not needed to achieve the jobs target. Small-scale changes could be handled through proposals in local development frameworks. 


Town centre or out-of-town centre? 

Alarm was expressed by Basildon at the call not to label Lakeside as an 'out of town centre' but to instead call it a town centre. The alarm was due to fears that this labelling would lead to major expansion, which could have an impact on Basildon.


Debate ranged round discrepancies in the schemes in the Regional Transport Strategy and in the Thames Gateway Business Plan, and also around the issue of blight caused by including schemes. It was pointed out that including reference to a Thames crossing pre-judged the outcome of studies. English Nature pointed out the conflict between the transport objectives and other regional objectives (an issue which was also raised in the Strategic Environmental Assessment).


Design quality 

The issue of need for good quality design (including water efficiency) was raised, but the East of England Consortium argued against having too high expectations for good design throughout the area. It was pointed out that "Some would say that it costs as much to design a bad building as a good one; it depends on who is doing the designing".

The Countryside Agency pointed out the lack of reference to countryside character and lack of sense of place. The agency wanted minor changes made to Policy TGSE4 ('the environment and urban renaissance') as well as a new point added that local authorities identify and implement proposals that are  "based on a sound understanding of the distinctive character of Thames Gateway and the contribution that a sense of place can make to achieving a higher quality of design". The Countryside Agency wanted to see a links made to Greening the Gateway (part of the Government's Sustainable Communities Plan) and to the Green Grid (a project to develop a network of open spaces and cycling and walking links throughout Thames Gateway South Essex) in both policy TGSE4 and its text, thus putting the "Natural landscape at the heart of the development process".


Haven Gateway

Ports and the economy

There was some debate about allowing ports to dominate the economy of the area and the need for a broader range of employment opportunities. The debate also looked at strategic employment site issues, including the need to consider health issues and to reflect the role of the health care sector as a generator of employment.


Town expansion and village coalescence concerns

Concerns were expressed about the proposed expansion of both Felixstowe and Ipswich and the potential for coalescence of villages located close to these towns. Concern was expressed, particularly by those local authorities whose boundaries were close to proposed extensions, that the sites for extensions should be determined by the Local Development Framework process.


Quest for more funding could push up housing numbers


Colchester Borough Council asked for an increase in housing so that it could achieve 'growth point' status and apply for funding. However, views were expressed over whether funding should be driving planning. Proposals by developers for a new settlement at Marks Tey  were not supported.


Should the Suffolk Coasts and Heaths AONB be extended?


A great deal of discussion surrounded a widely supported call for an extension of the Suffolk Coasts and Heaths AONB to the south side of the Stour Estuary. As there is a due process for doing this, it was held not to be a matter for the Regional Plan. Wording was sought to support the special landscape of the area without giving tacit support for the extension of the AONB in the plan. The Development Agency pointed out that tourism depended on the environmental quality of the area.


Week 9


Cambridge sub-region

New settlements in Green Belt?

Some developer called for two more new settlements of up to 25,000 houses each, one to the north of Northstowe and one to the south. This practicality of this idea was queried, in particular around the infrastructure requirements, the argument being that it will be difficult to meet infrastructure requirements for settlements already in the draft regional plan, let alone meet requirements if additional settlements go ahead. It was also pointed out that a southern settlement was more likely to be for Stansted rather than Cambridge.

As to be expected, there was some debate about the need for a Green Belt review, for example to allow expansion of Northstowe. East Cambridgeshire will review the outer boundary, designating additional land as Green Belt.


Market towns dormitories for Cambridge?


Debate covered the balance of houses and jobs and the differing market towns and whether more housing should be accommodated. It was suggested new settlements might be more sustainable than expanding market towns, however this was countered with the view there was little evidence for this and also market towns have existing public sites and services. It was pointed out that the three market towns were constrained by floodplains.


Alconbury airport

Despite there being a spirited promotion of Alconbury as a small regional airport, the case for the need for an airport was not established. It was also made clear that although Alconbury was a rural brownfield site, much of it was green and the road network wasn't adequate for much development. As well, it appeared that there were real constraints on the provision of a rail link. The debate appeared to support leaving the current policy in the plan as it was.


Stevenage sub-area   

The EIP considered the opposing views on development on greenfields. Time was spent on defining where exactly Stevenage is, because some people felt it was in the London Arc and others in the London-Peterborough 'growth area'. There was also disagreement on the precise borders, which many assumed was the A1(M). There was some debate about balancing housing and jobs, and fears that building many new houses without ensuring local jobs would lead to commuting. However, it was pointed out that in fact Stevenage is a net importer of labour - the 11% who commute out to London are outnumbered by those from the north of the town coming in.


Expansionist proposals?

Horror was expressed at the suggestion that development might take place not just to the west of the A1(M) and north into 'Forster country' but also east and south of Stevenage. This also prompted comments about deliverability and the principle that Stevenage should not encroach visually into either of the neighbouring valleys. However, it was pointed out that the draft East of England Plan does not contain any plans for expansion east and south.


Green Belt

The idea of rolling back the Green Belt, as would have to be done for development to take place west of Stevenage, and then promoting similar-sized bits of countryside as Green Belt miles away was described as 'bizarre' by the regional assembly representative.

Representatives for smaller settlements called for mini Green Belts, even if only a couple of fields, to help them to retain their identity and integrity rather than feel swamped by Stevenage.

It was stated that the area between Luton and Stevenage currently not protected by Green Belt status is to be so designated



Week 10


Arguments were broadcast on web

Because so many people were interested in listening to the arguments about the London-Peterborough 'growth area'  - a full auditorium's worth - the regional assembly broadcast a live audio web cast of the proceedings.  The archived web cast is available on the assembly's website (www.eera.gov.uk).

North Weald: a new settlement or barrier to regeneration?

The debate focused on whether development at North Weald would help or hinder Harlow regeneration - and developers were split on the issue. It was pointed out that development at North Weald wouldn't be being considered if the land were arable land and not former airfield. Essex County Council saw expansion at North Harlow and North Weald as the least bad options.

The view that there was a wide measure of support for the regional plan was denied (to applause) by the Harlow Civic Society.


Where will the jobs come from?

Talk ranged around whether houses were for commuters and whether jobs should be generated in Harlow rather than relying on Stansted to deliver employment.

Part of the discussions centered on Stansted and the relationship with the sub-region and the weight being put on jobs being derived from airport expansion. Discussion ensued as to skills levels of such jobs and the fact that BAA is currently advertising jobs in Europe, which suggests there's no guarantee that local people will derive employment. CPRE pointed out that using Harlow, as a dormitory for Stansted employees was not in reality a way to build sustainable communities.

The regional assembly suggested that if the second runway didn't go ahead, then intervention to deliver the employment would required - though by whom and what sort of intervention was not discussed.

Concerns were raised by the London bodies that developments in the Lower Lee Valley and surrounding 'the Olympic Village' would mean there were not enough jobs to meet aspirations of Harlow as well.

The Government Office for the East of England indicated it wasn't possible to forecast for jobs more than 10 years into the future, as this would be 'pretty dodgy planning', and emphasised housing numbers. At that remark, the Chairman asked the Government Office if this meant the regional plan was a housing-led strategy. The Government Office hastily replied 'no'. Environmental concerns were expressed by the National Trust, particularly over the damage to Hatfield Forest from the proposed airport expansion.

Not enough water to go around and no way to treat the sewage  

The Environment Agency suggested that current water supplies couldn't meet the projected need and there was a requirement for new sources. The agency again emphasised the 25% water efficiency requirement and the need to put the requirement in an Act and enforce it - but how? There would also be need for de-salination, reservoirs and bulk transport, which would need huge energy resources. 

Sewage treatment capacity for the proposed Harlow development does not exist, according to Thames Water, which indicated it doesn't have money for water infrastructure studies, no locations for facilities, no technological solutions and no funding until 2010.

Better recognition needed for environmental assets

The importance of 'green infrastructure' planning was discussed. There was concern expressed that the Government had pre-judged the EIP process by the suggestion that 10% of growth area funding should go into green infrastructure projects. The Government Office responded that this was not so. A level of growth was expected but decisions had not been made about scale and location of growth. This last comment was met by laughter from participants.

It was suggested that reference to the concept of environmental capacity should probably be a generic policy. The Countryside Agency observed that the regional plan consistently failed to recognise the wealth of environmental assets. Concern was raised over the very poor quality of the sustainability statements prepared by developers. The regional assembly admitted the shortcomings - a sentiment which was endorsed by the Chairman.

The need for strategic review of the Green Belt was said to depend on the outcome of the EiP, but the regional assembly considered it unnecessary.


27 February 2006  Week 11 (21 - 23 February)

Matters 8K, 8L, 8M


Matter 8K: Western Part of London Arc in Herts.

Is London Arc a sub-region, requiring a spatial strategy?

Herts County Council and several local authorities questioned whether the London Arc was a sub-region.  It contained areas with many differing characteristics, including both growth areas and restraint areas, and was divided by radial routes.  The sub-regional policy in the plan was not addressing any strategic policy deficit nor specific issues affecting the area.  More work was needed.


Should Watford and Hemel Hempstead have been identified as sub-regional centres?

Herts County Council did not understand why these towns had been specifically identified; the area was polycentric.  EEDA argued that Watford needed support for regeneration as a regional transport interchange, while Hemel Hempstead was recognised as a retail centre, with an economy restructuring into higher value fields.


Working with London?

Some were disappointed that there was no coordination with the policies in the London Plan relating to the Boroughs in north-west London; others considered that the area was fundamentally different from NW London and were concerned to ensure that the metropolis did not absorb and destroy the south of Hertfordshire, as Middlesex had been absorbed and destroyed.


Brownfield or Green Belt?

Developers predictably disagreed with EERA and the local authorities and sought more greenfield opportunities, arguing that expansion was essential to add critical mass to regeneration policies.  Hemel Hempstead was identified by them as a town that should expand in almost all directions, partly to restore confidence after the Buncefield oil depot explosion.  Dacorum Borough preferred a policy of restraint, and limitation of greenfield development, in order to maintain the focus on regeneration of the town centre and industrial area.


Jobs and houses

Local authorities saw the jobs targets as very challenging and were unclear as to their basis.  They appeared to be out of line with the housing figures and some saw them more as aspirations than as targets.  The local authorities had less concern with the housing figures which were largely in line with forecasts based upon recent urban capacity studies.  However, it was not clear whether the housing figures were maxima or minima; EERA had said that they were both!


Is there an infrastructure deficit?

Participants were broadly agreed that, in this most congested part of Hertfordshire, with much of traffic passing through on radial road and rail routes, the improvements in the plan (M1 and M25 widening) will be outweighed by the RSS growth proposals.  Thameslink 2000 will not be implemented until 2014.  Transport grant funds are insufficient to improve public transport (bus) services.   EERA reiterated that if infrastructure is not provided, growth cannot proceed. 


8L Eastern Part of  London Arc - Essex


Chelmsford for a sub-area?

Initial debate covered boundary issues whether Chelmsford and Maldon were in the LA which covered  the area Metropolitan Green Belt or should be a separate sub-area requiring a more explicit vision. The two areas are very different Maldon being very rural and with a number of environmental assets, where development  restraint was needed.


Crossrail beneficial or not to this area?

Some debate as to whether crossrail would help this areas congestion problems or whether it would only increase services to Stansted Airport and extend journey times due to it being a stopping serve. EERA had petitioned against the Hybrid Bill.


Employment and housing?

Discussion focussed on the realism of jobs targets and the forecasting reliability, some Local authorities suggested that figures were not challenging and that housing was becoming misaligned due  to big increases in housing over the years. CPRE called for  a strong resistance to new employment sites in the MGB and supported the ECC and BBC in asking for a lower target. Various developers were asking for development in their favoured direction. It was made clear that Chelmsford was not seeking Growth Point Status. Local villages represented by Essex Ass of LC were concerned that more development would destroy their communities whilst Maldon was concerned that restricting development could result in an aging population as there was a need to bring in younger people.


Infrastructure: rail, water and modal shift?

The Environment Agency reinforced its point on water supply and outlined the Abberton Scheme bringing water from Denver Sluice, indicating that there should be a closer link between development and water supply. Chelmsford Borough Council pointed out that: Chelmsford has the busiest station but no link to Stansted, and suggested a need to repackage transport proposals by sub-region.

Chelmsford was at the heart of bus growth in Essex., there were already travel to work plans for all major employers in Chelmsford. School travel plans had reduced car trips by 5-15% in the morning peak hours. SUSTRANS however, pointed out that travel to work was only 20% of al trips and that more restraint measures were needed. Air pollution was a problem due to queuing of cars as all roads were at capacity. Modal shift was dependent on funding. EERA suggested that the highest priority for funds should be given to small local schemes that provided the best opportunity to encourage modal shift and that greater links were needed between development and infrastructure delivery..


8M Bedford. Bedfordshire outside Milton Keynes South Midlands sub-region.


Is it in or is it outside the MKSM Growth Area?

There was considerable debate arising from the confusion of just what the MKSM Strategy covered and what policies in the Plan covered what bits of this area and also if the MKSM strategy could be incorporated in the Plan or left to the next review.  EERA  suggested that there were in fact 3 layers of policy, the generic policies in the Plan, policies of the London Arc except when there were specific sub-area policies. It was subsequently pointed out that the London Arc covered those areas where there was metropolitan greenbelt where in fact South-Bedfordshire had its own Green Belt and was not covered by metropolitan green-belt. The Government Office(Go-East) made it clear that the whole of Bedfordshire was in the Growth Area as in fact the Key diagram indicated (this had been queried) and thus could access Growth Area funding, this appeared to be news for a number of participants. Positive news for Forest of Marston Vale seeking funding, they also sought a target for woodland creation in the Plan.


Canal – is it in or out of Plan?

The proposal for a canal from Bedfordshire to Milton Keynes was supported by the Environment Agency as a good addition to the canal network and for leisure and tourism opportunities. The need to reserve the corridor was discussed and whether this proposal was strategic and needed to be in the Plan.


Jobs targets too high or deliverable and relationship to Luton airport?

Considerable debate surrounded, the issue of the Joint Economic Development Strategy (JEDS) and  Luton airport and the impact on the quality of life and whether it would in fact deliver on jobs. A key question was  whether the area was putting too much emphasis on Luton airport to deliver jobs and the alignment of jobs and housing. Luton Borough Council pointed out that forecasts were assumption driven, but went on to outline the buoyancy of market in the Borough . The representative for the airport admitted that ‘the industry had to address the issue of climate change as the government has to’.


Housing more or less?

The final session was taken up with housing issues. Developer proposals for developments East of Bedford were given short shrift by the Beds BC as they said there was already substantial available land supply and there was danger of competing in the same housing market and impacting on the other delivery plans for Bedford. The GO-East statement that all Beds was in the growth area raised  the issue of whether all parts of it should be contributing to the “step change” required by the Sustainable Communities Plan, and contradicted  earlier assurances from EERA of  “generic” policies applying to the rural areas. CPRE pointed out that the figures in the Beds CC paper showed that the step change was well catered for by the MKSM plans and that there was therefore a real opportunity to deal with the smaller settlements on the basis of clearly identified local needs.

4 March 2006  Week 12 (28 Feb  - 1 March) EiP closing week.

Matters 9A and 9B


Matter 9A. – Delivery and Implementation and Matter 9B – Monitoring review form and content


Does the delivery process have transparency?

EERA, outlines the process it intended implement regional stratgeies. There was much debate as to whether establishing various boards was the best way and if they would be transparent. EERA responded that, while a number of the meetings of the delivery boards would not be open to the public; organisations would be represented on them with responsibility for communication to a wider audience, minutes would be published on websites.  Friends of the Earth observed that past experience of regional forums did not inspire confidence and noted that meetings of the Regional Partnership Group, the key body dealing with delivery, would not be open to the public. 


New policy for implementation chapter

EERA’s implementation plan, came in for a lot of disucussion, from all sides.  Criticisms were various; it was not robust enough, deficient in various respects;  no timetable, no indication of priorities; it lacked any statement of delivery mechanisms and resources; the responsibilities of groups and partnerships involved with delivery were not clear; there was no guidance to local planning authorities to assist them in producing their local development documents.  EERA rejected these criticisms and EEDA supported the flexibility provided by avoiding hard and fast decisions now whilst.


New policy for the implementation chapter – trigger points and conditionality?

The new policy proposed by EERA envisaged  trigger points, which if reached would require intervention to get the plan back on track. and to correct any imbalance would be taken and what that action or intervention would be.  EERA expected to have identified some of the trigger points by the time the post-EiP proposed changes to the plan were published. The policy provides for annual monitoring to ascertain whether the delivery of infrastructure, the growth in jobs and the provision of housing are all proceeding at similar rates Fears were expressed by developers that the policy was designed to stop development.  The East of England Business Group, asked what the response should be if progress towards the jobs target was outstripping progress towards the housing target, said that the answer was to increase the rate of housing build.  If progress towards the jobs target was falling short, the Business Group’s answer was again to increase the housing build rate, to stimulate the economy.  Although strongly argued by the Business Group, few if any of the other parties present appeared to agree that increasing the rate of house building was the answer to every problem.  With the exception of Norfolk, which regarded transport infrastructure as deserving the highest priority, county councils were clear that jobs, housing and infrastructure must not get out of line with other; if they did long distance commuting and increased congestion would result.


When does the water run out- hitting the red light?

The Environment Agency pointed out that  water resources and waste water treatment plants in the region needed to be proceeded in phase with other development.  The analogy of a train running towards an obstruction was widely used.  Was the region running through yellow lights with a red light just ahead, when all development would have to cease?  How far away was the red light?  The Environment Agency preferred to say that we were running through green lights at present; there were yellows ahead with a red in the far distance but actions would be taken to turn the yellows into greens and the red into a yellow before they were reached, although these actions took time.  There was the possibility of increasing capacity at Rye Meads and other treatment plants to meet the requirement up to 2016 but more water treatment capacity would have to be found by then.  The region was not self-sufficient in water at present and more water would have to be imported from Rutland water and other sources.  Surprise was expressed that, while the regional plan was informed by various strategies, economic, housing, transport, etc., there was no corresponding water strategy


How can the target for affordable housing be met?

The environmental and the business lobbies found themselves on the same side for once, in agreeing that the provision of affordable housing was a fiscal, not a planning, issue.  The key was Government finance, not the building of market houses to finance the affordable sector.  CPRE pointed out the anomaly in the implementation policy that a failure to deliver jobs would also jeopardise achievement of the affordable housing target, given that housing may need to be slowed to address balance.


Enough guidance in the Plan for Local Development Documents, and what tariff system?

Most LAS were happy with the guidance, but Friends of the Earth pointed out that the Plan  lacked guidance on climate change issues such as  carbon neutral development and  water efficiency targets. There was a lot of debate surrounding developer contributions for infrastructure through the Milton Keynes example of a flat rate tariff (commonly known as a rook tax). It as pointed out this might be problematic for districts outside a growth area to achieve. It was also pointed out that there were special circumstances existing at Milton Keynes


Indicators, targets, maps and review

There was quite a lot of debate about targets ,EERA had provided a 2 page summary of those suggestions from response that they had agreed to take up. Once more water was focussed on in particular how to monitor water efficiency requirement effectively. Several suggestions were made regarding improvements to the key diagram. GO East suggesting a poster size map with insets for sub-regions.. EERA in their final response did acknowledge that there was a need to reinforce the environmental and sustainability monitoring arrangements and recognised that the plan needed to give more recognition that the Plan needed to emphasise not just responding to climate change issues but seeking to reduce climate change emissions, the difficulty was in finding indicators to measure this at the regional level.


On the need for review of certain matters which have arisen during the EiP , the subject of gypsies and travellers needs, waste apportionment and the need for a new settlement would all be necessary but at different time frames. The first two straight away the latter as part of a general review once the Panel report is out.This review would take the Plan to 2031.




The Government housing projections are due to be published on the 14th March. The Inspector has said that if following this there is a need to look at the figures in the Plan, the participants will be given 3 weeks to put forward further submissions to their statements to  the Panel, or if necessary he will convene an extra session of the EiP.


Next steps in the process for finalizing the Plan for the East of England.

The Panel Inspector publishes his report in June.(CPRE will be preparing a report on this)

Then the Secretary of State makes changes to the Plan and publishes these for a 12 week consultation sometime in the Autumn. (CPRE will be responding to this)

The Plan is then finalized and adopted during early 2007.


Delivery process needs to be transparent

The regional assembly outlined the process whereby it intended to implement regional strategies. There was much debate as to whether establishing various boards was the best way forward and whether the boards would be transparent. The regional assembly stated that while a number of the meetings of the delivery boards would not be open to the public, organisations with responsibility to a wider audience would be represented on them, and minutes would be published on websites. Friends of the Earth observed that past experience of regional forums did not inspire confidence and noted that meetings of the Regional Partnership Group, the key body dealing with delivery, would not be open to the public. 

Implementation plan could be improved

The regional assembly's implementation plan came in for a lot of discussion from all sides. Criticisms were various: it was not robust enough and was deficient in various respects; it had no timetable or indication of priorities; it lacked any statement of delivery mechanisms and resources; the responsibilities of groups and partnerships involved with delivery were not clear, and there was no guidance to local planning authorities to assist them in producing their local development documents. The regional assembly rejected these criticisms and the development agency supported the flexibility provided by avoiding hard and fast decisions now.

Business Group says housebuilding is the answer

The new policy proposed by the regional assembly envisaged trigger points which, if reached, would require intervention to get the plan back on track and to correct any imbalance. The regional assembly expected to have identified some of the trigger points by the time the post-EiP proposed changes to the plan were published.

The policy provides for annual monitoring to ascertain whether the delivery of infrastructure, the growth in jobs and the provision of housing were all proceeding at similar rates. Fears were expressed by developers that the policy was designed to stop development. The East of England Business Group, when asked what the response should be if progress towards the jobs target was outstripping progress towards the housing target, said that the answer was to increase the rate of housing build. If progress towards the jobs target was falling short, the Business Group's answer was again to increase the housing build rate, to stimulate the economy. Although strongly argued by the Business Group, few if any of the other parties present appeared to agree that increasing the rate of housebuilding was the answer to every problem.

With the exception of Norfolk, which regarded transport infrastructure as deserving the highest priority, county councils were clear that jobs, housing and infrastructure must not get out of line with each other; if they did, long-distance commuting and increased congestion would result.

Water will need to be imported  

The Environment Agency pointed out that water resources and wastewater treatment plants in the region needed to proceed in phase with other development. The analogy of a train running towards an obstruction was widely used. Was the region running through yellow lights with a red light just ahead, when all development would have to cease? How far away was the red light?

The Environment Agency preferred to say that we were running through green lights at present; there were yellows ahead with a red in the far distance, but actions would be taken to turn the yellows into greens and the red into a yellow before they were reached - although these actions took time. There was the possibility of increasing capacity at Rye Meads and other treatment plants to meet the forecast requirement up to 2016, but more water treatment capacity would have to be found by then. The region was not self-sufficient in water at present, and more water would have to be imported from Rutland Water and other sources.

Surprise was expressed that, while the regional plan was supported by various strategies, such as economic, housing and transport strategies, there was no corresponding water strategy.

Providing affordable housing is a fiscal, not planning, issue

The environmental and the business lobbies found themselves on the same side for once, in agreeing that the provision of affordable housing was a fiscal, not a planning, issue. The key was Government finance, not the building of market houses to finance the affordable sector. CPRE pointed out the anomaly in the implementation policy that a failure to deliver jobs would also jeopardise achievement of the affordable housing target, given that housing may need to be slowed to address balance.

Enough guidance in the plan for Local Development Documents?

Most local authorities were happy with the guidance provided, but Friends of the Earth pointed out that the plan lacked guidance on climate change issues such as carbon-neutral development and water efficiency targets. There was a lot of debate surrounding developer contributions for infrastructure through the Milton Keynes example of a flat rate tariff. It was pointed out this might be problematic for districts outside a growth area to achieve. It was also pointed out that there were special circumstances existing at Milton Keynes.

Monitoring arrangements need to be strengthened

There was quite a lot of debate about targets. The regional assembly had provided a two-page summary of suggestions from responses received that it had agreed to take up. Once more, water was the focus, in particular how to monitor water efficiency requirement effectively. Several suggestions were made regarding improvements to the key diagram, with the Government Office suggesting a poster-size map with insets for sub-regions. The regional assembly, in its final response, did acknowledge that there was a need to reinforce the environmental and sustainability monitoring arrangements, and recognised that the regional plan needed to emphasise not just responding to climate change issues but seeking to reduce climate change emissions. The difficulty was in finding indicators to measure this at the regional level.

On the need for review of certain matters which have arisen during the EiP, it was said the subject of gypsies' and travellers' needs, waste apportionment and the need for a new settlement would all be necessary, but at different times. The first two were needed straight away, and the latter as part of a general review once the panel report was out. This review would take the regional plan to 2031.

Government housing projections due next week

The long-awaited Government housing projections are now due to be published on 14 March 2006. The Inspector has said that if, following their publication, there is a need to look at the figures in the draft regional plan, participants will be given three weeks to put forward further submissions to their statements to the Panel. If necessary, he will convene an additional session of the EiP.

Next steps in the process for finalising the East of England Plan
  • The Panel Inspector will publish his report in June (CPRE will be preparing a report on this)
    The Secretary of State will make his own changes to the draft plan, and publish a revised draft for a 12-week public consultation sometime in the autumn. CPRE will also respond to this.
    The plan is due to be finalised and formally adopted in early 2007
Population Projections
14 March 2006


Government finally releases Household Projections

Last week, we said that we would report the Government's figures for household projections to 2021 and beyond.  We find the figures surprising and confusing. Surprising because the annual rate of increase for our region is put at 27,800 (2003 - 2026), whereas the Draft East of England Plan estimated 23,900. Confusing because no overall figure is given for population in the region, and there is no information available about the assumptions used in preparing these projections, and hence how the actual figures were derived.

Massive scale

Across the country as a whole, the projections - if translated into numbers of houses built - would lead to 16 square miles of countryside being built on each year. And that is only for the 40% of houses not built on previously developed, 'brownfield' land.

Where did the figures come from?
It appears that the figures are trend-based extrapolations; that is to say, they assume that what has happened in the past will continue to happen in the future.   It is essential to take account of the way that changes in policy can influence trends. Household projections of this sort cannot be used as a basis for establishing housing needs in the region because so many different factors need to be taken into account.

There appear to be three factors that have a significant impact on the final projections: life expectancy, migration and fertility rate. Any small change in just one of these factors could change the projected figure significantly. We are not told anything about the assumptions made for them.

Where does this leave the EiP?
If the Inspector decides to invite further submissions from participants in the light of the Household Projections, then CPRE will respond. We think that we - and other participants - will have some difficulty in making sense of such sparse and ill-supported figures.

If you would like the pleasure of reading the ODPM's figures first hand, you will find them on the Government's website:



Transcript  - East of England Plan, Examination in Public 

Matter 8H1:  Harlow section of Stansted/M11 corridor

February 15, 2006

Transcribed by Mary Edwards, 16/02/06


START of session on environmental issues, particularly water and sewerage  (17.20 – final session on day two of Matter 8H1)



Chat about whether or not to continue later than usual in order to discuss water and sewage issues particularly.  People voted to stay on.


Let me turn to the water environment issues.  In the Panel note it says the Environment Agency (EA) points out that catchment and this is the relevant areas from which water would have to be drawn to supply development in this sub-region, the relevant areas according to Catchment Abstraction Management Strategies show that they have no water available being overlicencsed and over abstracted.  Growth will require additional water resources development and this is in addition to water efficiency of 25% in all new development and then that there are water quality issues relating to low flows in the rivers Leigh and Stort, concerns about the ability of Rye Mead’s sewage treatment works (STW) to handle future demands without breaching EU environmental standards and that known technology I believe does not provide a solution for doing this within Rye Meads so that an alternative approach has to be looked for, as I understand it, in a location which might  enable discharges to be made elsewhere, that place again. 


Then there are flood risk concerns which I won’t elaborate on now.  They are raised particularly in the downstream sense by the GLA and I think the issue of sustainable drainage schemes and so on has been illuminated elsewhere.  My main concern is that we cover these water supply and sewage treatment issues as factors to be taken into account in the strategic thinking and I am not talking about the detail so much as is there a timing factor involved here, is there a locational factor involved here that we ought to be taking account of when making strategic decisions about development.  So with that I turn first to the Environment Agency.  And then Anglian Water, Thames Water, I beg your pardon, who are here to talk about this.  Environnment Agency please.


Environment Agency (EA)    Debbie Jones

Our point is that any development in this area should not be considered in isolation.  Neither Harlow nor North Weald or any other location can be considered from the East of England or indeed the South East.  The challenges on water resources come from a combination of developments and population and of course we are the driest part of the country.  Therefore the effect of proposed development is cumulative.  


We believe that the demand for water or shared water supplies could be met if there was 25% improvement in per capita water consumption so this would mean that explicit in any new build that the property was 25% more water efficient.  In terms of resource development, locally as you said, resources are fully committed to existing abstraction and the environment, and further development would mean major resource development outside the catchment.  Now that could be something like the Oxford reservoir or the desalination plant or indeed a bulk transfer from the north from Anglian Water.  All those things would need to be delivered according to water company plans and they are long term projects. 


Locally within one or two spots in fact North Weald and south of North Weald, if you look at our catchment abstraction management plan, it does say that there is some water available to meet local needs but that probably means that it’s small development, might just be farming needs and that any abstractions would probably be subject to conditions which would be unsuitable for public water supply because obviously you need a secure supply.


Moving on to the sewage issue, the sewage treatment issue, Rye Mead as we mentioned before, presently serves a very large area which includes Stevenage and Harlow.  The scale of the development that is proposed across the catchment will almost certainly require higher standards of treatment and just to explain that, and the comment that you made, is that if you increase the loading on the STWs the available dilution in the water course is less therefore the technology to meet the standards has to be that much higher.  What we’re saying is that with the proposed population growth, the technology is not available to meet the standards beyond that which it can meet at the moment.  And I have to say that Rye Mead is an exceptionally highly developed and highly efficient sewage works at the moment.


One of the solutions to that could be to provide additional treatment facilities somewhere within the catchment that would enable the self purification capacities of the river systems to be harnessed, but to do that the timescales for developing that additional infrastructure and enhancement would be no doubt quite long term.  As a rough guide I would presume, I am informed, would take probably some thing between seven and nine years to develop a fully operational STW.  But I’m sure my colleagues at Thames Water could give you a more precise figure on that.


The other issue with sewage treatment developments at the top of the catchments like North Weald, there are existing sewage works, they are quite small, and even if they have additional capacity the water courses at the top of the catchments are quite small.  They have low flows and whether the hydrology is appropriate to take additional discharges from the sewage works would have to be looked at and so I think what I’m coming around to in all the development what we’d say is that we do need integrated water cycle studies and they in themselves cost money and take time to do so that any development, specific development proposals must be accompanied by quite detailed integrated water cycle studies.



Thank you very much.  Just to confirm the point about 25% water savings which we’ve heard quite a lot about before and you say all new development and this would apply not just to the large developments that we’ve been hearing about of 6, 00 or 10,000 dwellings or even a few thousand but virtually all the development in the sub-region including the small scale development that goes to make up the numbers because the numbers still add up to the flow that has to be dealt with.  Is that right?


EA   Debbie Jones

Yes chair.  You’re right and in addition to that it would need considerable demand management from existing householders.



Thank you.  I’ll turn to Anglian (sic) Water, you may be able to help us with some of the points here and in particular the points we’ve just heard here from the EA about the need for alternative, when you get, I’d like you to cover both water supply and sewage treatment and when you get to sewage treatment about the options for doing something in relation to Rye Mead.  Clearly that needs to be thought about.  So I turn then to Thames Water.


Thames Water (TW)       Mark Dickenson

Just want to clarify a few points before we do start.  TW are the sewerage undertaker for the Harlow and surrounding area with the exception of Brentford and Epping Forest where we provide both water and waste water services.  I think you will find that the majority of the Harlow area for water is supplied by Three Valleys Water (TVW) not ourselves.  We have heard today and yesterday and the references to sustainability and deliverability and I would like to make some comments on both those topics.


Sustainability – In considering sustainability of a development or strategic growth area it is important to consider this beyond the context of the immediate site environment.  For sewage treatment, this will mean that environment of the possible receiving treatment works and critically the water course into which the treated effluent is discharged.  This can in some instances be some distance from the development area.


Deliverability – It’s important not to underestimate the time required for waste infrastructure provision.  Waste water infrastructure is essential to any development that takes place.  Phasing of the infrastructure in line with developments in the case of waste infrastructure needs to happen ahead of any development.  Failure to provide infrastructure in time can lead to internal sewerage flooding because the sewers are not large enough or pollution of rivers because treatment plan cannot be built in time.  Under the Water Industries Act, TW Utilities has a legal obligation to provide infrastructure and in the majority of cases infrastructure can be provided in time.  Small construction projects take 18 months, upgrades to treatment plants around 3 years and relocation of treatment plants can take 7 to 10 years.  For instance, Reading STW has recently been relocated.  From an engineering point of view it was not complex and from a planning point of view had the support of the local planning authority, but still took 7 years to construct at a cost of over £80 million. 


TW often gets challenged as to why infrastructure takes so long to put in place.  This is often as a result of external factors.  For example TW is reliant on the EA for defining the treatment limits we work to.  It is not uncommon for it to take 2 years for treatment limit to be released.  This is because the EA needs to undertake comprehensive surveys and modeling work.  Added to the 3 years for design and construction, 5 years becomes a considerable period.  Inability to gain planning permission is also an issue.  We may need to lay a pipeline but the requirement for an Environmental Impact Assessment (EIA) may also substantial increase the timescales required.  Lack of early consultation from local planning authorities and developers can also delay the delivery of infrastructure.


TW is reliant on OFWAT to set its funding levels.  The recent determination for our funding period up to 2010 has allocated us less money than we requested to meet the growth levels of Regional Planning Guidance (RPG) 9, in advance of RPG14.  The additional growth levels identified as part of the East of England Plan will place a further strain on these funding levels.  The EA defines statutory treatment limits for us which are dictated by EU law.  They effectively dictate the chemical load which we can discharge to the river.  The more development that takes place the greater the chemical load we discharge to the river.  In order to keep the river at the same environmental condition, the EA tightens the treatment limits so that the river remains the same. 


TW already has some of the tightest treatment limits in the country.  Although Rye Meads is not the lowest, it is within the top three out of 350.  The top 9 of which are rapidly approaching the limits of what is physically possible to treat with existing sewage treatment technology.  Following the Milton Keynes-South Midlands Examination in Public (EiP), TW has recognized the need to develop and trail new technology.  However this has not been funded as part of the 2005 to 2010 bid to OFWAT.  Either as a pilot plant or as a series of plan upgrades, assuming funding was allocated in 2010, a trial would be required taking 2 years and if successful, construction would be a minimum of 3 years taking the time period up to 2015.  In addition to this problem, the EA has also indicated that it will be introducing upper tier treatment limits for which TW has again not been funded by OFWAT.  These are treatment levels which are 3 times the normal treatment limits but must be met 100% of the time instead of 95% of the time.  To ensure that there is no failure of the requirement, robust testing of any new process would be required again extending delivery timescales.


Moving on to some specific issues around Rye Meads and later on moving on to North Weald.  Rye Mead STW – Waste water for the Harlow areas is treated at the TW Rye Mead’s Sewage treatment works located at 5 kms west on the River Leigh.  This works also receives waste water for flows from other areas.  These include Sawbridgeworth, Welwyn Garden City, Stevenage, Hertford, Ware, Stansted Abbots, Hoddeson, and North Broxbourne, and also takes trade effluent from Stansted Airport in the form of glycol.


The cumulative impact of growth must be taken into account.  The growth in Harlow alone is an increase of 25% or 50,000 population equivalent on the works.  Rye Meads STW is located at the headwaters of a sensitive river.  Most of the river is made up of what we discharge from the STW therefore further growth will inevitably results in a reduction of the treatment limits.  The EA have yet to confirm the effluent consent that would be required for the levels of projected growth in the area, but have verbally stated that these would be consistent with the Water Research Council’s model.



Can I just stop you there.  There is no need to read all of this out.  We have most of these points from your statement.  What we are anxious to get into is what’s being done about it and what we are to do about it.  OK so we are aware of the factual background but particularly interested in the options and actually whether there is a process going forward between the water industry and EERA (East of England Regional Assembly), or the planning authorities and the GLA in particular because clearly their area is also implicated.  So if you could cut to the chase.


Thames Water     Mark Dickenson

I’ll cut to my conclusions in just one moment but you might be interested in a statement on North Weald about a statement that Lend Lease made in their written submission.  Lend Lease have said that North Weald is particularly well served with regard to most utilities including sewerage.  They then go on to say that current sewerage works has a spare capacity of approximately 1,500 properties.  North Weald STW currently treats sewerage for a population equivalent of about 5,000 and while the equipment on site may well have a theoretical capacity to treat another 1,500 properties or a population equivalent of 3,500 that is likely to trigger a new consent from the EA and therefore what we would say is that it is not fair to say that there is spare capacity there for another 1,500 properties.  We’ve also heard about the potential river flooding that could occur further downstream and again that would be an issue for the EA to determine whether or not sufficient hydraulic capacity existed in the receiving water network.


Just to go on to our conclusions, to consider further the suitability of the Harlow – North Weald area as a strategic growth area we would encourage the EA to undertake a full water cycle study for the area.  This would include river modeling to identify the existing sewerage treatment works, whether or not there was sufficient capacity for us to drain into the ah, hydrologically drain into the existing rivers and also identify the potential  locations of any new strategic STWs that they felt were necessary.  


Engineering solutions to waste water drainage and treatment may be available, but in the context of the environmental constraints the EA have outlined in their submission, it would appear that such solutions are unlikely to be easy to be identified and without significant financial costs or quick to deliver.  TW’s next opportunity to obtain the funding for the growth identified in the draft plan for the East of England will be from 2010/11 financial period (as referred to as our AMP 5 period).  This process will begin in 2007/08. 


The government has confirmed in its draft revised circular on planning obligations that the use of Section 106 agreements is not appropriate for the funding and delivery of water supply and waste water infrastructure.


Just one other point I would like to pick up on, the 25% water efficiencies on new build, while TW supports the principle of this one of the things we are concerned of is how we ensure that they are, that water efficiency is maintained long term, for instance if people redevelop or refurbish their bathrooms and subsequently fit power showers or not water efficient products.  That’s all I have for now.



If I can summarise what you say in layman’s terms, we have a problem.  We have no technological solution and no locations on which to plan facilities to solve that problem and no funding as far as Thames is concerned to address it until 2010?


Thames Water      Mark Dickenson 

With regard to the funding that is correct with regard to 2010.  Some of the other points may be better directed to the EA with regard to suitable locations.



I will come back to the EA because as I understand it the EA is calling for water cycle studies to be undertaken but you have just replayed that call to the agency so I’d like to know first how this happens.  Are we talking about different levels in other words the agency is looking at water cycle studies related to particular developments but you’re talking about needing to do it on a sub-regional and a wide sub-regional scale at that, so I’d like to hear from the agency on that next please.  I appreciate others want to come in on this.  You can see why I wanted to originally address these issues before lunch yesterday.  EA please.


EA      Debbie Jones

Unfortunately we are not funded to do strategic water infrastructure cycle studies for the catchment.  On terms of local studies we would try and contribute to some sort of partnership arrangement, but we are not funded to undertake the cycles themselves.



Would you agree with TW’s analysis that a sub-regional scale, a wide sub-regional scale study is need?  We don’t have much information to go forward with on a detailed level in relation to actual solutions to this problem at the moment do we?


EA        Debbie Jones

No, we don’t have the information and with all these I think it is a strategic view that we need but we don’t have that information.



Thank you.  Well we’ve reached an interesting point here.  I’d like to turn to Friends of the Earth.


Friends of the Earth, East of England       Mary Edwards

Boy am I happy to come in here.  I personally would call that the smoking gun.  I’ve been looking for it but thank you Thames Water and thank you the Environment Agency.  I’m pretty nonplussed even by my standards.  I wanted to come in particularly on this.  My bigger picture was on sustainability, global warming, CO2 emissions and indeed water, issues related to climate change.  But if we should possibly have time I might get back to those but I wanted to ask a couple of questions on this, points of clarification really because I am so nonplussed by this.


Has anyone anywhere done any kind of, even a back of the envelope attempt to cost all of this?  The EA doesn’t have the money to do the studies, TW is throwing it back to the agency because they don’t have the money and there is no chance of getting the money, even asking for it before 2010.  This is quite quite astonishing to me that we have come this far and this is where we find ourselves.  So has anybody got that back of the envelope amount of money that this is going to cost, including the sewage and the supply?


 Also what I have never heard, has within the figuring on this factored in the reduction in supply because of climate change because obviously we are looking at a bit more rain in the winter but much less rainfall in the summertime so how is this being factored into the question of whether or not we actually have the supply? 


And finally what I’m also not clear on is whether or not the EA and TW are looking at the total water picture and sewage picture in terms of for instance on waste we frequently talk about just municipal solid waste and we forget about all those thousands and millions of tonnes of commercial and industrial waste and all those other difficult to handle things.  So are you looking at the total water picture so that all of the, not only houses that are going to be built, but all the commercial development etc., are you looking at those water requirements and sewerage requirements as well?



I will come next to developers Lend Lease and Savills I think to begin with, ah yes, let’s have Anglian Water again...


(Brief toing and froing over Thames Water not Anglian Water)

Thames Water

Sorry sir Thames Water.



Yes I keep calling you that because of…



We are Thames Water not Anglian Water



I know you are Thames Water.  It’s my fault.  I tend to think of the words Anglian and Water in the same breath after the time we spent at Ely hearing from them, but I know who you are, Thames Water.


Thames Water            Jason Stratton

I just wanted a point of clarity really.  The Agency mentioned, when talking about the water resources for the strategic growth area, the possible use of the Oxford reservoir that TW is currently undertaking studies on.  I am the planning manager for that project.  The demand for that project is being driven by growth in Swindon and Oxfordshire and London.  The growth in the East of England region is not a factor driving the development of that reservoir.  We’re fully developing a reservoir that will meet the needs of London, Swindon, and Oxfordshire and not, as I say, East of England in that scheme.



Sir, as I say, I don’t think we have Three Valleys Water here, and I appreciate that water supply to this sub-region isn’t primarily for you, but what you are saying is that as far as at least water resources are being developed in your region, they are spoken for?



Yes Sir



Thank you.  Now Lend Lease please.


Lend Lease             Adrian Smith

As has been amply demonstrated just in the debate that has just happened, the provision of water to cater for growth in both households and employment that is projected for the sub-region and the region as a whole, is an issue of some concern and that is regardless of where that growth goes across that region.  We recognize this.  However it is also worth noting that from investigations that we have undertaken and also from discussions we’ve had with Three Valleys Water (TVW), which is the provider for water, would be the provider for water in North Weald, and in both his submission and his correspondence to us, it has confirmed that not only is it obviously his duty to provide water for all future needs, but it has - it is making allowances within its long term plans to cater for this growth commensurate with levels outlined in the plan.  And that was their correspondence to us. 


We are also aware obviously, and are exploring other opportunities to help that water efficiencies and to supply a proportion of the North Weald’s water demands from other sources and as you are aware a number of these issues and a number of these ways of water management have been already identified whether this is water harvesting of sustainable urban drainage systems (SUDS) and efficiency measures that you would put in to any new development particularly of the scale, that type of development of North Weald would become, we potentially have more opportunities to enhance that well above the 25% efficiency levels that are currently being sought.  We will be exploring these options with TVW from the earliest possible times.


It is also important to note that comments made by TVW on the benefits of large scale development as opposed to large scale piecemeal development also need to be taken into account.  It says that urban concentrations present particular planning challenges for water supply and a large amount of development within or adjacent to existing urban sectors would require significant distribution systems, upgrades and expansion and when development is piecemeal and spread over time, it is more difficult to apportion these costs between developments.  Importantly the company identified that large scale new settlements facilitate a more efficient approach to the provision of this new infrastructure and obviously developments of the scale of, as I said, of North Weald and other large settlements that have been promoted by people around the table do allow for this careful and coordinated planning and implementation of water efficiencies and conservation measures and does enable and give time for people, for the utilities and others, and the Environment Agency to plan for the long term future, gives that greater certainty.


Moving onto the sewage treatment issues, although in the past it has been stated that obviously TW operates with a certain degree of headroom for future growth as we’ve just heard, that degree of headroom is probably not as great as people would wish.  However, from our early investigations, and yes we have had these investigations undertaken by Atkins, and they did indeed indicate that the NW STW has spare capacity for a further 1,500 homes and obviously we are aware of the consent issues that that would require, and obviously we would be looking to overcome that and have discussions with both TW and the EA as soon as we could to make sure that those consent issues and any flow management measures would be incorporated into any design to make sure that it didn’t have any issues of flooding risks from discharge.


We have also been advised by TW that subject to the expansion of Rye Mead, and obviously that is potentially a big subject too, which is not just to undertake and cater for NW’s development but, depending on that and subject to that RM’s expansion, that it would be able to receive foul water from our proposed development through the long term.  We are also obviously exploring other options of developing treatment facilities on site that would cater for some if not all of the treatment that would be required and also possibly allow for the consolidation of the existing Thornewood and NW works.  Thank you.



Thank you.  I think our perception is that there is an issue here for EERA as much as for anyone else in terms of the Plan and the overall scale of development at regional level rather than for individual developers, though clearly their role in delivering anything will be important.  With that in mind I come to Savills and with an eye on the clock please, Mr. Brighton again please.


Savills                      Mr. Brighton

Thank you sir, I will be very brief.  We have been aware of the difficulties at RM for some little while and as part of the consideration of any scheme north of Harlow we have given a good deal of thought to the whole issue of waste water treatment and what I hear from my left is really a single model approach based on really existing practice.  But there are other approaches and certainly one which we believe has great promise for urban extensions of the type that are proposed around Harlow is the whole concept of local treatment based on single or perhaps double neighbourhood level of treatment.  These, from a sustainability view point, are much more energy efficient than piping sewage five miles down the valley to a distant facility. 


As I mentioned yesterday in terms of achieving the water savings requirements, we see that the whole issue of grey water recycling and storage on the site and dual pipe systems containing both potable and non-potable supplies will become a necessity on all development and certainly it’s something we assume will be required as part of any scheme that we are involved in, and it’s only by achieving or implementing those sorts of measures that you will achieve the greater efficiency in the use of water.


Clearly I take your point that this also needs to be extended to existing water users in the region to be fully effective, and to complete the integrated nature of this approach, the solid waste that results from that process is potentially useable in biomass power generation, again within the same locality so rather than just recognize a problem and set it out to you, we are beginning to develop solutions which are capable of being implemented commercially.



Thank you.  The North Weald Bassett Community Action Group please.


North Weald Bassett Community Action Group

Thank you chairman.  We touched on flooding yesterday and you kindly suggested that we return to it today.  This is the opportunity.  We at times have too much water which is quite a strange thing to say, but this occurs due to flash flooding, normally in the summer period, and we are advised that this normally occurs every 40 to 50 years, but we have had three in the last 30 years, one every ten years.  We’ve had two flood alleviation schemes in NW and one in Thornewood village, which is in the parish.  They’ve been installed over the recent years at a cost of over a million pounds each which at the moment are adequate for our needs but unlikely to support a new settlement.


The flooding, may I remind people, has in fact been 4 foot high in many of the houses around the High Street.  This has contained water and effluent.  This has been detrimental to health, not only from the sewage and water ingress but also from mental stress.


It has caused reduced property prices in the area and is also been a significant increase in insurance policy rating for the area as it has now been recognized as a flood problem area.  All local planning does take this into account, but if I may, may I ask the Panel please to give their assurance that special consideration is given to the North Weald flooding issue when making their recommendations.  Thank you.



Thank you.  We have that also from various written submissions.  I’ll turn back to the EA please to come back on the issues to do with how this is assessed and whatever you were going to say.


EA           Debbie Jones

Firstly I’m sorry.  I didn’t mean to mislead the Panel by quoting the Oxford reservoir as a source of supply.  I was merely using it as an example to say that major resource development is needed for the South East of England. 


Secondly, if what I think we are asking is that, if sub-regional development proceeds, that we need collectively to do a piece of work and that to meet the aspirations of the RSS, we need to set out terms of studies and needs, and that would be in terms of studies for water cycle and in terms of need, that if the RSS thinks or directs that we need to start thinking about sewage works for future development then it should instruct us to go away and start doing a site search.  Thank you.



Thank you.  And when you say ‘we’, who other than the Agency do you have in mind?


EA            Debbie Jones

I would say that is in partnership and that’s developers, Thames Water, the Agency, perhaps some of the local councils.



And EERA?  Unintelligible  Thank you.  Let’s take the Government Office next please.


GO-East                    John Dowie

Thank you.  Just trying to pull some threads together from the previous discussion.  I think we’ve got a number of issues here that iterate between themselves.  The understanding that I have is that the water industry needs clarity of development levels in order to meet that development both in terms of water supply and disposal as well.  At the same time they’ve got constraints in terms of rolling out new infrastructure whether it’s upgrading existing sewage works, whether it’s building additional sewage works.  The study that has just been referred to clearly does need to pull together a number of partners and needs to be done in partnership.  I’m sure that the Office of the Deputy Prime Minister would be willing to contribute to deliver such a study, is best done in the context of a development framework.  So I understand.


I think the issue for the Panel and the development of the RSS is to get a better handle on the lags or the implications for the development phasing of the lags required in delivery of the sewerage infrastructure.  I think things today have been left rather too loose to allow you to do that properly and to take a proper judgment, and I think there may be a window of opportunity between now and the implementation session in a couple of weeks time to try and pull together a better piece of advice to you to give a sense on the development phasing consistent with the existing infrastructure.



Thank you.  Can I take up just one aspect of that and is there any sense in which Sustainable Development and considering Sustainable Communities requires a more holistic approach rather than the sort of sequential one that you imply there, where you decide where development is going to go on a regional scale and how much you are going to have and then you deal with the consequences in terms of engineering the environment to cope with it.


Whereas perhaps you make that decision perhaps all in one rather than simply regarding the water environment consequences as a consequence, as an implementation issue because clearly it may have an influence on the options available to you as to where development takes place, in what quantity over what timescale and so on.  So is there an element in which more integration of the process is required and that the reason why we are in a little bit of a bind this afternoon is that that hasn’t been the approach so far?


GO-East                    John Dowie

I think what we’ve got is a process which inevitably has to involve a degree of iteration between an emerging spatial strategy and an emerging strategy for the water infrastructure.  And to some extent there is an issue about relative positioning of horses and carriages here, that there needs to be clarity about future development trajectories in order to drive forward considerations of the water industry’s infrastructure whether that’s in terms of supply of infrastructure or in terms of provision of funding through the price control formula for the water industry.  That cannot operate on the basis of a set of hypotheticals. 


At the same time, you are absolutely right that there needs to be iteration back to the development trajectory to reflect realities in terms of the water industry.  What I’m suggesting by way of process is clearly imperfect, but I think it is the best I can do at present in order to try and produce an effective iteration.



Thank you.  I’m acutely aware that we have to wrap things up for tonight come what may because there are other users needing to use the building tonight.  We’ve overstayed our welcome by half an hour already.  Is there a brief comment by way of finishing off Mr. Burchell you’d like to make, otherwise those who are here tomorrow for our resumption in 8H2 overlap…….DISCUSSION OF NEEDING TO USE THE RESERVE SESSION ON FRIDAY TO FINISH OFF


EERA                     Mike Burchell

Chairman, hopefully just trying to wind up on the issue we’ve been discussing.  I mean I think you’ve been getting the impression that there’s been no dialogue going on between EERA and the water and waste water industry.  That has clearly not been the case, and we have various iterations in the process to date, had exchanges of view and whilst we have been given the clear impression that the development strategy that is being proposed is a challenging target, none the less, we’ve not been given any impression that it is prohibitively a problem.  And clearly in relation to water supply, we’ve previously discussed at some length efficiency targets and we’re fully behind that. 


We realize that new resources need to come on stream, and we appreciate that there is a different planning cycle that’s needed at OFWAT, and as Mr. Dowie has said, to some degree they need some certainty from us about what they have to do before they can get into that cycle.  But again our questions to the water industry about whether there’s in a sense, a preferred way of couching the spatial strategy that would make their job easier or not, we haven’t had that impression from them.  They’re in a sense willing to deal with the strategy as we put it on the table. 


And we’ve been acutely aware of some of the limitations of dealing with waste water, and that has been a subject of some discussion about, in the Stevenage context.  Again we have been given the impression that there are ways of dealing with that, either by a new facility or by managing the way in which they’d handle the water through existing, through networks in dealing with that problem.  Again we are aware that that needs to feed in on a planning cycle in order to deal with any new facility that’s required to take the pressure off Rye Mead.


So with that background Chairman, it does seem to me that it doesn’t actually, whilst there are clearly challenges in all of that that need to be brought on mind, and it clearly affects the phasing issue of when development comes forward, it doesn’t fundamentally undermine the strategy that we’ve been discussing today.



Thank you.  Close of session




EERA              East of England Regional Assembly

EA                   Environment Agency

GO-East          Government Office for the East of England

TVW                Three Valleys Water

TW                  Thames Water

STW                Sewage treatment works

RPG                Regional Planning Guidance

RSS                Regional Spatial Strategy




Coming next

7-10 February, there is no sitting of the EiP.

Next week, 14-17 February, the EiP will hear discussions about Stansted and also about the London-Peterborough 'growth area', which CPRE has been campaigning hard on. You can read more on our website: http://www.cpre.org.uk/campaigns/planning/sustainable-communities/index.htm

And please note: Stop Harlow North is organising a public demonstration of support for the Green Belt around Harlow, which is under threat from these growth area plans. If you can, please attend the public demonstration, which is at 9am on 14 February. More details can be found on the group's website: www.stopharlownorth.com