Proposal for an Eco-town at Ford

 

 

 

The Government’s initial summary of the main issues identified for the site at Ford

 

Description

 

The 350 hectares site includes 110 acres of brownfield and a former airfield site close to Ford open prison and is served by rail to London and the Sussex coast route.

 

Proposed benefits

 

There are two proposals for this site – a strategic development area delivering 5,000 homes (40%) affordable; a 30 hectare economic hub; a major contribution towards the provision of necessary local infrastructure; site specific energy solutions utilising local resources (including major recycling facility); and relocated railway station and improved services to assist the regeneration of the Sussex coast.

 

Housing Affordability Pressure – Very High. Scheme would deliver around 1,500 affordable housing units in comparison with current delivery of 46 and 15 annually in 2005/06 and 2006/07 respectively in Arun. Current households on housing waiting list – 3,880.

 

Initial summary of challenges and constraints

 

Environment – The site includes areas in all 3 flood zones so built development will need to focus on Zone 1 and there will be a requirement for Flood Risk Assessment and application of the sequential test. The existing water abstraction point is currently ‘over-licenced’. Development phasing would be important. Potential impacts on local watercourses would need to be considered. Land contamination and possible impacts on groundwater would need to be assessed. Associated road infrastructure could impact on BAP habitats.

 

Transport – The site would need to make good use of rail but the major issue is the relationship of the site to pressures on nearby trunk roads and particularly the A27. A robust programme of sustainable transport solutions will be required to minimise the impact of the development on both local and strategic road network.

 

Employment – The site could generate significant employment through a science and technology park alongside existing uses including Ford open prison.

 

Conservation and historic constraints – The site masterplan and approach to design will need to take account of major conservation features in the surrounding area including the river arun, the South Downs, listed buildings and historic settlements nearby.

 

 

Letter to Margaret Beckett MP

 

YAPTON PARISH COUNCIL

FORD ECO-TOWN

RESPONSE TO 2ND ROUND OF CONSULTATION

 

 

 

The Rt Hon Margaret Beckett MP

Minister for Housing and Planning

Communities and Local Government

Eland House

Bressenden Place

LONDON SW1E 5DU

 

 

28 April 2009

 

 

Dear Mrs Beckett

 

2nd Stage of Eco Towns Consultation

 

The Parish Council is grateful to have this opportunity of responding to the 2nd stage of the consultation exercise taking place on the Government’s proposed eco-town programme.   Although Council members do not have the professional expertise to address in detail some of the technical issues involved, we do nonetheless represent the grass roots community and in our submission, as a quality council, have striven therefore to address the local concerns.   We trust therefore you will find time to read this letter personally.

 

In essence, the Parish Council in Yapton, representing as it does all residents in the largest of the three villages directly affected by the development, has very strong misgivings about the proposal for an eco-town at Ford.  Mass urbanisation on this scale with its density of design should not be imposed on rural communities.  People nowadays desire more, not less space.  The incidence of crime and anti-social behaviour is recognised as often being in proportion to the environmental background of the individuals concerned.  The Parish Council believes the location of an eco town at Ford is unsustainable for the following reasons:-

 

1)       It will cause the destruction of currently productive grade one, high quality, agricultural land to provide 70% of the land for construction of the proposed new town at Ford giving this scheme no eco-credibility. In the current financial climate this land should remain in use for the production of crops thus contributing to a reduction in imported food produce and the balance of payments.

 

2)       The villages of Clymping, Ford and Yapton would become part of a major urban conurbation losing their individual identities.

 

3)   The proposed site for the new town is in an area that has a high risk of flooding.

 

4)  Affordable housing should be built in or close to existing urban areas where there is a greater need. Many people living in such accommodation have family links in the towns of Littlehampton and Bognor Regis and it would not be sensible to move them from these areas. Such housing would be more sustainable as part of an urban extension of these two towns where infrastructure is already in place.

 

5) Self sufficiency in energy provision is commendable but not if in so doing waste has to be imported from other parts of West Sussex.  The associated HGV movements will be detrimental to inhabitants located adjacent to the routes used by these vehicles and will lead to significant congestion and pollution throughout the County.

 

6) The location of a new town at Ford would seriously affect plans to regenerate the towns of Bognor Regis and Littlehampton.

 

7) Previous studies have stressed that the A27 Arundel bypass must be in place before any further major development takes place in the area.

 

8) The present local road network suffers greatly from overcrowding and there are no plans to provide any improvements that will ease the current congestion.

 

9) The proposal to provide a link road between the A27 and the A259 will locate a major road through the middle of the proposed new town. Apart from obvious safety concerns this would seem to be in contradiction of the eco ethos of reducing private vehicle use. This will also have a major impact of the Ford Road at Arundel.

 

10) There are few diversionary routes available when incidents occur or there is disruption due to routine maintenance/renewal work of the road infrastructure by public utilities taking place.

 

11) The closure of Ford Lane as part of the new town proposal will increase vehicle movements on other local roads and in particular HGV movements through Clymping, Ford and Yapton which is totally unacceptable.

 

12) Timekeeping of bus services is greatly affected by traffic congestion of the local road network in peak times of travel. These services are therefore unattractive as an alternative travel option due to protracted journey times and unreliability resulting from the congestion in peak travel hours.

 

13) Whilst there is a station near the proposed site at Ford, coastal services are slow, subject to overcrowding in peak travel hours and are therefore also unattractive as an alternative travel option. Trains are formed of three or four coaches and Southern, the present franchisee, has confirmed there is no spare rolling stock to increase the current train formations and capacity.

 

14) The proposal to provide four thousand jobs at Ford is questionable with no clear evidence as to how this will be achieved. Should employment be provided this will also have a significant impact on the local economies of Bognor Regis and Littlehampton.

 

15) It would seriously impact on many species of wildlife which presently inhabit the area.

 

16) The new town would severely harm the landscape and character of the lower Arun valley.

 

17) The new town would have a detrimental affect on views both to and from the new South Downs National park.

 

  18) There is overwhelming local opposition to this proposal.

 

The Parish Council whilst supporting the general principle that all future house building should be eco-friendly believes for the reasons set out that an eco-town at Ford is unsustainable and the scheme should not be further advanced. A more sustainable proposal for providing additional homes in the district should be sought which is acceptable to the local communities in the area.  Those whose lives will be most affected should have a greater say in major plans affecting their future and their views should be respected.

 

In the Council’s opinion the existing planning procedures provide the best and proper way forward.  These ensure that the views of the local electorate are fully taken into account by locally elected and democratically accountable district councillors before difficult and far reaching decisions are made on the location of any large scale house building within the district.

 

Accompanying this letter are the Parish Council’s separate responses to the following documents:-

 

 

ENCLOSURE 1

 

RESPONSE TO:-

 

A) THE DRAFT PLANNING POLICY STATEMENT: ECO-TOWNS – CONSULTATION

 

B) ECO TOWNS SUSTAINABILITY APPRAISAL AND HABITATS REGULATIONS ASSESSMENT OF THE ECO-TOWN PROGRAMME: FORD

 

Q1. A prior review should be undertaken by an Independent Planning Inspector to make the process fair to all affected parties. A PPS should not identify proposed individual sites as this could influence subsequent planning applications. Reference to the "approved" list of eco towns should be removed.

 

Q2. The locational principles appear to apply to already selected locations. This gives locations some credence as being suitable for the purpose of an eco town which is very misleading.

 

Q3. These standards are likely to be mandatory from 2016 for all development proposals.

 

ECO TOWN STANDARDS

 

Q4.1 Any planning application will be a formality as the location has been selected without the benefit of the democratic process. These standards are likely to be mandatory from 2016 for all proposals for housing development.

 

Q4.2 The cost of providing eco housing units with related infrastructure may be too high for individuals unless properties are subsidised.

 

Q4.3 A locally generated energy production facility should be specified and included in the PPS. It is important to stipulate the development of brownfield land first and this should be used in the first construction phase of any mixed land development site.

 

Q4.4 Whilst all standards indicated are essential some require greater clarity.

 

Q4.5 ZERO CARBON

Why have cars, vans and HGVs been excluded from this section? A process is required for monitoring the standard to see it is being achieved.

 

Q4.6 CLIMATE CHANGE ADAPTION

The standard needs to be higher than existing planning guidelines.

 

Q4.7 HOMES

A locally generated energy production facility should be specified and included in the PPS.

Cars, vans and HGVs need to be included with a process for monitoring the standard to see that it is being achieved. On site energy generation should be to a separate and far more rigid standard.

 

Q4.8 EMPLOYMENT

Employment requires co-ordination so that local job opportunities are synchronised with completion of housing. Any delay will make it essential for residents to seek employment elsewhere thus leading to an increase in vehicle movements for those needing to travel. Any journeys in excess of one mile are likely to encourage use of cars. A good selection of jobs needs to be provided to suit all the different skills likely to be available from new residents. Will this be realistic in such a small employment area. Longer distance commuting to centres such as Portsmouth, Southampton , Croydon and London should be by exception and therefore discouraged if the principal of an eco town is to be observed.

 

Q4.9 TRANSPORT

Suitable transport must be available to coincide with occupation of the first properties if residents are to be encouraged to use public transport instead of their own cars. This is extremely important to the success of any similar development. Both bus and rail services must be attractive and dependable if residents are to be confident of using them for their regular transport journeys.

 

Q4.10 LOCAL SERVICES

A minimum level of local services required needs to be laid down. Such services should not abstract from similar services provided elsewhere in the local area.

 

Q4.11 GREEN INFRASTRUCTURE AND BIODIVERSITY

Green areas must be of a high quality and varied to discourage inhabitants travelling to other nearby local recreational areas which will have an impact on their present qualities if used in excess. It will also increase traffic flows to the detriment of the area.

 

Q4.12 WATER AND FLOOD RISK MANAGEMENT

Water neutrality and efficiency should be defined by clearly defined standards. The standards for water and flood risk management need to be clearly identified and enforceable. New towns should not be built where there is any risk of flooding unless steps are taken to eliminate such risk. We must learn from previous incidents of flooding around the country.

 

Q4.13 WASTE

Waste storage must be made as simple as possible to encourage residents to segregate their waste correctly. In these new towns higher standards must be achieved as an example for other locations to follow. Such standards can be incorporated from first occupation of homes and will not have to be introduced as a change to existing waste disposal arrangement which would normally meet with limited initial success while people adapt. These are fundamental to the foundation of any new town.

 

Q4.14 TRANSITION AND DEVELOPMENT

This is an important standard for the construction of any new development particularly for the first inhabitants who will have to endure the remaining construction phases. There needs to be a trade off between the developer who is looking to maximise profit margins and the well being of those who live within the new town whilst it is under construction. It is an important habit forming phase which will contribute greatly to the success of the new town if handled correctly. Policies should be in place to support the transition and development phases.

 

Q4.15 COMMUNITY AND GOVERNENCE

Simplicity will be key to the success of any governing body selected from the local community. There wIll also need to be a good cross section of inhabitants involved in running the community to ensure that all views are taken into consideration. Careful thought will need to be given to how this can be achieved successfully. County, District and Parish Council responsibilities should be used as a basis when setting up such bodies.

 

* * * * * * *

 

SUSTAINABILITY APPRAISAL, HABITATS REGULATIONS ASSESSMENT AND IMPACT ASSESSMENT

 

Q5 The SA/HRA needs to make some comparison with other forms of development to test the efficiency of the proposal. Better informed detail is required in any further Sustainability Appraisals produced prior to issue of the final Planning Policy Statement. Existing planning policies and guidance will already achieve most of the standards proposed in the document. Proposed Government revisions to existing Building regulations if adopted, are likely set a higher standard than those proposed for these new towns.

 

Q6.5 NEW TOWN LOCATION

Table three requires careful revision to remove all inaccuracies and reflect correctly the weaknesses identified in location of a new town at Ford. At present it highlights only comments which heavily favour the construction of the new town. It is misleading and does not provide a well balanced reflection of all known factors which have so far been identified.

 

* * * * * * *

 

OVERALL CONCLUSION

 

The Parish Council asks that its comments are given due consideration prior to any decision being taken on location of the new towns. It also reiterates its view that a new town at Ford is unsustainable for a variety of reasons. It believes there are better solutions to housing needs in the Arun District Council area and these are actively being formulated at the present time by the Local Authority.

 

 

ENCLOSURE 2

 

         YAPTON PARISH COUNCIL

 

RESPONSE TO ECO-TOWNS: FINANCIAL VIABILITY STUDY OF THE ECO TOWNS PROGRAMME

 

HOUSING

 

In the summary of the proposed scheme, development for 5,000 homes has been phased over a 20 year period at 340 homes per annum which equates to 6,800 homes, a substantial increase on the original proposal. The figure of 250 homes per annum equates to the original proposal for 5,000 homes. The Parish Council has assumed the figure of 250 homes per annum is therefore correct.

 

TRANSPORT

 

 

 

 

 

QUESTION 1: Do you consider that as a high level strategic assessment this study has identified the main issues affecting viability.

 

 

QUESTION 2: Are there any major areas of cost or infrastructure provision and funding of other issues affecting financial viability which are not identified and could be considered at this stage.

 

 

QUESTION 3: Are you aware of evidence which would lead you to different conclusions to those set out here? For example, where the assessment shows a negative financial outcome are there additional public policy reasons (e.g regeneration or site restoration) which could justify an alternative approach.

 

 

* * * * * * * *

CONCLUSION

 

 

In the Council’s opinion the study should be rejected as ‘unfit for purpose’; it leaves many questions unresolved due to a lack of definite information.

 

 

ENCLOSURE 3

 

YAPTON PARISH COUNCIL

 

RESPONSE TO THE FAVG STRATEGIC TRANSPORT ASSESSMENT REPORT.

 

 

INTRODUCTION

 

In the opinion of the Parish Council the FAVG Strategic Transport Assessment contains many misleading predictions in the two models used by WSP Consultants.

 

THE ECO TOWN EFFECT

 

It is questionable that the statement “People choosing to locate in Ford Airfield Eco town will have made a conscious decision to buy into and adopt the sustainable living ethos that sits at the heart of the eco town philosophy” applies to future inhabitants of the new town. If they are looking for affordable housing they will locate wherever this is available and will give very little, if any consideration to an eco town philosophy. The remaining statements regarding transport are also pure conjecture and there is no evidence to support the views expressed by FAVG. These misleading opening statements set the style for the rest of the report.

 

STRATEGY

 

The transport strategy produce by FAVG does little to encourage residents of the proposed new town with a suitable public transport alternative.

 

MOVEMENT AND ACCESS

 

Whilst FAVG’s aspirations are commendable the likelihood is that they will not be achieved due to the failure to provide good alternative public transport services.

 

MOVEMENT NETWORK – KEY COMPONENTS:

 

 

INTERNAL MOVEMENTS

 

A high frequency community shuttle bus will not be viable with the numbers of people likely to use it encouraging greater use of personal transport.

 

DEMAND MANAGEMENT AND SMARTER CHOICES

 

 

THE STRATEGIC HIGHWAY NETWORK (A27 ARUNDEL BYPASS)

 

 

THE LOCAL HIGHWAY NETWORK

 

The elimination of Ford level crossing and provision of a bridge crossing requires co-ordination with improvements to Ford Road in the Arundel area. Traffic signals are not a suitable long term solution to remove congestion at this location. Other alternatives need to be explored to resolve this significant traffic problem. Restrictions on HGV access for instance and banning on street car parking could be part of a long term solution at this location.  The Highways Agency should not be using the present unsatisfactory situation to limit traffic movements between the A27 and A259 via Church Lane/Ford Road.

 

COASTAL EXPRESSWAY

 

With regard to an upgraded 700 bus service, FAVG have committed themselves to a contribution to the cost of bus priority measures. A realistic assessment needs to be made of all the many schemes/proposals FAVG are prepared to contribute to.

FAVG are unlikely to have sufficient finance available to underwrite all they have committed to. The finance can only be made available from the sales of housing units which will make the cost prohibitive for prospective purchasers. Both the A259 and A27 have their own constraints on traffic flows and these need to be addressed in conjunction with some of the cosmetic proposals suggested for Bognor Regis and Littlehampton which will not resolve any of the major traffic problems that presently exist for bus services. A global strategy needs to be adopted to improve the present busy road network, looking at each route in its entirety, together with other interdependent routes.

 

2.4 REGIONAL POLICY

 

WEST SUSSEX STRUCTURE PLAN 2001-2016 (ADOPTED)

 

2.4.4 The provision of a new town fails to accord with the aspirations of Policy DEV1 High Quality Development. Whilst the development may be of a high quality it will not integrate with and enhance adjoining land uses and minimise potential conflicts between land uses and activities.

It will also impose costs on existing residents and businesses in west Sussex and thus fails to accord with the requirements of Policy DEV3 Infrastructure Requirements and DEV4 Travel Needs and Choices.

It fails to meet the requirement of DEV5 Parking Provision, in providing sufficient parking spaces to avoid environmental or safety problems such as parking on pavements and obstructing access for emergency vehicles.

 

WEST SUSSEX TRANSPORT PLAN 2006-2016

 

2.4.5 This plan proposes less congested transport networks which contribute towards improved quality of life, access to services, jobs and housing, local economy and environment in West Sussex. The proposal for a new town does little to support this vision. It will spoil the quality of life and environment for the existing settlements of Barnham, Clymping, Eastergate, Ford, Walberton and Yapton.

 

2.5 LOCAL POLICY

 

ARUN DISTRICT LOCAL PLAN (1996 – 2011)

 

2.5.3 The requirements that the new development should be sited in a location that does not add to congestion and pollution outlined in GEN4 Location and Travel Demand, have been totally disregarded.

 

3 ECO TOWN CASE STUDIES

 

The European case studies selected have little relevance to the United Kingdom due to different National attitudes that prevail on a range of factors.

 

7 DEVELOPMENT PROPOSALS

 

7.2 CYCLE/PEDESTRIAN PROPOSALS

 

7.2.3  The cycle routes proposed on Ford Road from Ford station to Arundel and on the A259 from the B2233 junction to Flansham on roads where the prevailing speed limit is 60 mph is extremely unsafe. Any “Safe” cycle route will be detrimental to road vehicle movements if lower speed limits are introduced which in turn will lead to greater congestion in the immediate area.

 

7.3 PROPOSED INTERNAL SHUTTLE BUS

 

As previously highlighted a high frequency community shuttle bus will not be viable with the numbers of people likely to use it encouraging greater use of personal transport.

 

7.4 PROPOSED BUS IMPROVEMENTS

 

Comments have already been provided under Coastal Expressway above.

 

7.5 PROPOSED RAIL IMPROVEMENTS

 

7.5.2 The cost of providing the infrastructure for trains to overtake would be prohibitive. Such facilities already exist at Barnham following some major work recently completed on the rail infrastructure and there is no supporting financial or operational case to replicate any of these facilities at Ford.

 

7.7 PROPOSED PARKING PROVISION

 

7.7.1 Any restriction in parking facilities will need a major change of attitude by residents of the new town. As mentioned before provision of insufficient parking spaces will encourage unsafe and unsightly parking on pavements also obstructing access for emergency vehicles. No evidence has been provided that indicates this has been successfully applied elsewhere.

 

8 TRIP GENERATION AND MODE CHOICE

 

How can Chichester and Ford new town record the same attractiveness score? The data used to calculate transport movements leaves much to be desired and should be more robust when making decisions for the future which will have serious implications on the local area in and around Ford. The behavioural change model used makes no allowance for normal changes in behaviour that are likely to occur within the early period of transition. Use of private vehicles will not be reduced as dramatically as the assessment predicts. Alternative transport modes need to be of a high quality, reasonably priced, attractive to use, fast and very frequent. None of the transport alternatives suggested fall remotely into any of these categories.

 

10 TRAFFIC IMPACT

 

Both the A27 and A259 are badly congested during both morning and evening peaks. Arundel is the worst location for delays on the local road network. The traffic flows are projected to increase annually worsening the present unsatisfactory situation. This will be exacerbated by increased heavy goods vehicle movements to feed the new Materials Recycling Facility at Ford. When incidents occur or infrastructure repairs are undertaken there are limited diversionary routes available leading to severe disruption of the road network. If the new town is built the abandonment of Ford Lane will lead to an increase of traffic including many HGVs on alternative local roads. Improvements to the local road network are several years away and do not seem to feature in the Promoters plans at present. Consideration needs to be given to the diversion of traffic from Ford Lane and the affect this will have on other local routes and communities.

 

11 CONSTRUCTION TRAFFIC

 

To ensure the developer honours its commitments rigid conditions need to be put in place with regard to access and movement of construction material. All too often we have seen developers failing to keep their promises particularly when budgets are tight and they look to reduce their costs.

 

CONCLUSION

 

The Strategic Transport Assessment report makes many claims which are not substantiated with supporting evidence. It therefore fails to provide a firm basis for the logic of building a new town at Ford. The provision of a quality transport system and appropriate infrastructure are the most important element in locating a new town at Ford. The report gives little confidence that this can be achieved.

 

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Yours sincerely

 

 

Clerk of the Council