Proposal for an Eco-town at Ford

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.
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.
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.
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:-
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.
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.
* * * * * * *
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.
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.
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.
===
Yours
sincerely
Clerk
of the Council