Eco-Town Submission

1. Introduction

In July 2007, the Government published a prospectus outlining its intention to build up to ten ‘eco-towns' by 2020; each one a ‘zero-carbon' development of 5-20,000 houses, with 30 to 50 per cent of the homes to be ‘affordable'.  In response to its invitation, the Government received 57 bids for eco-towns and, in April 2008, the Government published a shortlist of 15 sites to proceed to the next stage.

One of the 11 locations on the current shortlist 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 and to comment on the draft Planning Policy Statement (PPS) for eco-towns.

2. Our Principal Concerns

We fully endorse the comments of Communities Against Ford Eco-Town (CAFE), submitted to the Department of Communities and Local Government (DCLG) this week as part of the consultation, on the suitability of Ford as the site for an eco-town.  We would, however, like to reiterate some of our key concerns.

2.1 Risk of flooding

The Government acknowledges, in its Sustainability Appraisal for Ford, that the potential for flooding is a key weakness of the site.  It recognises that, as a coastal area, Arun District ‘is likely to experience some of the most severe impacts due to climate change' and that there is a particular risk to groundwater supplies.

2.2 Greenfield site, with high-grade arable farmland

Whilst the area does not include ‘green belt' land or areas with special protection such as AONBs or SSSIs, 87 per cent of the site is greenfield, comprising high-grade agricultural land.  A tiny percentage of the site, around 4 per cent, is actually under concrete and this part will not be built on.  Despite this, promoters continue to describe Ford as a ‘brownfield' site.

2.3 Destruction of local identity and character

The eco-town will swallow up the quiet, rural villages of Ford, Yapton and Climping and concrete over 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.

2.4 Lack of infrastructure and the scheme's viability

2.4.1 Key concerns: Our key concerns centre on the need for adequate transport infrastructure, hospital services, schools and water supplies.  These are already under huge strain and 5,000 new houses will make matters worse.

2.4.2 Funding for new infrastructure: The promoters indicated early on that "£200 million" would be available to pay for infrastructure, which we have been told will include a new railway station, two primary schools, a secondary school, health centre, community and sports facilities, wetland area, children's play areas and much more besides.  We question whether this will fund the promised infrastructure. 

We also doubt whether a scheme for 5,000 houses, 40 per cent of which will consist of affordable housing, will generate the sums required, especially at a time when the UK is experiencing a severe economic downturn and house prices have fallen sharply.

2.4.3 Funding for highway works: In its formal submission to the Government, the promoters identified an allowance of £41 million for off-site highway works, which would provide a link to the north of the site, a link south of the site to the A259, and a contribution to a new A27 bypass at Arundel.  However, the Department for Transport says that this figure is unsubstantiated.

2.4.4 A27 Bypass: The promoters have long acknowledged that a new bypass on the A27 at Arundel would be a prerequisite for an eco-town at Ford and indicated their willingness to contribute towards the cost of providing it.  However, in their final submission to the Government in August 2008, the promoters performed a remarkable volte-face and now say that an eco-town "is in no way dependent upon the bypass being in place".  We believe that a new bypass on the A27 is essential, with or without the eco-town, to alleviate the severe pressure on this strategic east-west route.  It now seems even less likely to proceed, with any scheme for the ‘preferred' route of a new bypass affected by the boundary of the new South Downs National Park.

2.4.5 Car Use: We believe that the reduction in car use envisaged for the development is totally unrealistic.  At the public inquiry last year, conducted by Arun District Council, the promoters 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 new town sited in the middle of the countryside, away from the established settlements of Bognor Regis and Littlehampton.

2.4.6 Viability of transport proposals: We understand that a Strategic Transport Assessment has not yet been carried out.

The financial viability study, produced by PricewaterhouseCoopers (PwC) and published by DCLG in March 2009, has raised a number of key concerns about transport and provides little evidence for the viability of the proposals for Ford.  On page 32, it states that:

"At the time of this report the promoter had not proposed a transport solution for addressing the impact the development could have on local roads and the strategic network that is acceptable to the DfT/HA (Department for Transport / Highways Agency)."

2.4.7 Rail improvements: The promoters still do not have an agreement with Network Rail to re-organise rail services to serve a new eco-town population and have not presented a sound economic basis for relocating the station at Ford.

The PwC report adds that the "promoter is also yet to fully develop their rail strategy for the project..."  Highlighting the proposal to provide a new station or loop and adjacent parking facility with 500 spaces, the report points out that "the promoter has costed this item at £2.5 million which the Department's advisers believe is likely to be insufficient for these works."

2.4.8 PwC's conclusions: The PwC report concluded on page 34 that:

"...there are material uncertainties over the nature and cost of transport solution[s] required to meet DfT/HA's (Department for Transport / Highways Agency's) requirements, small movements in the cost of which could adversely impact the viability of this proposal."

2.5 Waste management

The promoters have made much of their intention to minimise the generation of waste and maximise recycling and recovery.  However, this would be expected from any new development of the scale proposed. 

The promoters have, in their final submission to the Government, placed great emphasis on the County Council's Materials Recycling Facility (MRF) at Ford, which will open in July 2009.  However, this will deal with recoverable materials and will not provide developers with an energy-from-waste solution.

The County Council confirmed, some time ago, that 5,000 houses will not generate enough waste to justify the construction of a dedicated energy-from-waste plant.  In fact, the Council has already made arrangements to deal with household waste that would otherwise be landfilled.  In September, it announced a 25-year, £1 billion contract with Biffa to establish an energy-from-waste plant in the north of the County.  The plant, at Warnham, will open in 2011 and deal with all of the County's household waste.

For an energy-from-waste plant at Ford to be viable, the promoters have acknowledged in their submission of August 2008 that they would have to "import" 120,000 tonnes of waste (RDF or Refuse Derived Fuel) each year.  This would amount to 80 per cent of the waste required for the plant.  The import of large quantities of waste, by road, seriously undermines the ‘eco' credentials of the proposed development.

2.6 Delivery of 4,000 skilled jobs

The promoters based their ‘original' plans in 2007 around the opening of a new science park on the Ford site and the creation of 4,000 skilled jobs, 40 per cent of which are to be filled by residents of the eco-town.  The promoters have retreated from this vision and are now focusing on plans for a ‘business park', but provide little evidence of how they will overcome the limitations of the site and attract the investment required.

2.7 Local democracy and accountability

The Planning Policy Statement (PPS) on eco-towns will override any document produced by a local planning authority and the Government has also indicated that the Secretary of State may ‘call-in' a planning application and apply its powers under the New Towns Act.  Any pledge from the Government that the proposals for Ford will be subject to a local planning application will therefore offer little reassurance.

We believe that the PPS should not be site-specific and that it should, instead, limit itself to setting out general principles for the national eco-towns programme.  As the Chairman of the South East England Regional Assembly has said:

"The principle and location of eco-towns should be considered through the normal development plan process, and the PPS and eco-towns programme should not supersede or override local and regional plan-making."

During a debate in the House of Commons on 18 March 2009, Housing Minister Margaret Beckett confirmed that 5,000 houses at Ford could be subtracted from the Government's overall housing target of 11,300 for Arun District over the next 20 years.

This is a key development and leads to an obvious question - if the 5,000 houses are not additional, why should it not then be for the local planning authority, Arun District Council, to decide where these houses will be located within the District?  Arun District Council is much better placed to make informed judgements about the suitability of sites for development and is directly accountable to the local electorate. 

The Council is already making arrangements, through its Local Development Framework (LDF), to identify sites for new housing and has just completed a consultation with local people on a range of options for meeting the Government's housing target of 11,300 houses.  It will now produce a draft Core Strategy that will be submitted to the Planning Inspectorate in the near future.

We would urge the Housing Minister, who said in the recent Commons debate that "eco-towns are just one of the options that local authorities can choose to adopt when planning to meet the challenges in their area", to wait for the outcome of this process before making a decision on the eco-town proposals for Ford.

The decisions about where to locate new housing will be difficult and controversial, especially with the scale of development proposed, but it must be right that they are taken by those who are accountable to the local electorate.  It cannot be right that these decisions 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.

2.8 Public opinion

We have each received hundreds of e-mails and letters from our constituents about the eco-town, the overwhelming majority of which are strongly opposed to the proposal.  Indeed, local opposition to the plan is near unanimous. 

Last summer 2,000 residents of Ford, Yapton, Climping, Barnham, Arundel and other neighbouring towns and villages attended a rally at Yapton and then marched on footpaths across the fields where the houses would be built.  In October, CAFE delivered a petition signed by 10,000 people to Number 10 Downing Street.  In November, 250 local residents packed into Yapton and Ford Village Hall to express their continuing opposition to the eco-town proposal. 

We believe that this weight of local opinion must be taken into account.

3. Conclusion

Many of the concerns expressed by local residents, councils, businesses and MPs about the suitability of Ford have been acknowledged by the Government in its Sustainability Appraisal.  Despite this, Ford has been given a ‘B' rating, the Government concluding that it ‘might be a suitable location [for an eco-town], subject to meeting specific planning and design objectives'. 

We do not believe that the site is suitable for large-scale development or that the proposals for an eco-town are viable.  The Government's own advisers, PricewaterhouseCoopers (PwC), provided very little evidence to support the viability of the proposals put forward by the Ford Airfield Vision Group and have indicated that the scheme carries significant financial risks.

It is clear that there is overwhelming opposition to the proposals and we do not believe that an eco-town should proceed without local support.  We also believe that decisions about where to locate new housing should be made by elected local councillors, not the Government, and that local democracy should be not be subverted.

We urge the Government not to include Ford on the final shortlist.

Nick Herbert MP for Arundel & South Downs & Nick Gibb MP for Bognor Regis & Littlehampton

Kevin Wilson