A couple of weeks ago, a consultation was quietly started on the Strategic Environmental Assessment (SEA) of the revocation of the South East Plan. Enough to send most people off in a stupor before they’ve finished the headline!
Current Government policy is to simplify planning by stripping away regional governance and plans, and by the introduction of the National Planning Policy Framework (NPPF). Therefore this is just another step along that path. Given it is going to happen, does it matter? Will it make any difference?
These are the questions that the SEA is looking to assess, to see whether the Plan should be revoked in total or whether particular policies should be kept in place, even if only temporarily.
The South Downs are in an odd position as when the South East Plan was written the area was not yet confirmed as a National Park and so did not have a proper policy as the New Forest did. Instead it was covered by the policy on Areas of Outstanding Natural Beauty (AONB). However, since the AONB policy no longer applies to the South Downs, it now being a National Park, it is harder to make a case that it would be any better or worse off with or without the South East Plan.
Where there might be concern about the loss of the South East Plan is in the New Forest and the remaining 9 AONBs in the South East. Here the Plan was strong on the concept of ‘conserving and enhancing’ these landscapes and on ‘having regard to their setting’, the latter an important point picked out by the Inspector as justification for having regional policies on nationally important landscapes.
The critical test is whether these policies are covered by the NPPF. This does indeed have policies on landscape and specific mention of National Parks and AONBs. While it does talk of ‘conserving and enhancing’ and ‘protecting and enhancing’ ‘valued landscapes’ in paras 109 and 156, in para 115 when it talks of nationally important landscapes it only talks of ‘conserving’ them; ‘enhancement’ is not mentioned. Therefore there is a certain ambiguity as to whether ‘enhancement’ of National Parks and AONBs still has the same priority under the NPPF as under the South East Plan.
In addition, there is no mention of the importance of the setting of nationally designated landscapes. The only time setting is considered important is for heritage assets. Therefore, this would suggest that the region’s nationally important landscapes would be worse off without the South East Plan.
While the SEA does pick up a minor policy difference between the mean low water mark and mean high water mark for AONBs, it is silent on these other issues. This is of concern and hopefully people will respond to the consultation if only to make this point. As to whether it will be noticed or not will depend on development pressures around the edges of our nationally important landscapes and the weight given to protecting the environment. Only time will tell…
The consultation ends on Thursday 6 December, 2012. You can send comments to:
Post: Environmental Assessment Team, Department of Communities and Local Government, Zone 1/J6, Eland House, Bressenden Place, London, SW1E 5DU