The South East Plan - "A Clear Vision for the South East"

To: The Secretariat, SEERA, Berkeley House, Cross Lanes, Guildford GU1 1UN This representation is made on behalf of the Sussex Wildlife Trust. The SWT is a charity founded in 1961 concerned with a broad range of issues centred on people and wildlife. We are a medium size business, turning over of about £1.5m per annum, and we own and manage an estate in excess of 1,500ha. The Trust is a membership organisation with over 16,000 members. We are part of the partnership of 47 Wildlife Trusts throughout the UK who collectively comprise the Royal Society of Wildlife Trusts (RSWT).

The South East Plan has been prepared to a tight deadline yet this is an important, 20 year, statutory document. It is questionable that the preparation of the plan has allowed adequate time for a proper consideration of the issues that are likely to drive changes over the next 20 years. In general, although it may have good principles and some valuable individual polices, the overall plan has not made sufficient moves in the direction of environmental sustainability.

The plan is strongly development led, giving an overall presumption in favour of more housing, more business development and more infrastructure. Sustainable development should be the guiding theme running through the whole document, yet it is dominated by socio-economic gains balanced against environmental loss. Little attention is given to the true environmental cost of development on this scale. The bigger picture, promoted through this plan, is one of continuing unsustainable practice at a global level.

A more detailed response on the policies is given below, but the SWT has major concerns in the following areas of general principle:

Resource use

It is difficult to see how the policies in the plan will contribute the cross-cutting theme of reduced resource use. The SEEDA document entitled "taking stock" shows that our ecological footprint is 29 times the physical area of the region and if everyone on earth used resources as we do then we would require 3.5 planets. This is an unsustainable situation and can not last for 20 years. The magnitude of the changes needed requires a fundamental look at the functioning of the economic system of the south-east.

Economic growth

The current economy of the South East is growing at around 3% GVA per annum, but it is a false assumption to presume that this level of growth must continue for the South East to flourish. This starting point compromises all other principles in the plan. This principle should be reversed. The plan should set out its objectives and then it should be for the economic system to be a means of delivering them. It is likely that a sustainable economic system will have to turn towards a low resource-use, efficient, environmentally and socially beneficial system that may or may not provide 3% growth.

Water use

The plan sets development levels and then requires the water industry to provide the water. Policies for water efficiency and infrastructure development do not counteract this underlying approach. The plan is built on the presumption of massive infrastructure development. Even this is probably an under-estimate as figures for the water that can be saved from efficiency measures are over-optimistic. This is not sustainable development. The correct approach would be for development to be conditional on water availability and for the provision of water to be conditional on the environmental acceptability of resource exploitation. Water is a finite resource yet the Plan is built on the principle of increasing exploitation. The short term results of this are loss of wildlife habitat, short term availability problems and water quality issues, the long term effects will be ongoing physical shortages, severe economic consequences and disruption of the hydrological cycle.

Sustainability

The approach to water exposes a more general problem. The Plan often recognises environmental or resource problems but makes the assumption that these can be overcome by increased investment. Thus, even though the plan sometimes states that we can not build our way out of the problem, it is still implied that more investment is the answer. However careful the investment, or advanced the technology, there are still physical and environmental problems with lack of space for transport, absolute lack of water, lack of holes in the ground for waste residue and so on. The plan does not address the basic issue of how to deliver continued wealth creation whilst at the same time reducing resource use and delivering social and environmental gain.

Energy use

Energy use is not sufficiently highlighted as an issue. Policies on renewable sources are welcomed, however, in the 20 year period of the plan it is likely that there will be major energy crises (demand for oil might exceed supply, natural gas provision may be vulnerable to political instability elsewhere etc). The plan does little to promote a robust alternative to our current insecure reliance on unsustainable energy resources. Far more is needed on renewable alternatives and improved efficiency.

Climate change

The highlighting of climate change is welcomed, but the plan fails to grasp the implications. The general prediction of warmer summers and wetter winters hides a great deal of unpredictability. This could result in global instability in a variety of areas, any one of which could have major implications for the environment and economy of the south east.

Biodiversity

Biodiversity is still on a long-term downward trend. The commitment to reverse this is poor. There may be good individual policies in Section D5 but it is questionable how well these would fair against the many contradictory policies promoting economic growth, development and house building. Even good policies are weakened by qualifying statements such as " avoid net loss", or "avoiding wherever possible " rather than a straightforward policy to prevent loss.

Ecosystem services

As well as being an issue in its own right, biodiversity has links to the provision of ecosystem services (such as water quality, flood defence, prevention of soil erosion, equitable climate etc) and hence to long term survivability. Biodiversity is an important element in maintaining a functioning environment, and is a key indicator of success so there should be more of a lead to maintaining a healthy, functioning environment in the south east. This should embody concepts such as large-scale habitat restoration, strategic areas for biodiversity improvement and the building of a well-linked ecological network.

The SWT therefore considers that the SE Plan is a large, important, statutory document that has spent too little time addressing some of the most important issues in the region. Huge areas need further work (see summary at the introduction) and it is unlikely that this will be achieved in advance of final adoption. It is therefore strongly recommended that a review of the plan be started immediately.

For tables detailing the Sussex Wildlife Trusts comments on specific policies in the South East Plan please click here (pdf, 85kb). This link will open in a new window.

I hope these comments are helpful. If you have any queries please do not hesitate to contact me.

Yours truly

Dr A Whitbread