Eco-Town submission
1. Introduction
In July 2007, the Government published a prospectus outlining its intention to build up to ten ‘eco-towns' as its response to the twin challenges of climate change and housing shortages.
In response to its invitation, the Government received 57 bids for eco-towns. In April 2008, the Government published a shortlist of 15 sites to proceed to the next stage in the process. It is anticipated that the shortlist will be reduced to 10 sites sometime later this year or early next year.
The Government has indicated that it wants to build five eco-towns by 2016 and ‘up to five' more by 2020. It is intended that these will be ‘zero carbon' developments of 5-20,000 houses, with 30 to 50 per cent of the homes to be ‘affordable'. The Government hopes that construction work will begin in 2010.
One of the 15 locations shortlisted is Ford in West Sussex, the site of a former airfield operated until 1959 by the Fleet Air Arm. The runways remain and most of the buildings and hangars have been removed or converted to light industrial use. Today, most of the Ford Airfield site is used for agriculture.
The two constituencies most affected by the eco-town proposals at Ford are Arundel and South Downs, which includes the villages of Ford and Yapton; and Bognor Regis and Littlehampton, which includes the village of Climping. An eco-town will swallow up the rural villages of Ford, Yapton and Climping, but the impact will be felt much further afield.
As the Members of Parliament for Arundel and South Downs (Nick Herbert) and Bognor Regis and Littlehampton (Nick Gibb), we are submitting this formal response to register our strong opposition to the proposals to build an eco-town of 5,000 houses at Ford.
2. Our objections to an eco-town at Ford
2.1 The wrong location
We believe that Ford is the wrong place for 5,000 new houses. The local planning authority, Arun District Council, has already ruled out Ford for large-scale development and rejected previous applications from developers.
In August 2007, the Local Development Framework Sub-Committee of Arun District Council made a series of recommendations on the LDF Core Strategy. Ford was one of the locations judged to be unsuitable for development.
Before these recommendations could be debated by the Full Council, the Panel which had examined the draft South East Plan recommended that the housing allocation for Arun be increased by 2,000, from 9,300 to 11,300. As a result of this, Arun District Council had to delay going to public consultation and revise its proposals to meet these higher numbers.
The most sustainable locations for new development, set out in the draft Regional Spatial Strategy, were urban extensions. We believe that urban extensions would be more environmentally sustainable and provide housing where the local demand exists.
2.2 Destruction of greenfield land
2.2.1 Greenfield land
In its ‘Eco Town Bid' of August 2007, the Ford Airfield Vision Group said: "Ford Airfield is a 360 hectare site comprising brownfield land."
In its publicity material, the Vision Group describes the development as "Ford Airfield Eco-Town", to reinforce the impression that the developers would be making use of brownfield land or what some promoters have described as ‘wasteland'.
The original proposals of Ford Enterprise Hub conveyed the same message. They stated that: "Ford is a very large, previously developed site which should come forward in plans for housing before greenfield sites".
However, figures in the Government's own consultation paper confirm that only 44 hectares of the 350 hectare site is brownfield land - less than 13 per cent of the total.
The same document, published by the Department for Communities and Local Government, says that eco-towns should be sited "where appropriate, making good use of brownfield ... land".
The developers now say that only 30 per cent of the site consists of brownfield land. This is based on the Government's definition of brownfield land, which allows for the curtilage of an airfield to be included. It does not take into account the fact that much of the former airfield's curtilage is prime, Grade 1 agricultural land. A tiny percentage of the site, around 4 per cent, is actually under concrete.
Further confusion has been created by the way in which the figures have been presented in the Government's consultation document, in which the DCLG say: "The 350 hectares site includes 110 acres of brownfield ...." The use of two different measures in this way has, intentionally or not, given the impression that around one-third of the site consists of brownfield land.
2.2.2 The rural character of Ford
At the Arun Local Plan Inquiry, five years ago, it was accepted that 800 new houses would "seriously erode the rural setting of Ford". The eco-town, as we all know, will consist of at least 5,000 houses, completely transforming the area.
Whilst the area does not include ‘green belt' land or areas with special protection such as AONBs or SSSIs, over 87 per cent of the site consists of greenfield land. It links the South Downs with the coastal strip of Sussex and it is one of the last open areas of countryside along the south coast between Portsmouth and Peacehaven.
The beautiful countryside in this part of the Arun Valley adds much to the rural character of the district and makes a valuable contribution to the tourism industry. It is particularly important to tourism in the seaside towns of Bognor Regis and Littlehampton and to the historic town of Arundel. Urbanisation will irrevocably damage the attractiveness of the area.
The developers have indicated that they wish to provide opportunities for residents of the eco-town to engage in food production. This is a laudable aim, but we should remember that the town will be built on high-quality agricultural land. In a period of high food prices and food shortages, in an area where farming and horticulture is important, the most productive agricultural land should not be developed.
2.3 Lack of infrastructure
2.3.1 Overview
A serious deficit in local infrastructure is critical to the debate over the eco-town.
The developers have indicated that "£200 million" will be available to pay for infrastructure. We question whether this will fund the promised infrastructure - which includes a secondary school, two or three primary schools, a relocated railway station, a bridge over the railway, a health centre, arts centre, sports facilities, energy schemes, a contribution towards a new bypass for the A27 and other road improvements, allotments and more besides. We also doubt whether a scheme for 5,000 houses, a significant proportion of which will consist of affordable housing, will generate the sums required.
Our key concerns centre on the need for adequate roads, hospital services, schools and water supplies. These are already under huge strain and 5,000 new houses will make matters worse.
2.3.2 Roads
Arun District Council, Arundel Town Council and West Sussex County Council all agree that any significant development in this area should be subject to the prerequisite that a new bypass is provided on the A27 at Arundel.
In its recent report, the Select Committee appointed by Arun District Council to examine the eco-town proposals concluded:
"...any substantial development of the type proposed must be subject to the prerequisite of a by-pass being provided at Arundel. Although Eco-Towns aim to reduce car use, if unrealistic expectations of reduced car use are not achieved, the implications of establishing an Eco-Town in this location on the road network would be chaotic. In the absence of a firm commitment to a by-pass the Eco Town should not proceed."
Local residents, councils, MPs and the business community have been arguing for decades that a new bypass is needed. It is clear that on existing ‘plans' no bypass will be completed before 2020; indeed there may not be one at all. An additional 5,000 houses would create further congestion on this important strategic route.
Developers have long acknowledged that the A27 bypass is a prerequisite to an eco-town of 5,000 houses, although they recently argued that they should be allowed to build up to 1,000 homes without it. They have claimed that an eco-town would bring forward plans for the bypass.
However, the Eco-Town Challenge Panel has stated emphatically that funding for the Arundel bypass should be abandoned because "it is not consistent with sustainable principles". It suggests that the developers should "examine how to create travel behaviour change".
The proposed eco-town would continue to rely on Ford Road which links the A259 in the south with the A27 in the north. Ford Road is a single carriageway route which is already struggling to cope with the number of HGVs which require access to industrial developments at the southern end, and is a bottleneck at the northern end in Arundel. These problems will worsen next year as the West Sussex Materials Resource Facility (MRF) opens at Ford. Ford may also be the location of a Built Waste Management Facility - land has already been earmarked by the County Council in its draft Minerals and Waste Development Framework document.
We believe that the reduction in car use envisaged for the development is totally unrealistic. At the recent public inquiry conducted by Arun District Council, the developers indicated that they were aiming to limit journeys by car to 25 per cent - at worst 40 per cent. This is unlikely to be achievable in a town sited in the middle of the countryside, away from the established settlements of Bognor Regis and Littlehampton.
West Sussex is a largely rural county. Experience shows that, even in those nearby towns and villages that have a railway station (such as Barnham, Arundel and Pulborough), car dependency is high. Residents who do not own cars, particularly young mothers and the elderly, find themselves severely disadvantaged in a county poorly served by public transport. At the Arun Local Plan Inquiry, five years ago, it was accepted that development at Ford would generate a large volume of additional car traffic. It is unlikely, given the experience elsewhere, that the new railway station will enable residents to travel freely around West Sussex.
There are serious and unanswered questions about how the aim of reducing car ownership to a level completely out of line with equivalent sized settlements in rural West Sussex could possibly be achieved without disadvantaging residents.
2.3.3 Hospital services
On 4 June, the West Sussex Primary Care Trust decided to proceed with the downgrading of St Richard's Hospital in Chichester. The hospital, which serves residents in Arun, will lose its consultant-led maternity unit, inpatient paediatrics and emergency surgery. These services will be centralised at Worthing Hospital and some patients in the west of the district will have to travel further for treatment.
The PCT has assured the local community that the new services will be sustainable, but while local services are being downgraded, the population is increasing. The reconfiguration and centralisation of services is at odds with an increase of 58,000 new houses - quite possibly more - in West Sussex by 2026, and an eco-town could add to this pressure.
2.3.4 Schools
We still do not know what the impact of an eco-town will be on local schools. At the recent public inquiry conducted by Arun District Council, it was unclear as to whether the developers planned to build two primary schools or three; whether 5,000 houses warranted a new secondary school; whether the developers had assessed the capacity of local village schools to take additional pupils, and what investment would be required to create new accommodation.
There was no evidence that developers had assessed whether the expansion of local schools was feasible at all - and what impact the expansion of small village schools would have on educational standards.
2.3.5 Water Supplies
Two summers ago, West Sussex experienced a drought so severe that standpipes were almost introduced. It is far from clear that adequate supplies of water will be available to serve a large, new development at Ford. The Government's own consultation paper concedes that "the existing water abstraction point is currently over-licenced" and "impacts on local watercourses would need to be considered."
2.4 Undermining local democracy
There is an established system for making decisions about where to locate new housing. It is not without its faults, but it is evidence-based, takes account of the views of the public and stakeholders, and is subject to independent scrutiny.
The developers first proposed the site at Ford for housing in 2000, long before the concept of eco-towns was born. The local planning authority, Arun District Council, decided that Ford was not an appropriate location for large-scale development through its Local Development Framework (LDF) process. It is a process that, so far, has cost taxpayers in Arun around £0.5 million and has been hampered by repeated changes to the context in which it has been operating.
It may all be for nothing. At the invitation of the Government to submit proposals for eco-towns, developers resurrected their plans, attached some ‘green' initiatives, and re-badged them as eco-friendly developments. Worse still, the decision-making process for eco-towns is bypassing the local planning system altogether.
The decisions on eco-towns are being made by the Government. The developers responsible for the schemes at Ford submitted their proposals direct to the Government, thereby bypassing Arun District Council as the local planning authority.
A planning policy statement, to be produced later this year, will override any document produced by a local planning authority and the Government has also indicated that the Secretary of State may ‘call-in' an application and apply its powers under the New Towns Act.
It cannot be right that decisions about where new housing will go are made by Ministers and civil servants in Whitehall and not by our locally-elected councils. It subverts the normal planning system and undermines local democracy.
2.5 Lack of local support
The Eco-Town Challenge Panel has said that "evidence of local support for the scheme is needed". It is already clear that there is negligible local support for an eco-town at Ford.
In May and June this year, Arun District Council appointed a cross-party Select Committee to investigate the proposals for an eco-town at Ford. The inquiry heard a range of evidence on the proposals. In its report, which will be considered by the Full Council on 30 June, the Select Committee recommended that:
"...the Council should express its opposition to the Ford Eco-Town Proposals, and urge the Government not to take the proposal forward to the next stage of development."
It is likely that the Council will accept this recommendation.
West Sussex County Council has also voiced its concerns about the eco-town proposals. Councillors have described the plans as "deeply flawed". The Council Leader, Henry Smith, has said: "New settlements and additional housing need careful consideration, and should not be parachuted in."
In a news release issued on 4 April, the Council declared that they were "seriously concerned" about the eco-town proposals. John De Mierre, then Cabinet Member for Strategic Planning, said:
"If the Government believes the proposals for an Eco-Town at Ford deserve consideration, then they should be tested through the proper planning process starting with the Arun Council's Local Development Framework.
"However, the Government has said it will if necessary change the rules regarding planning. If this does indeed happen, they will be overriding the democratic process."
Following a public meeting in Arundel on 19 May, attended by around 200 local residents who heard presentations from Harold Hall of the Ford Enterprise Hub and Communities Against Ford Eco-Town (CAFE), Arundel Town Council pledged their opposition to the eco-town proposals.
The parish councils of Ford, Yapton, Climping, Felpham, Barnham, Middleton-on-Sea and Walberton have also declared their opposition to an eco-town at Ford, as have Littlehampton Town Council.
As local MPs, we have received thousands of letters and e-mails from constituents to tell us that they oppose an eco-town and almost none in favour. A strong, independent grassroots community campaign, Communities Against Ford Ecotown (http://www.nofordecotown.com/) has received overwhelming local support, and we wholly endorse its separate submission to the DCLG. Over 5,000 local residents have signed its petition against the eco-town and 2,000 marched in protest. If the Government drives through an eco-town at Ford, it would be against the express will of local people.
2.6 Housing needs
It is of concern that many people, especially young adults, are unable to get their foot onto the housing ladder. It is common ground that we need to build more homes and that a significant proportion of these should be ‘affordable'.
West Sussex is already being asked to build at least 58,000 houses over the next 20 years and there is concern that the infrastructure will be unable to cope with these numbers.
The Panel Inspector has recommended that 11,300 houses will be built in the Arun district. The numbers have already been increased by 2,000 from the original recommendation of the South East England Regional Assembly.
Arun District Council, in its core strategy document, has already identified and allocated land for 9,500 houses, of which between 30 and 40 per cent will be affordable housing. The Council is therefore making good progress with the supply of affordable housing in the district.
We strongly believe that the elected local authority is in a better position to decide where these houses should be located than the Government.
2.7 ‘Green' housing developments
We agree that houses should be designed in such a way as to limit their impact on the environment. All new houses will, in future, be built to a higher standard, whether or not they form part of an ‘eco-town'. However, houses built in eco-towns up to 2016 will be less environmentally-friendly, at Sustainability Code 3, than all other houses which will be built at Code 6.
If we really want to tackle climate change, we need to focus more of our attention on the millions of houses that have already been built. Many of these homes are inefficient and poorly insulated.
We do need to ensure that new houses are eco-friendly, but the proposed eco-towns will represent a tiny percentage of the 3 million new homes that the Government wants to build by 2020.
Housing developments sited in areas far from work and amenities are not eco-friendly. As a location for large-scale development, Ford has already been rejected by the local planning authority in favour of urban extensions which take advantage of existing employment opportunities, facilities and travel networks. Urban extensions are more sustainable than new towns built in the heart of the countryside.
It is difficult to see how the construction of a new town of 5,000 houses on a greenfield site, consisting largely of prime, Grade 1 agricultural land, could be considered remotely ‘eco-friendly'.
3. Conclusion
Ford is an unsuitable location for an eco-town of 5,000 houses. This is a view shared by local councils, MPs, businesses and residents.
The new town will destroy one of the last open areas of countryside along the south coast between Portsmouth and Peacehaven, irrevocably change the rural character of the district, destroy some of the most productive agricultural land in the county, place even more pressure on local services and infrastructure, deprive Bognor Regis and Littlehampton of much-needed investment and, perhaps most important of all, undermine local democracy.
Developers have been seeking to develop Ford for some time. The eco-town process has merely allowed them to dress up their proposals and subvert the decision of the local planning authority by applying directly to central government.
As the local Members of Parliament representing the areas that would be directly affected by an eco-town at Ford, we are strongly opposed to the development and urge the Department for Communities and Local Government to omit this site from their final shortlist.