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1. – Is the analysis in the 'where are we now' section accurate and complete? If not, what evidence supports your view?

We have general misgivings about this section, which argues that the credit crunch has moved or will move the Region off-course to attain the targets of the East of England Plan, and that therefore action is needed to bring the region back on course to its targets (the “Filling the Gap” concept of the EEIP Executive Summary, pages 5 – 7). The underlying logic is flawed. To the extent that the credit crunch represents the normal business cycle, and that the Plan took account of the normal business cycle, the position will be recovered as the economy recovers. To the extent the credit crunch involves a set back more than the usual business cycle, it is appropriate to review the targets.

We question the value of attempting to apply to this sort of plan the quality control logic, of specifying a target trajectory, monitoring deviations from that trajectory, and acting to bring actual in line with plan, all in quantitative terms. In principle, if the Region was doing better than the planned trajectory, would the Implementation Plan be proposing to do less than planned, to bring actual in line with plan? In practice, how can one tell whether the plan represented a realistic projection taking account of the business cycle, or one assuming the continuance of unsustainable boom conditions? And the novelty of this type of initiative suggests it is better to focus on whether the implementation actions are taking place, than on how their outcome will stack up against targets.


2. – Do you think the categorisation of the current themes and sub-regional priorities adequately captures the ambitions of the regional economic and spatial strategies?

The categorisation by theme/sub-region risks overlooking the significance of certain strategic issues. One that stands out is control of the location of development in the context of climate change.

Control of the location of development is the essence of spatial planning. It is also critical to addressing climate change: we strongly endorse the Overall Spatial Vision of the East of England Plan where it puts as Objective (i), 1st bullet, “locating development so as to reduce the need to travel”.

This insight seems to have been lost in the EEIP. In the greenhouse gas entry in the Filling the Gap table of the EEIP Executive Summary, page 6, no mention is made of controlling the location of development. The supporting document Climate Change Plan makes no reference to spatial planning as a contributor.

This is a very serious omission. Spatial planning is to a large extent under the control of government, unlike much of what the East of England Climate Change Plan lists. Locating development so as to reduce the need to travel helps reduce the investment required in infrastructure, and such investment is an important resource constraint on development.

Locating development so as to reduce the need to travel is a cross-cutting theme. It affects every type of development: housing, transport, employment, education, leisure.

3a. – Housing Does the theme and its programmes capture the ambition for the region and scale of the challenge? If not, what changes would you suggest and what evidence supports these changes?

The change we suggest is to make climate change, and hence locating development so as to reduce the need to travel, central to this theme.

3b. – Housing Is there other existing or planned work we should include that will significantly deliver the headline targets and ambitions of the RES and RSS?

The current approach of allocating the Regional and sub-Regional housing targets to Districts, and then towns and villages within Districts, is counter-productive. Concentrating housing (and other) development at major centres not only fulfils Objective (i), 1st bullet, of the Overall Spatial Vision of the East of England Plan (“locating development so as to reduce the need to travel”), but also is likely to reduce the capital required.

3c. – Housing Are there programmes that you would prioritise or remove? What are your reasons for this?

We would remove, downgrade or radically recast the programme of Affordable housing in rural areas (EEIP, Table 12, page 35). This problem is often exaggerated. Most young people positively want to move away from home and to the bright lights (and the jobs). If the young in question have jobs, it would be absurd, and contrary to Policy SS2 of the East of England Plan, to build social housing in villages so they can commute to jobs in towns. If they don’t have jobs, it would be even more absurd to build social housing in villages so they can sit around in a place with low prospects of them finding jobs. The only case for such provision is where those concerned have stable but inherently low-paying jobs in the village. But this is justifiable only if there is an effective means of confining such housing to those actually doing such jobs. This will be regarded as harsh, but if our society is to respond to climate change, it is necessary to challenge the idea that people have an entitlement to subsidised housing wherever they would wish to live ("subsidised", because there is a cost to requiring developers to provide X% of dwellings as "affordable").

4a. – Transport Does the theme and its programmes capture the ambition for the region and scale of the challenge? If not, what changes would you suggest and what evidence supports these changes?

No comment.

4b. – Transport Is there other existing or planned work we should include that will significantly deliver the headline targets and ambitions of the RES and RSS?

The programmes focus too much on investment to meet demand. The theme chapter does not refer to control of location of development as a means of reducing demand for transport while not harming economic growth, and while contributing to climate change objectives (and possibly others, from health to social cohesion)
The programmes make no reference to the implications of transport for the Environmental aspects of the RSS eg ENV1, ENV2, ENV6. These are significant not only for the amenity and bio-diversity agendas, but also for climate change (see above) and the types of up-market tourism that offer rural economic development in sensitive areas without jeopardising the attributes of those areas that make them attractive.

Also see comment under Utilities on high-speed broadband.

4c. – Transport Are there programmes that you would prioritise or remove? What are your reasons for this?

The programme on Improving Access to Key Services in Rural Areas needs to be even blunter about the drawbacks of conventional public transport in rural areas, and more concrete and urgent about investing in research, experiment and innovation in this field.

5a. – Utilities Does the theme and its programmes capture the ambition for the region and scale of the challenge? If not, what changes would you suggest and what evidence supports these changes?

No comment

5b. – Utilities Is there other existing or planned work we should include that will significantly deliver the headline targets and ambitions of the RES and RSS?

Effort should be put into developing radio-based high speed broadband for rural areas. It has potential for cost saving, by avoiding lengthy cabling; for amenity, by enabling overhead telephone wires to be dispensed with; for environment-friendly job creation in rural areas; and for social inclusion, by accelerating the provision of modern communication facilities. It is generally accepted that it will be necessary to achieve government objectives for high-speed broadband access in very remote areas such the Scottish Highlands and Islands, but its potential for English rural areas seems to have been overlooked. See Policy T7 of the East of England Plan.

5c. – Utilities Are there programmes that you would prioritise or remove? What are your reasons for this?

No comment

6a. – Enterprise, Business Support and Innovation Does the theme and its programmes capture the ambition for the region and scale of the challenge? If not, what changes would you suggest and what evidence supports these changes?

No comment

6b. – Enterprise, Business Support and Innovation Is there other existing or planned work we should include that will significantly deliver the headline targets and ambitions of the RES and RSS?

No comment

6c. – Enterprise, Business Support and Innovation Are there programmes that you would prioritise or remove? What are your reasons for this?

No comment

7a. – Skills and Employability Does the theme and its programmes capture the ambition for the region and scale of the challenge? If not, what changes would you suggest and what evidence supports these changes?

No comment

7b. – Skills and Employability Is there other existing or planned work we should include that will significantly deliver the headline targets and ambitions of the RES and RSS?

No comment

7c. – Skills and Employability Are there programmes that you would prioritise or remove? What are your reasons for this?

No comment

8a. – Culture, Creativity and the Visitor Economy Does the theme and its programmes capture the ambition for the region and scale of the challenge? If not, what changes would you suggest and what evidence supports these changes?

No comment

8b. – Culture, Creativity and the Visitor Economy Is there other existing or planned work we should include that will significantly deliver the headline targets and ambitions of the RES and RSS?

Under Table 65 support should be given to the proposal to seek World Heritage Site status for the Dedham Vale & Stour Valley AONB. Under Table 63, reference should be made to the "Managing a Masterpiece" programme for the Dedham Vale & Stour Valley , and consideration should be given to extending it, in scope, time and to other such areas. Both of these are significant as examples of what can be done to promote the appropriate development of sensitive rural areas, and of what can be done to promote cultural assets without massive bricks-and-mortar investments.

8c. – Culture, Creativity and the Visitor Economy Are there programmes that you would prioritise or remove? What are your reasons for this?

No comment

9a. – Green Infrastructure, Landscape, Heritage, Flood Risk and Coastal Environments Does the theme and its programmes capture the ambition for the region and scale of the challenge? If not, what changes would you suggest and what evidence supports these changes?

Green Infrastructure is defined in the EEIP Glossary as wildlife corridors with recreational uses. But in the main document it is used generally to refer to any infrastructure with a sustainability angle. See eg EEIP, Table 1, right-most column.

Table 70 does not sufficiently recognise the importance, for better or worse, of actions under other themes for this theme's objectives. Specific points are made elsewhere in these comments. A similar point may well apply to other Tables under this theme.


9b. – Green Infrastructure, Landscape, Heritage, Flood Risk and Coastal Environments Is there other existing or planned work we should include that will significantly deliver the headline targets and ambitions of the RES and RSS?

See comments under 8b above.

9c. – Green Infrastructure, Landscape, Heritage, Flood Risk and Coastal Environments Are there programmes that you would prioritise or remove? What are your reasons for this?

Table 70 puts forward as a “key component” “investment in a limited portfolio of major new large scale projects . . .”

We note that EEDA have used the Regional Economic Strategy to justify supporting the Horkesley Park application on the grounds of new jobs, many visitors etc., and presumably envisage that project as the sort of thing intended by that “key component”. This is deeply worrying. Many of the Region’s significant landscapes are fragile, liable to be ruined by mass tourism of the Horkesley Park type, and the Dedham Vale AONB immediately adjacent to the Horkesley Park site is one such. Such cultural/environmental projects need to be considered in more than a narrowly economic context. We have in mind Policies C2 and ENV6 of the East of England Plan. There are considerable doubts about the business plan for that project, but even taking it at face value, the proposed site is wholly inappropriate: a site adjacent to the A12 and Colchester would be better on a range of grounds. This programme needs to be regarded with some scepticism and applied, if at all, with great care and discrimination.

10. – Are there any other programmes outside the themes that might be needed to successfully deliver the two regional strategies?

We emphasise again the need to control the location of development in the light of climate change: in essence, all development with choice of location should be in a major urban centre, by a trunk road junction or alongside a railway main line.

11a. – How do we get there? - by place Do the sub-regional priorities capture the ambition for the region and scale of the challenge? If not, what changes would you suggest and what evidence supports these changes?

We are concerned about the geographical extent of the Haven Gateway sub-Region. We recognise the logic of identifying Ipswich/Felixstowe/Colchester/Harwich and their associated transport corridors, A12, A120 & A14 and the main railway lines, as a development pole (“core Haven Gateway”). We note that 13.28 of the East of England Plan says that the geographical extent of the Gateway is to be agreed for these purposes, and that the boundaries shown in the Regional Key Diagram differ from those in Figure 3 for housing purposes. We note that the whole of the Dedham Vale AONB and much of the Suffolk Coasts and Heaths AONB is put within Haven Gateway. We contend this is mistaken. The large-scale economic opportunities associated with core Haven Gateway do not apply to the AONBs. None of the sub-regional priorities proposed in the EEIP apply to the AONBs except for the Aldeburgh/Snape development is which is now virtually complete. The planning issues which apply to the AONBs are quite different from those which apply to core Haven Gateway. There is overlap and possible conflict in terms of the Stour and Orwell estuaries’ littoral. But this does not justify extending the sub-region to the inland rural areas. See comment on 10 above.

11b. – How do we get there? - by place Is there other existing or planned work we should include that will significantly deliver the headline targets and ambitions of the RES and RSS?

No comment

11c. – How do we get there? - by place Are there priorities that you would prioritise or remove? What are your reasons for this?

No comment

12. – Do you have any comments about the proposed governance and monitoring mechanisms set out in the implementation plan?

No comment

13. – Do you have any views on the presentation of the final implementation plan in terms of its length, structure or design?

No comment

14. – Do you have any comments on the Climate Change Action Plan document?

It is frankly disappointing. Particularly given the salience of climate change considerations in the East of England Plan - Overall spatial Vision, Objective 1 - and the importance of regional planning and implementation to meaningful action to mitigate climate change.

The first three and a half pages are waffle about "We have a problem". This could usefully be condensed to about half a page. The next one and a half pages are waffle about "We have objectives to address the problem". Then half a page of gestures towards actions to reduce emissions. And so it goes on. It really is not an Action Plan. It mentions a few actions that have been or are to be taken, but avoiding specifying the connection if any with the East of England Plan and its implementation offshoot. It elides encouraging bio-diversity and mitigating climate change. It makes no reference to control of location of development as a means of addressing climate change. It makes no reference to utilities and sustainable energy production. There are no statements of the form "We shall do . . ." or "X needs to be done but there as yet no plans to do it". There is no quantification of Regional greenhouse gas emissions or their sources, still less any quantification of the sources of the reductions aspired to.

It is green-wash.

Submitted via EEDA website 3 July 2009