Agenda No 9 AGENDA MANAGEMENT SHEET
Name of Committee Cabinet
Date of Committee 26 February 2009
Report Title Government Consultation: Draft Planning Policy Statement (PPS) on Eco-Towns
Summary Government is consulting on a draft Eco-towns Planning Policy Statement (PPS) together with a draft Sustainability Appraisal of schemes put forward for its Eco-town programme. The final decision on the potential locations for eco-towns will be made in early 2009, after which each scheme will have to submit planning applications. The closing date for comments is 6 March 2009. The Director's report recommends that the Council responds to the consultation as advised (in Appendix A) by the Joint Local Authority Members Working Party of the three Counties and three districts directly concerned with the ‘Middle Quinton’ bid at Long Marston depot.
For further information Andy Cowan please contact Chief Planner Tel. 01926 412126
andycowan@warwickshire.gov.uk Would the recommended No decision be contrary to the Budget and Policy Framework? There are no formal background papers – all Background Papers documents referred to being in the public domain. However, hard copies of the Draft PPS are available for inspection in Environment and Economy or can be viewed on the DCLG website following this link: http://www.communities.gov.uk/publications/planninga ndbuilding/ppsecotowns
CONSULTATION ALREADY UNDERTAKEN:- Details to be specified
Other Committees ......
Local Member(s) X Councillor Mrs I Seccombe (With brief comments, if appropriate)
Eco-towns Consultation.doc 1 of 9 Other Elected Members X Councillor P Barnes Councillor M Jones for information Councillor P Morris-Jones
Cabinet Member X Councillor C Saint - comments incorporated. (Reports to The Cabinet, to be cleared with Councillor M Heatley – noted. appropriate Cabinet Member)
Chief Executive ......
Legal X I Marriott – agreed.
Finance ......
Other Chief Officers ......
District Councils ......
Health Authority ......
Police ......
Other Bodies/Individuals ......
FINAL DECISION YES (If ‘No’ complete Suggested Next Steps)
SUGGESTED NEXT STEPS : Details to be specified
Further consideration by ...... this Committee
To Council ......
To Cabinet ......
To an O & S Committee ......
To an Area Committee ......
Further Consultation ......
Eco-towns Consultation.doc 2 of 9
Agenda No 9
Cabinet – 26 February 2009
Government Consultation:- Draft Planning Policy Statement (PPS) on Eco-Towns
Report of the Strategic Director for Environment and Economy
Recommendations:
1. That the proposed response advised by the Joint Local Authority Members Working Group attached at Appendix A to the Director’s report be endorsed and that the Government, together with local authority partners and the Regional Assembly, be informed accordingly.
2. That a letter should be sent to Communities and Local Government, signed by the Leaders and Chief Executives of the six affected local authorities, including the County Council, confirming the united position of the local authorities in their opposition to the Middle Quinton proposal.
3. That the Strategic Director for Environment and Economy be authorised, in consultation with the Portfolio Holder, to make minor changes to the response to update technical supporting material as indicated in paragraph 4.4 of the report.
4. That notwithstanding the Council’s constructive approach to the issues raised in the Draft Planning Policy Statement (PPS), the Council remains of the view that an Eco-town as proposed at Long Marston Depot is not sustainable and any comment on the criteria contained in the Draft PPS should not be regarded as conveying its support for that proposal.
1. Introduction
1.1 Following Government launch of the initial consultation on the Eco-town programme (in April 2008), the Council, in concert with the other five authorities directly affected, responded to the effect that:-
(i) Government should rethink its whole approach and follow the development plan strategies being put in place for redevelopment and expansion of existing towns and cities; and (ii) It should specifically reject the proposal for an eco-town at Long Marston Depot as being the worst of locations for a concept that was (anyway) flawed.
Eco-towns Consultation.doc 3 of 9
Neither this advice from the Council, nor similar advice from the Regional Assembly and other authorities, appears to have been taken on board in the recently launched second stage of consultation on the Eco-towns programme. 1.2 This second stage consultation on the Eco-towns programme is marked by the publication of the Draft Planning Policy Statement on Eco Towns on 4 November 2008 (originally scheduled for Sept 08). The original deadline for comments on the Draft PPS was 19 February 2009 but this has now been extended to 6 March 2009. (This extension of the consultation period was due to a legal challenge heard in the High Court on 22 and 23 January 09 that was subsequently dismissed). 1.3 The Draft PPS is accompanied by the publication of the following documents:- (i) A Sustainability Appraisal of the Draft PPS (ii) A Sustainability Appraisal of the Eco-towns Programme – Introduction, (iii) Conclusions and individual chapters for the short-listed locations (iv) An Impact Assessment of the draft PPS (v) Eco-towns – summary of consultation responses.
1.4 The ‘Middle Quinton’ Eco-town proposal for Long Marston Depot remains within the shortlist of 12 locations that are being considered for inclusion in the Eco- towns programme. The shortlist also includes two new locations which have been identified by local authorities as reasonable alternatives, at Rackheath (Norwich) and North West Bicester (Cherwell). Through the Sustainability Appraisal (SA) each of the 12 short listed locations has been assigned one of the following grades: Grade A: generally suitable for an eco-town. (NB. Only Rackheath, Greater Norwich is considered as falling within this grade). Grade B: might be a suitable location subject to meeting specific planning and design objectives. (NB. Ten out of the twelve bids, including ‘Middle Quinton’, fall into this grade). Grade C: location only likely to be suitable as an eco-town with substantial and exceptional innovation (NB. This grade is currently occupied by Weston Otmoor, Oxfordshire).
2. Draft PPS Key Features
2.1 The Draft PPS provides the long awaited guidance on how eco-town proposals should be considered through the planning system. The main features of this are summarised below:-
(i) Regional Spatial Strategies (RSS) – Should consider eco-towns as one of a range of options when determining the overall level and distribution of housing in future RSS reviews. Where an eco-town is already included in the national programme, or in a development plan document, or where planning permission has been granted, RSS reviews should consider the location or longer term growth options for the eco-town.
Eco-towns Consultation.doc 4 of 9 (ii) Local Development Frameworks (LDF) – Once again eco-towns are one of a range of options which should be considered and can be allocated within the Core Strategy. Where Core Strategies are in preparation and an eco-town location is included in the national programme, they should include it as an option for consideration. However, there is no requirement to allocate an eco-town if a better way of meeting future needs exists.
(iii) Handling Planning Applications for Eco-towns – The draft PPS confirms the government’s commitment to the plan-led system, and indicates that the starting point for the consideration of any planning application should be the development plan. It is clear however that the PPS and the locations identified in the Eco-towns programme will be a material consideration in the determination of planning applications. The weight likely to be attached to the PPS will be greater if the development plan for the area is out of date.
2.2 In terms of locational principles the draft PPS stresses that Eco-towns should comply with national policy set out in all PPSs. In identifying suitable locations the following factors should be considered:-
(i) The proximity of the eco-town to higher order centre(s) and the capacity for public transport links to that centre (ii) Proximity to planned or existing employment opportunities (iii) The role an eco-town can play in delivering other planning, development and regeneration objectives (iv) The Eco-towns Programme itself.
2.3 The draft PPS proposes a range of ‘green standards’ which Eco-town proposals are expected to meet. These Eco-town standards are broadly as set out in the Progress Statement published by CLG in July 2008 and are summarised below:- (i) Achieving zero carbon status across all the town’s buildings. (ii) Allocating 40% of the area within the town to be green space. N.B only half of this needs to be accessible to the public, the remainder can be private gardens. (iii) Requiring homes to reach the Building for Life silver standard and achieve 70% carbon savings, above current building regulations. (iv) Providing a minimum of 30% affordable housing. (v) Create more options for travel so that residents can make the majority of their journeys without a car. (vi) Ensuring a minimum of one job per house accessible by non-car modes of travel. (vii) Locating homes within 10 minutes walk of public transport and neighbourhood services. (viii) Ensuring all homes achieve at least Level 4 of the Code for Sustainable Homes.
2.4 The draft PPS also provides guidance on the development and management of eco-towns which includes, master planning, managing delivery through the planning process and community and governance arrangements.
Eco-towns Consultation.doc 5 of 9 2.5 Responses to the draft PPS have now to be submitted by 6 March 2009, and part 3 of the Draft PPS lists a range of consultation questions upon which CLG are seeking feedback. This list of questions includes the opportunity to comment on the SA of the draft PPS, the eco-town programme and the individual locations. 3. Sustainability Appraisals
3.1 As indicated above, the draft PPS is accompanied by the publication of a range of documents which includes a Sustainability Appraisal of the draft PPS itself and a separate SA of the Eco-towns programme. The SA of the programme includes chapters on each of the short-listed locations.
3.2 The SA for Middle Quinton identifies the following key strengths of the location:- (i) A brownfield development with potential to develop the existing recycling plant. (ii) A range of ecological considerations, but development would not necessarily result in the loss of an ‘ecologically coherent landscape’ and offers potential for biodiversity enhancement ( NB ecological considerations are arguably a weakness). (iii) Potential links to academic institutions and links to local horticulture and food production industries. (iv) Proximity to rail station and the potential to link to it with rapid transport systems (v) Existing cycle route between the site and Stratford with the potential to for the rapid transport system to run along this route.
3.3 Conversely the following key weaknesses of the location are identified:-
(i) Conflict with plans for growth and regeneration at a regional and local level. Local area is affluent and does not need regeneration. (ii) Rural area with the potential for the eco-town to impact on rural communities and economies. (iii) Site is remote from any city or major town which could result in long distance travel by car. (iv) Those likely to occupy the affordable housing will be from the wider region rather than the local area. (v) The loss of existing jobs on the site. (vi) Land contamination.
3.4 The SA goes on to identify three particular strengths of the development proposal itself as follows:- (i) The potential for a rapid transport link between Honeybourne, the site and Stratford. (ii) Ambitious plans for waste management and energy from waste (iii) Potential to retain existing woodland, develop lakes and create a biodiverse landscape.
Eco-towns Consultation.doc 6 of 9 3.5 Whilst concluding that the location might be suitable for an eco-town subject to meeting specific planning and design objectives, the SA also identifies a range of issues which need further consideration as follows:-
(i) The impact on views from Meon Hill (Cotswolds AONB). (ii) The socio-economic impact of the loss of existing jobs. (iii) Delivery of rapid transit proposals and public transport to other destinations. (iv) The need for and deliverability of a Western Relief Road for Stratford. (v) Ensuring that Middle Quinton is not a satellite to Stratford with commuting by car. (vi) A thorough Transport Assessment. (vii) A detailed Flood Risk Assessment. (viii) A detailed ‘land budget’ to demonstrate capacity of the site. (ix) The potential for Middle Quinton to relieve the pressure on Stratford and complement the tourist offer.
4. The Proposed Response
4.1 Appendix A sets out a report on the proposed response to the Government’s consultation. This response has been prepared by the Joint Officer Working Group with input form the six local authorities namely; Gloucestershire, Warwickshire and Worcestershire County Councils and Cotswold, Stratford on Avon and Wychavon District Councils. The Joint Member Working Group has considered this proposed response and is recommending that it be agreed by each of the six local authorities as the basis for their response to the second stage consultation. The West Midlands Regional Assembly’s Joint Planning and Environment Executive, meeting on Friday 30 January 09, endorsed a report recommending a response to Government’s consultation along very similar lines to that set out in this report and its Appendix A.
4.2 The key elements of the proposed response are summarised below:-
(i) That the PPS include a clear statement that because of their strategic significance eco-towns would only be acceptable where they have been considered within and supported by the development plan process. (ii) Changes sought to the proposed locational principles which would enable the consideration of smaller eco-communities within or adjacent to existing urban areas. (iii) Detailed comments on the proposed Eco-town standards seeking clearer, more robust standards and the use of performance phasing to ensure compliance with the standards. (iv) Detailed comments on the Sustainability Appraisal (SA). These conclude that the weaknesses of the location are such that the SA should have rejected the Middle Quinton location outright.
4.3 It is anticipated that the response will be supported by technical appendices, reflecting assessment work which has been undertaken and commissioned by the Local Authorities which includes:-
(i) A Viability Study
Eco-towns Consultation.doc 7 of 9 (ii) Critique of the Strategic Transport Assessment (iii) Retail Impact Assessment (iv) Economic Impact Assessment
4.4 Not all of the technical work will be complete prior to the Cabinet meeting and as such it may be necessary to make minor changes to the proposed response prior to the consultation deadline of 6 March. It is expected that these adjustments will be only of a limited technical nature and not alter the basis of the evidence and arguments underpinning this report and its Appendix. However, in the event that they prove to be otherwise, the matter will be brought back to Cabinet.
4.5 It should be noted that the current 'Middle Quinton' proposals for education provision do incorporate some of the features discussed with the developer. However, concerns remain about the timing of education provision: there is to be no secondary provision in the town until Phase two (i.e. for at least 7 years) and there is no clarity about when the first primary school would be provided. With large housing developments the trigger point for the development of a primary school is often the September following the completion of the 500th house. On these time scales it is likely that secondary aged pupils would need to be transported to existing secondary schools (e.g. in Stratford on Avon) in growing numbers and for several years, at a significant cost to the County Council. Primary school places would also be needed in existing, local schools, probably requiring extra accommodation in the short term. Your officers had thought it worthwhile considering the promoters original proposal for two 0-19 schools for the eco-town, on both phasing and educational grounds. However, this has been dropped in the latest land use vision document to a more conventional approach with one ‘co-located’ primary and secondary school and a further two primary schools to be built elsewhere in the eco-town at a later, undetermined, date.
5. Financial Implications
5.1 Responding to the Eco-town proposals has entailed substantial additional work on behalf of the Council and the other affected local authorities. A total grant of £100,000 has been awarded by DCLG to support the work of the six local authorities in the technical assessment of the Eco-town proposal at Middle Quinton. This includes funding of the evaluation of the promoters’ transport assessment and the appointment of a Stratford on Avon officer as a coordinating officer for all six authorities directly affected. In the event that the Middle Quinton proposal goes ahead, the County Council will probably need to commit a full-time senior officer to coordinate its engagement in the project.
Eco-towns Consultation.doc 8 of 9 5.2 The financial implications of the Eco-town proposal itself are not fully understood at this stage, as the results of DCLG’s financial viability and deliverability assessment are not available as part of the current consultation. The Joint Eco- town Working Group has commissioned consultants CB Richard Ellis to provide an independent view on the viability of the Middle Quinton proposal and the findings of this assessment will inform the final response which is submitted to CLG.
Paul Galland Strategic Director for Environment and Economy Shire Hall Warwick
5 February 2009
Eco-towns Consultation.doc 9 of 9 Appendix A of Agenda No 9
Cabinet – 26 February 2009
Government Consultation:- Draft Planning Policy Statement (PPS) on Eco-Towns
ECO-TOWNS – SECOND STAGE CONSULTATION (DRAFT) RESPONSE TO THE DRAFT PLANNING POLICY STATEMENT AND ACCOMPANYING DOCUMENTS
1 Introduction The Government launched the second stage consultation in respect of its Eco-towns programme, with the long-awaited publication of the draft Planning Policy Statement on Eco Towns on 4 November. The deadline for comments on the draft PPS has been extended to 6 March 2009. The draft PPS is accompanied by the publication of the following documents: • A Sustainability Appraisal of the Draft PPS • A Sustainability Appraisal of the Eco-towns Programme – Introduction, Conclusions and individual chapters for the short-listed locations • An Impact Assessment of the draft PPS • Eco-towns – summary of consultation responses. This document sets out a (draft) response to the second stage consultation and has been prepared for consideration by the following Local Authorities: Cotswold District Council Stratford-on-Avon District Council Wychavon District Council Gloucestershire County Council Warwickshire County Council Worcestershire County Council. The (draft) response has been prepared with input from officers from all the above authorities together with our regional partners, the West Midlands Regional Assembly and Advantage West Midlands.
2 Response to the Draft Planning Policy Statement (PPS) 2.1 The draft PPS on Eco-towns sets out a series of consultation questions at Part 3 of the document. The proposed responses to these questions (where relevant) are set out below. 2.2 Q1. Does the draft PPS provide sufficient guidance on the consideration of eco- towns through the plan making process? 2.2.1 The statements at paras 2.2 and 2.3 of the draft PPS that Eco-towns are one of a range of options that should be considered through Regional Spatial Strategies (RSS) and Local Development Frameworks (LDF) are welcome. This reduces to
Eco Town Appendix A.doc A1 of 15 some extent the concern expressed in response to the first stage consultation that the eco-towns initiative is being progressed outside the proper planning processes with no evidence based justification. The statement at para 2.4 acknowledges that Core Strategies do not have to allocate an eco-town if a better way of meeting future needs exist. This statement is helpful and reflects the fact that all reasonable alternatives have to be considered and tested by local planning authorities through the LDF process. 2.2.2 Notwithstanding the positive statements made regarding the consideration of eco- towns through the development plan system, the subsequent paras 2.5 - 2.9 of the draft PPS would still enable the approval of an eco-town which is not supported by the development plan. This is totally unacceptable. Eco-towns, because of their scale are of strategic significance and should considered within the wider strategy for the local area, sub-region and region rather than being viewed as isolated proposals. This wider consideration can only be effectively achieved through the statutory development plan, i.e. by the testing of eco-town proposals through the RSS and LDF. This would ensure that any eco-town proposal is rigorously tested against all the alternative spatial options for meeting future development needs, and as such would only be allocated where it was proven to be the most sustainable option for meeting those needs. 2.2.3 The current short-listed locations are being considered in the absence of both a regional and local plan context for them. Many of the eco-town locations identified in Annex A of the Draft PPS, such as Middle Quinton, are in conflict with approved RSSs and Local Development Documents (LDDs) and the process for short-listing locations effectively overrides and undermines regional and local plan-making to date. The PPS needs to be amended to include a clear statement that, because of their strategic significance, eco-towns would only be acceptable where they have been considered within and supported by the development plan process. 2.2.4 The Draft PPS consultation is being undertaken against a background of uncertainty about national and regional housing figures and the draft PPS is unclear whether eco-town households will deliver houses in addition to the RSS targets or will contribute to meeting those targets. The final PPS should confirm that any eco- town homes will count towards RSS and local authority housing targets, and not be in addition to them. 2.2.5 Consideration of longer-term growth options for eco towns identified within the programme (Para 2.2) could have detrimental impacts for both the sustainability of the eco town i.e. future expansion onto greenfield land and the capacity of the infrastructure to cope with future growth. There would also be a negative impact on future land availability and prices in the localities. 2.2.6 Paragraph 4.1 - notes that “there are other circumstances where a small new settlement in more remote locations may be suitable”. However these circumstances are not defined within the paper. Such definitions should include how smaller settlements will provide the necessary critical mass to make the developments viable. 2.2.7 It would seem that the benefits that eco towns can deliver identified in Paragraph 8a i.e. “relieve pressure for development in urban areas and particularly in relation to their green spaces and public services” are at odds with the previous statements made in paragraph 7 that “The majority of housing growth has always been in our towns and cities and this will continue, with a focus on brownfield land, as set out in PPS3” and also with the principles of urban renaissance as set out within the WMRSS. 2.3 Q2 Are the locational principles for eco-towns sufficiently clear and workable? 2.3.1 Eco-towns are being promoted as exemplar projects which will be required to meet exacting ‘eco-standards’, yet para 3.1 appears to offer the prospect that these standards could be ‘watered down’ to reflect ‘local opportunities and interests’.
Eco Town Appendix A.doc A2 of 15 There should be a clear requirement for any proposal to meet the eco-standards set out in the PPS and these should be applied without exception. Para 3.1 should be amended accordingly. 2.3.2 The locational principles at para 3.2 lack clarity and could be used to justify a wide range of proposals. They could provide much greater clarity around the circumstances in which an eco-town proposal could be acceptable. For example, the proximity of the proposed eco-town to a higher order centre(s) appears to be an important consideration in para 3.2(a) and at para 4.1. However para 4.1 goes on to confuse the issue by stating ‘there are other circumstances where a small new settlement in more remote locations may be suitable’. This statement contradicts the advice given at para 3.2(a) and in the preceding sentence of para 4.1, and begs the question under what circumstances is a new settlement in a remote location appropriate. Much greater clarity is required from the PPS in this respect. 2.3.3 The PPS does not offer any rational justification for the locational principles, i.e. why do eco-towns have to be separate settlements? Whilst the development of a new separate settlement may provide an opportunity to plan for internal sustainable travel, it will result in longer trips to other services and facilities. It is difficult to see how new, separate and distinct eco-town sites of 5,000 homes could have sufficient mass to support the necessary community infrastructure (including schools and health facilities) and public transport to achieve the self-sustaining aspiration. The sustainability of selected sites should be measured against urban extensions and other suitable sites in and adjacent to existing urban areas. These could meet the same exacting “Eco” and “Zero-carbon” standards as distinct new settlements. 2.3.4 The general principle of putting environmental sustainability and responding to climate change at the core of the eco-towns concept is widely supported. However these principles should be viewed as the norm for all development. Restricting the potential for eco-towns to new settlements separate and distinct from existing towns has resulted in a number of short-listed schemes which are in highly unsustainable locations. The principles of eco-towns would be better achieved if they were located in or adjacent to existing urban areas, which link opportunities and needs and utilise existing infrastructure more effectively. The locational principles in the PPS should be amended accordingly. 2.3.5 The proposed principle that in identifying suitable locations for eco-towns, consideration should be given to the “Eco-towns Programme” is not supported, because many of the locations identified in Annex A of the Draft PPS (including Middle Quinton) may not be in sustainable locations. 2.3.6 To address the above issues the final PPS should enable consideration of smaller (less than 5,000 homes) eco-communities within or adjacent to existing urban areas which link opportunities and utilize existing infrastructure more efficiently. 2.4 Q3 Taking overall the standards set out in the draft PPS do you think that they achieve a viable eco-towns concept? 2.4.1 In short the answer is no, the PPS needs to provide much greater clarity around the locational principles for eco-towns with an emphasis on locations in or adjacent to existing urban areas as set out above. The preferred option for many regional and local planning authorities and as recommended in Table 6 of the SA would be for the eco concept to be delivered as part of urban regeneration or urban extensions. The potential for this means of delivery is reinforced by the proposals being taken forward in the Leeds City Region. 2.4.2 It would be more sustainable to locate extra development in existing urban locations. Given the current economic climate the time, effort and funding expended on supporting the Eco Towns programme could be better utilised in supporting existing developments with planning permission that have been effectively ‘moth balled’. An example of which in the West Midlands would be the former Longbridge site, which provides the benefit of being able to connect to
Eco Town Appendix A.doc A3 of 15 existing transport infrastructure, and whilst also providing other environmental benefits. 2.4.3 Paragraph 8 - states that eco towns should have the necessary critical mass to deliver higher standards of sustainability. It should be questioned as to whether the locations identified have the necessary mass to make the developments viable yet alone sustainable. 2.5 Q4 Views on the Eco-town standards General Comments (Questions 4.1 – 4.4) 2.5.1 As stated previously Eco-town proposals should be identified through the development plan system, and meet clear locational requirements in respect of their proximity to existing urban areas. Only when these requirements are met would the eco-town standards set out in the PPS be relevant. Put simply if the proposed eco- town is not in the right location, compliance with the eco-town standards alone would not make it sustainable. 2.5.2 It is recognised that by providing high levels of infrastructure, zero carbon buildings and affordable housing Eco-towns are unlikely to be financially viable to developers without Government support. There is considerable concern that any public sector funding towards delivering eco-towns would divert private and public investment away from delivering other housing and transport priorities elsewhere in the region. Any funding to deliver eco-towns should either be secured from the developer or, where this is not possible, be funded from additional national resources. 2.5.3 There is also concern that the consequences of not meeting the required eco-town standards in terms of affordability, provision of jobs, infrastructure and essential services could fall on local government. To address these concerns, the final PPS on eco-towns should provide clear guidelines on what financial guarantees or commitments could be expected from landowners/developers or Government to ensure that eco-town standards are achieved. 2.5.4 The draft PPS needs to include robust mechanisms to ensure compliance with the Eco-town standards. To ensure delivery is in accordance with the eco basis for promotion of eco-towns the PPS should include 'performance phasing'. In brief, the PPS should require eco-town schemes seeking approval in principle (development plan or outline application) to be phased such that the next stage after commencement cannot proceed until the previous stage meets all the targets (carbon footprint, energy conservation, max car trips etc). This should address the problem of uncertainty about the feasibility and viability of many of the aspects of eco-towns being promoted in the absence of supporting design details and evidence. 2.5.5 The Sustainability Appraisal recommends (para 3.9.5) inclusion within the PPS of a section on Landscape and the Historic Environment, which could include requirements for landscape character assessment and historic environment characterisation to be undertaken, and for ensuring that development is sympathetic to the landscape and conserves and enhances historic environment assets. 2.5.6 It is a matter of concern that the inclusion of such a section has been ruled out (para 26 of Introduction to Draft PPS), on the grounds that national policy is established in PPG15 (no reference is made to PPG 16) and that these issues are considered to be matters of regional and local significance to be handled at the appropriate level of plan-making and which will be taken into consideration in the decision-making process. 2.5.7 It is understood that a draft PPS on the Historic Environment, replacing PPGs 15 and 16, will shortly be issued for consultation. The scope and level of detail of planning guidance likely to be current when eco-town schemes are being worked up are thus presently uncertain. Since sustainability is one of the key characteristics of the eco-
Eco Town Appendix A.doc A4 of 15 towns concept, it seems perverse that the PPS should exclude guidance on sustaining the landscape and historic environment. 2.5.8 The European Landscape Convention and its Implementation Framework underscore the need to integrate landscape into policy (Article 5d - 'integrate landscape into regional and town planning policies... as well as any other policies with possible direct or indirect impact on landscape'); this does not appear to be consonant with the draft eco-towns PPS. Landscape defines local character and distinctiveness and shapes peoples’ sense of place; consideration of landscape is thus essential for place making. Development of eco-town proposals should therefore incorporate a full understanding of the character, context, significance and vulnerability of landscape and historic environment. Commitment to this principle appears to be entirely lacking in the draft PPS. 2.5.9 Paragraph 4 states that eco towns “will have sustainability standards significantly above equivalent levels of development in existing towns and cities” and that they will “enable the development of exemplar schemes to demonstrate how we can live in a low carbon future provide”. Whilst it would be beneficial for eco towns to meet standards above current or existing standards it would hardly seem an ambitious target. Indeed current provision within Regional Spatial Strategies emerging LDFs would meet with the standards proposed and in some cases exceed them. 2.5.10 In addition, owing to market uncertainty and lead times for the potential developments, it is likely national standards for all development, such as the Code for Sustainable Homes (CSH), will have reached the levels proposed within the draft PPS. In this context eco-towns would hardly seem to be exemplars. 2.5.11 It is welcomed that paragraph 5 recognises that such standards are suitable for other forms of development i.e. urban extensions however a stronger emphasis of this potential should be made throughout the paper and consideration should be made to include this within the title for the paper i.e. Eco Towns and Urban Extensions, Sustainable development etc. 2.5.12 However the standards to be achieved for homes would appear to fall short of setting exemplar standards i.e. Building for Life should be at Gold Standard and not silver and CSH should be at level 6 from the start to deliver the highest standards of both design and environmental benefits and to reduce the retro fitting of measures in the future otherwise as noted previously they are not exemplar and will only attain the same levels being prescribed in RSS and core strategies. 2.5.13 Paragraph 32 – further details should be provided of the nature of the assessment of suitability for government funding. Such funding should be from additional government funds and should utilise any gain realised from the sale of former government owned land i.e. former Ministry of Defence sites such as the Middle Quinton proposal. In addition such funds should not affect regional or local funding allocations for infrastructure or the funding programmes of statutory or public bodies. Furthermore, it is difficult to make a reasoned judgement, when owing to commercial sensitivity, access has not been made available to economic viability assessments completed on behalf of CLG to assess developer potential to deliver the proposed schemes. Zero Carbon in Eco-towns 2.5.14 We support the principle embodied within the draft PPS, but concern is expressed that the definition excludes transport. Where eco-towns are proposed in remote locations which generate the need to travel, carbon emissions from transport would offset the carbon neutrality achieved within the built environment. The PPS should also seek to assess and reduce the carbon emissions associated with construction e.g the source and transport of materials. Embodied carbon is excluded from the definition of zero-carbon in the PPS, but there should be some requirement to restrict the use of materials with high levels of embodied carbon.
Eco Town Appendix A.doc A5 of 15 2.5.15 The definition of zero carbon development still requires clarification in order to remove uncertainty both for developers and planning authorities especially if the principles of the Eco Towns PPS are to be taken up elsewhere by developers. Indeed research by the UK Green Building Council into the definition of Zero Carbon shows that “current definition is not achievable on up to 80% of new homes. Therefore, if Government wants to maximise its housing delivery targets, without watering down the level of carbon savings, the definition of zero carbon must change” (see link: http://www.ukgbc.org/site/resources/showResourceDetails?id=180). 2.5.16 It would also seem that the setting of a zero carbon definition only in the context of eco towns and not in anticipation of the zero carbon definition that will apply to all new homes by 2016 only serves to add further confusion. 2.5.17 The phased programming (para 4.5) to be submitted with the planning application should deliver zero carbon (as defined) from the beginning of development, requiring the delivery of energy infrastructure in the initial stages of development at all scales and should not provide the opportunity for claw back at later stages of development i.e. where emissions are potentially zero or below. Climate Change Adaptation 2.5.18 This appears to repeat advice which is in the Climate Change supplement to PPS1, and as such does not set a standard which is specific to Eco-towns. Could be deleted as all development should comply with the PPS1 supplement. 2.5.19 Consideration should be given on the impact that the development of Eco-towns would have on the relevant national indicators for local authorities in terms of emissions, adaptation and biodiversity protection. Homes 2.5.20 Support requirements to achieve the Building for Life and Lifetime Homes standards. However the standards set within the Draft PPS fall short of delivering sustainability standards that would secure exemplar projects to showcase sustainable living above current or proposed requirements already set out within RSS. For example, the West Midlands RSS Phase 2 Revision will require all new homes to meet at least level 3 of the code for sustainable homes and consider level 4 before 2013 and zero carbon before 2016 whereas the Draft PPS will require Code level 4 at a minimum. When the potential lead in time for these developments is considered they are unlikely to be delivering higher standards than those that will be expected of all new development in the near future. Therefore the PPS should seek to gain the most stringent standards from the start. 2.5.21 The standard relating to affordable housing should make it clear that requirements for more than 30% would be appropriate where this is justified by the levels of housing need identified in Local Housing Assessments and by the policies of the Local Development Framework. 2.5.22 It is also essential that affordable housing is to meet local needs. Affordable housing in excess of local needs can lead to unbalanced communities and inadvertently draw households out of the MUAs and undermine the objective of urban renaissance. There is concern that the potential problem of unbalanced communities could be exacerbated by concentrating so many affordable houses in ‘separate and distinct’ towns where the public transport infrastructure, initially at least, is not developed enough to link people (particularly those on lower incomes) to jobs and other facilities. Employment 2.5.23 It is assumed that the requirement to provide one ‘accessible’ employment opportunity per new dwelling, means that the employment opportunity should be provided within the proposed eco-town itself. The wording of para 4.11 should be absolutely clear in this respect.
Eco Town Appendix A.doc A6 of 15 2.5.24 If these settlements are to be sustainable, then it is arguable that a higher level of employment provision should be sought. This reflects the lack of ambition evident in para 2.1 of the PPS which states that eco-towns are ‘not expected to be entirely self-sufficient, particularly in terms of employment.’ Whilst not suggesting that eco- towns should be functionally isolated from surrounding communities, if they are to be exemplar proposals they should aim for as higher degree of self containment as possible. The PPS should make it clear that eco-towns cannot merely rely on the ubiquitous service employment generated by the housing itself but must have an explicit definition of, and programme for, the substantial development of an economic potential that is specific to that particular location. Failure to provide adequate employment within eco-towns could have a detrimental impact on the availability of employment opportunities in surrounding communities. Transport 2.5.25 This is a key area, but the draft PPS is relatively weak on this: The PPS needs to define what is meant by ‘frequent’ public transport and ‘neighbourhood’ services. Travel plans should be tougher e.g. ensure that at least 50% of trips are non-car, not just enable. Para 4.16 – if the standard is reasonable there shouldn’t be any need to make exceptions. If water or other physical landscape features restrict accessibility then the sites may not be suitable as an eco-town. 2.5.26 The PPS ( at para 4.13) should emphasise the provision of transport choice and infrastructure from day one of residential occupation, and this should be available to support all the uses within the eco-town such as employment and education. 2.5.27 There should be a much greater emphasis on eco-towns being exemplars in the design and operation of their transport systems. The PPS should set out clear and ambitious targets for the modal split of journeys and for the overall CO2 emissions associated with transport. It should also set out the mechanism for ensuring that these targets are met and that sustainable transport outcomes are delivered. Local Services 2.5.28 Para 4.17 does little more than state the obvious, and does not really provide clear guidance on the level of services which eco-towns are expected to deliver. The draft PPS could provide more detail and clarity regarding the level of service provision which is expected. For example what is the definition of a ‘good level of provision of services.’ Whilst it is acknowledged that the local context for eco-town proposals will vary, the PPS could attempt to establish a minimum level of service provision that all proposals would be expected to meet. 2.5.29 Education provision is an area of key concern for the local authorities. It is essential that the PPS secures the early delivery of schools within Eco-towns and ensures that the impacts on existing schools within the local area are fully considered. Opportunities for innovation within the delivery of education services should be encouraged. Green Infrastructure 2.5.30 One of the alleged advantages of eco-towns over development in existing urban areas is the opportunity they provide to deliver a ‘good quantity of green space of the highest quality’ (see Part 1 para 8). In this context the requirement for 40% greenspace seems unambitious, particular when up to 50% of this requirement can be made up of private garden space. 2.5.31 As stated in the SA there is an obvious risk that eco towns will have a detrimental impact on the historic environment and landscape character however these have not been considered within the PPS. Whilst these may be issues to be considered at a local or regional level it does not lessen the need for the PPS to consider or highlight these issues as historic and landscape assets will inevitably form part of the wider
Eco Town Appendix A.doc A7 of 15 green infrastructure network and may also deliver biodiversity, recreational and cultural benefits. Biodiversity 2.5.32 Paras 4.20-4.21 – whilst the principle of no net loss of biodiversity on the site together with maintenance and enhancement of ecological sites and species is welcome, it is not clear how this is an improvement on business-as usual. PPS9 already highlights the provision for such measures, which could include the management of such sites, and which is also referred to in Local Plan Policies. 2.5.33 Para 4.21 – need to define what is meant by species and habitats of principal importance. Is this the same list as that provided by PPS9? Water 2.5.34 The aspiration to reach water neutrality should not be confined purely to areas of high water stress but should be for all developments if to they are to be exemplar and deliver the highest environmental gains. Water efficiency measures for non domestic uses should not only be limited to their domestic use but should also include operational or manufacturing uses i.e. certain energy generation process such as steam combustion require large volumes of water for the production of energy. Flood Risk Management 2.5.35 Eco-towns should not be located in areas where they have the potential to increase the risk of flooding. Paras 4.27 and 4.28 should make stronger statements in this respect. The words ‘wherever practicable’ should be deleted from the first sentence of para 4.27. The words ‘as far as possible’ should be deleted from the second sentence of para 4.28. Waste 2.5.36 The proposed waste standard is in the main clear and workable but words like "be substantially more ambitious" are not particularly helpful as different interpretations could be applied. Firm numbers are much more helpful and would create an even playing field. An ambitious target should be set for recycling/recovery which reflects the standards already being achieved locally1 and those being achieved by other European countries such as Belgium. The Middle Quinton proposal for example aims to achieve zero waste to landfill. 2.5.37 Combined Heat and Power (CHP) does have its own limitations being very much dependent on the technology to be adopted. If the traditional energy from waste (incinerator) facility is to be the preferred option then it is questionable whether there would be sufficient waste generated locally to feed it whilst recognising that you can have such plants of anywhere from 50,000 tonnes per annum capacity upwards. Even then it is quite likely that waste/biomass imports would be required which then raises questions about sustainability and public acceptability for such a scheme. Unless waste/biomass imports can be sustainably sourced and transported, the use of these technologies would undermine rather than support the eco-town concept. 2.5.38 There are other technologies such as pyrolysis, gasification and anaerobic digestion that can deliver combined heat and power with only the latter of the three being proven technology. All three technologies require carefully prepared feedstock which then adds to the cost and may not be economically viable. These technologies can operate on a modular basis with modules being as small as 10,000 tonnes per annum capacity so would perhaps fit the residual waste arisings from an eco-town size development.
1 Cotswold District currently achieves a 74% rate for waste recycling and recovery
Eco Town Appendix A.doc A8 of 15 2.5.39 Bullet point four is difficult to understand and should spell out under what circumstances landfill may be the ‘least environmentally damaging option’. The PPS should not even be considering landfill as an option as all such materials should be reprocessed and used within the development. Even where the materials are contaminated they should be treated on site and re-used. Developments of this size should aim to accommodate on-site remediation of residual contamination as far as possible. 2.5.40 Having collected the "seven priority" waste materials consideration should be given as to how and where they will be reprocessed. In the Middle Quinton proposal this will be done in an on-site facility. The PPS could require similar provision across all Eco-towns to reduce the transport of waste materials. Transition and Development 2.5.41 The proposals seem reasonable but the PPS should include a reference to performance phasing as set out in para 2.5.4 of this response. Community and Governance 2.5.42 Agree that long term governance arrangements are essential, but the PPS should give greater emphasis on governance arrangements fitting into existing local government structures. 2.5.43 The annual monitoring of the sustainability of eco towns by either region or district planning authorities could become an onerous task in its own right placing additional resource pressures on authorities. A set of indicators should be outlined in the PPS to provide guidance on measurements whilst enabling authorities to take into account locally specific factors. This will also enable the governance structure for the eco towns to collate the necessary information whilst ensuring the success of any potential developments. 2.5.44 As the SA in paragraph 2.6.9 (bullet 4) states “whether or not eco-towns achieve their aims is likely to depend to a large extent on the vigilance of Communities and Local Government, local authorities and communities”. The requirement for continual or annual monitoring by the regional and local authorities will, as noted above, create additional pressure on resources. As Eco-towns are being promoted as a national policy CLG should retain some responsibility for delivery and the achievement of standards.
3 Comments on the Sustainability Appraisal, Habitats Regulation Assessment, and Impact Assessment of the draft PPS and Eco-towns Programme 3.1 The Council(s) does not propose to make detailed comments on these documents, but considers that a robust sustainability appraisal would require the assessment of ‘eco-towns’ as a option against other spatial options for addressing housing growth and climate change. This should be done within the clear regional and local context provided by Regional Spatial Strategies and Local Development Frameworks.
4 Comments on the Sustainability Appraisal/Habitats Regulation Assessment for Middle Quinton
General Comments 4.1 There are serious concerns about the robustness of the SA which has been undertaken for the Middle Quinton site as set out in the following paragraphs. 4.2 Paragraph 1.1.2 of the SA – notes that it has been undertaken at a strategic level and is necessarily broad in its conclusions whilst also noting that it constitutes the first of a series of successive assessments that will be required as eco-town proposals are taken forward. The SA forms part of the basis upon which the Middle Quinton site has been graded for inclusion in the PPS. However, because of its timing the SA relies almost entirely on developer led assessments (see para 2.7.2)
Eco Town Appendix A.doc A9 of 15 of the SA. A number of these assessments were not submitted to the local authorities until October and as such the assessment was made without the benefit of comments from the local authorities on key documents such as the energy statement and retail impact assessment. 4.3 It is also apparent that there is an absence of information on a number of key issues which the SA should consider. This is clearly illustrated in Table 4 page 41 where comments for critical SA issues (Climate Change, Water Resource and Infrastructure) are currently listed as ‘not known’. It is difficult to see how a reasonable assessment could be made even at a strategic level if such data were not available and future in depth assessment could deem the site unsustainable. 4.4 Whilst acknowledging that the larger part of the site falls within Stratford-on-Avon District the SA appears to have an overwhelming emphasis on the impacts on Stratford with little or no reference to Wychavon. For example paragraphs 2.5.34 – 2.5.37 (Employment and Economy) make no assessment of the sustainability impacts on Wychavon or Worcestershire’s employment and economy. 4.5 There are a number of errors within the SA document itself which suggest it has been undertaken hurriedly. 4.6 Paragraph 2.2 of the SA identifies the Middle Quinton Eco Town location as a Brownfield site. Whilst significant parts of the site are previously developed, the site also contains extensive areas of green space including woodland, water features and agricultural land. This should be acknowledged within the SA.
Policy Context (section 2.3) 4.7 A key objective of the West Midlands RSS is to make the major urban areas (MUA’s) of the West Midlands increasingly attractive places where people want to live, work and invest. Beyond the MUAs, the provision for housing will generally be concentrated in Settlements of Significant Development (namely Worcester, Telford, Shrewsbury, Hereford, Rugby, Burton upon Trent, Stafford, Nuneaton/Bedworth, Warwick/Leamington Spa and Redditch) although some peripheral development of other settlements may need to be considered in LDDs, as part of an overall approach to the development of sustainable communities, provided this does not undermine the renaissance of the MUAs (Para 3.12(a)). Housing development outside these areas is primarily to meet locally generated needs. 4.8 The above policy principles are reflected primarily in policies CF2 and RR1 of the West Midlands RSS Phase Two Revision Draft Preferred Option (December 2007). The West Midlands RSS Phase Two Revision – Draft Preferred Option also emphasises need to reverse the movement of people and jobs away from the Major Urban Areas. For the Coventry, Warwickshire and Worcestershire sub-regions, the WMRSS Phase Two Revision emphasises (Para 3.45 and 3.65) that housing growth in Stratford-on-Avon and Evesham should be limited to local needs. 4.9 Draft Policy CF3 identifies 5,600 net additional dwellings in Stratford-on-Avon District 2006 – 2026. The 6000+ dwellings associated with the Middle Quinton proposal would exceed the RSS housing target for the District yet may fail to meet local needs of several small towns in the district such as Alcester, Shipston-on-Stour and Southam. Draft Policy CF3 also identifies 9,100 net additional dwellings for Wychavon. Whilst 6,000 dwellings clearly does not exceed this target it may not leave sufficient numbers to meet local needs within the District. 4.10 In light of the above, it is clear that a “Middle Quinton” eco-town does not align with the objectives and policies of the West Midlands Regional Spatial Strategy. This is acknowledged within the SA at section 2.3, but it still goes on to indicate that the location, might be suitable.
Eco Town Appendix A.doc A10 of 15 Detailed Comments on the SA 4.11 Paragraph’s 2.5.4/5 – in describing the biodiversity and green infrastructure within the site identify the SA identifies areas of species rich grassland, calcareous grassland and one field previously described as species rich. It would seem difficult to square this evidence of diverse habitats with the promoters preferred position that the site be considered as Brownfield. Whilst grassland may have suffered from a lack of management in recent years it is possible to restore such grassland due to dormant seeds etc being retained and as such measures should be required to mitigate the impact of the development. Further more these species or habitats are BAP habitats and EU Habitats Directive Annex 1 and as such should be afforded greater protection and priority. 4.12 Paragraph 2.5.13 – Discusses the landscape and historic environment however no note is made of the potential for Romano British activity within the site as identified by the developer’s consultants Waterman CPM Ltd (WCPM) and supported by Warwickshire County Council’s County Archaeologist. 4.13 In discussing the built heritage of the site the notes that “Due to the postwar redevelopment of Long Marston there are relatively few surviving war time structures such as Romney huts. The Romney huts are semi-circular corrugated steel sheet covered structures, similar to the smaller and better-known Nissen hut. They were used for stores and workshops. There were a number of Romney huts across the site, which are now generally being used for storage”. This paragraph would seem confusing and would appear to contradict itself in suggesting that there “were” (past tense) a number of Romney Huts which “are being used for storage” (present tense) and from this statement it would seem unclear as to what the present situation is with regard to built heritage. 4.14 The statement at para 2.5.22 in respect of groundwater and water supplies relates to a document produced by Lincolnshire County Council, and describes the situation in the Anglian region. It certainly doesn’t relate to Middle Quinton which falls within the Severn Trent region. This error highlights the speed with which the SA has been produced. 4.15 Paragraph 2.5.25 – In discussing Community Infrastructure states that “At this point it is not possible to describe in any further detail the current situation in terms of access to services and facilities experienced by residents of nearby villages”. However this would appear contradictory to comments in paragraph 2.5.27 which notes that: “Stratford District can be described as having: communities that experience low levels of deprivation and crime but high property values and for those in rural areas, poor access to key services”. If the previous paragraph states that it is not currently possible to discuss service deprivation in the vicinity then it would appear that further consideration of the impact on rural services both positive and negative is required in order to make an accurate assessment to inform the SA. 4.16 Paragraphs 2.5.26 – 2.5.30 (Community Well Being & Decent Affordable Homes) have very little, if any reference to Wychavon and this assessment would appear inadequate. The impacts of the development will be cross boundary particularly for Wychavon D/C villages in the immediate proximity i.e. Pebworth and Honeybourne and for the wider district toward Evesham. The same issues should also be considered for the cross boundary impacts on settlements in Gloucestershire such as Mickleton and Chipping Campden. 4.17 Paragraph 2.5.26 states that the SOA “appears” to perform particularly poorly in terms of health deprivation. Further in depth assessment should be completed in the locality (across boundary) to clarify the true position. This indication may be related to a number of factors including service deprivation for rural localities and the
Eco Town Appendix A.doc A11 of 15 ageing demographic population and the additional pressures this may put on health infrastructure. 4.18 Paragraph 2.5.30 – states that there are currently 2,779 households on the council’s waiting list. Once again this relates only to Stratford District and does not assess the spatial distribution of this need relative to the site. 4.19 Paragraph 2.5.31 – identifies the high reliance on car dependency within the location and the numbers who commute out of Evesham daily to work (6,000) a higher number than Stratford. The development of employment opportunities at Middle Quinton may only serve to reinforce these trends and will impact on the potential levels of containment of employment within the site for residents. The proposed phasing of the development of the transport solutions and the identification by the promoters of the “potential” (not a given) for connection to Honeybourne will exacerbate this issue particularly in the early phases of development. 4.20 The SA highlights that the location and transport connectivity of the site are not promising for the achievement of high usage of sustainable transport modes. There is significant risk that the ‘Eco’ transport outcomes will not be achieved. The Strategic Transport Assessment (STA) which has been produced by the promoters is a reasonable piece of work having regard to the time constraints within which it has been prepared. However any assessment of transport is unlikely to predict real outcomes. There is no tried and tested methodology for assessing or achieving the transport outcomes that are set out for the eco-town. Because of the limited amount of work that has been possible within the time constraints there can be no certainty that the assumptions set out in the STA will be valid or that the transport proposals are affordable and deliverable. 4.21 Paragraphs 2.5.34 – 2.5.37 make no assessment of the sustainability impacts on Wychavon or Worcestershire’s employment and economy. 4.22 Paragraph 2.6 - in considering the ‘business as usual, option’ the appraisal makes no reference to Wychavon. 4.23 Paragraph 2.7.9 – 2.7.10 whilst the site would benefit from rainwater attenuation further assessment would be required of the impacts of SUDS or soft landscaping and remediation of previous hard standings and the potential reactivation of past contaminants through groundwater. It is noted that parts of the site fall within Flood Zones 2 and 3a, but that the masterplan does not propose built development in these areas. Furthermore the Environment Agency has not indicated that flood risk is a major issue on this site. Notwithstanding this, given the scope of the national Eco-town programme it should be possible to identify sites which have lower levels of flood risk than the Middle Quinton proposal. Para 2.5.11 of the SA notes that the underlying geology has a tendency to retain water which can result in the ground becoming saturated following heavy rainfall. The previous use of the site by the MOD was only possible following major ground stabilisation achieved by importing ash and rubble from Hinckley Power Station. 4.24 Para 2.7.13 – with regard to the proposed waste facility the developers supporting energy statement contains little illustration of the potential biomass resource available from the Eco Town for every 1MW of energy approximately 10,000 tonnes of biomass is required and it is not clear if the Eco Town would be able to support this requirement. Equally no evidence is given of the potential to source energy crops for the facility given the current pressures on agriculture weather, yields, funding mechanisms etc. This may bring into question the need to import feed- stocks from a greater geographic area and as such the sustainability and deliverability would be impacted upon. Again an accurate assessment is required to support a meaningful sustainability appraisal. 4.25 Para 2.7.15 – suggests that there is no indication that the eco-town proposal will significantly impact on views from Meon Hill or on the surrounding landscape
Eco Town Appendix A.doc A12 of 15 character when compared to the existing buildings/use of the site. Worcestershire County Councils officers have recommended that winter comparison of the impact on viewpoints should be made. This may throw up some additional viewpoints to take into consideration. The intensification of development within the site to deliver the proposed housing densities, infrastructure and employment land plus the waste facility will have a greater impact than the current dispersed nature of buildings. 4.26 Paragraph 2.7.19 – with reference to the waste facility the reality of the proposed waste facility being able to recycle or reuse 100 percent of Middle Quinton waste stream would seem highly improbable. Some materials simply have no market or as yet are simply not economically viable. Equally no mention is made of the disposal of hazardous materials such as paints or chemicals from households or business. There are very few points nationally available for the disposal of such materials with those that do exist being largely reliant on incineration. Such waste streams that may have to either be combusted or sent to landfill may also include waste woods and no mention is made in either the vision statements, energy statements or the SA of these materials. 4.27 Paragraph 2.7.25 – 2.7.28 makes no comment of the impacts on Wychavon. 4.28 Paragraph 2.7.34 – notes that the re-instatement of the railway line between Honeybourne and Middle Quinton is an “aspiration”. The Councils do not believe that reinstating the railway as a cul-de-sac from Honeybourne for passenger services will ever be viable. The only way in which a passenger service could be provided at Middle Quinton would be as a stop on a through service which would require the reinstatement of the railway through to Stratford-upon-Avon. There are also local aspirations to extend rail connection south through to Cheltenham. It is clear that the Middle Quinton proposal will not deliver the extension or reinstatement of rail services and there is no prospect of these connections being delivered in the short term. This represents a missed opportunity to deliver a step change in rail service provision in the local area, which would have helped to address some of the fundamental concerns about the sustainability of the site’s remote location. 4.29 Paragraph 2.7.43 – notes the potential for a rail distribution centre to serve the Vale of Evesham fruit and vegetable industry this would however be detrimental to sites such as Vale Park which houses many chilled distribution businesses and would serve to draw businesses i.e. packaging, preparation and distribution related to this sector away from the Vale of Evesham. Equally such produce would still need transporting either to or from the site with the resultant impact on the local road infrastructure. The local authorities in the Vale of Evesham have worked jointly to restrict the growth of HGV traffic within the area, because of the adverse impact that this has had upon the local road network and local communities. This work culminated in the preparation of a Joint Supplementary Planning Guidance entitled ‘Lorries in the Vale of Evesham’. This SPG establishes a ‘control zone’ within which development which would result in an increase in HGV movements is restricted. The Middle Quinton site falls within this ‘control zone’. 4.30 Paragraph 2.7.46 – makes no mention of potential further education links to Wychavon or Worcestershire. 4.31 Paragraph 2.7.47 - the exact nature of the waste facility is yet to be determined including the potential volumes of waste that would be required for energy generation and the ability of the population of the Eco Town to create the levels of waste required for the processes envisaged and may in turn lead to the need for additional waste materials to be imported. Clarification of the employment potential of the proposed facility should also be sought as part of the assessment. 4.32 Paragraph 2.7.52 – the same comments can be made of the impacts on the historic environments of Wychavon and the Cotswolds AONB.
Eco Town Appendix A.doc A13 of 15 4.33 Paragraph 2.7.54 – The draft PPS (paragraph 2.2) would place a requirement for regional and local planning authorities to plan for expansion of proposed eco town sites. It should be noted than any further expansion of the Middle Quinton proposal would require the release of extensive areas of greenfield land. 4.34 Paragraph 2.7.55 – discusses the issue of past contamination and past efforts taken to remediate this and the resultant reduction in contamination levels. However further investigations would be required as stated to ascertain potential contamination from a number of sources including the former military use of the site, the current recycling facility run off, run off from hard standing used to store vehicles and those areas used to store railway stock. 4.35 Paragraph 2.8.4 – Table 4 pg42 in discussing SA Issues relating to Transport and Accessibility makes no comment of Evesham as a higher order centre (a consistent theme throughout the SA) and only makes note of Honeybourne station (which as previously commented is identified as having a ‘potential’ for links). Comments on the conclusions of the SA 4.36 The SA concludes that Middle Quinton is a Grade B site which ‘might be suitable for an eco-town subject to meting specific planning and design objectives’. The logic for this grading is unclear and further explanation of the ‘specific planning and design objectives to be met’ is required. 4.37 At para 2.8.1 the SA identifies the key strengths of the location. These strengths however do not bear close scrutiny. The emphasis on brownfield development ignores the extensive areas of green space on the site. The ecological considerations which apply to the site are a potential constraint to development rather than a strength. Recently the site has been considered by the selection panel for designation as a Site of Interest for Nature Conservation (SINC). The Panel concluded that part of the site merits SINC designation. Further information will be forthcoming in this respect. 4.38 The other strengths are all potential rather than guaranteed e.g. the potential links to Honeybourne and Stratford Stations by rapid transit systems. The local authorities have undertaken an assessment of the Strategic Transport Assessment which has informed the SA and this raises serious questions about the transport impacts of the development and the business case for the public transport proposals. The findings of this assessment undertaken on behalf of the local authorities are included in Appendix X attached to this response. 4.39 The weaknesses of the location set out at para 2.8.2 are much more tangible and reflect the opposition to the proposal which has been clearly articulated by the local authorities responses to the first stage consultation. The weaknesses of the location, i.e. its conflict with strategic plans for growth and regeneration, and the remote rural location with potential to increase long distance travel by car are so substantial that the SA should have rejected this location outright. 4.40 Para 2.8.5 of the SA provides a list of matters which require further consideration. The local authorities consider that all of these matters need to be satisfactorily resolved before the site is included within the Eco-towns programme. The technical work undertaken by the local authorities challenges whether the issues highlighted within the SA, particularly those relating to transport, can be satisfactorily addressed whilst maintaining the viability of the development proposal. 4.41 XX Summarise the findings of the viability assessment and retail assessment and insert in the appendices to the response XX
5 Conclusion 5.1 This response has been prepared by the Joint Officer Working Group with input form the six local authorities namely; Gloucestershire, Warwickshire and Worcestershire County Councils and Cotswold, Stratford-on-Avon and Wychavon District Councils.
Eco Town Appendix A.doc A14 of 15 The Joint Member Working Group has considered the proposed response and is recommended that it be agreed by each of the six local authorities as the basis for their response to the second stage consultation. 5.2 In responding to the first stage consultation the Council(s) made clear its opposition the proposed Eco Town development known as Middle Quinton, based on the information then available. Notwithstanding the additional information that has been produced as part of the second stage consultation, the Council(s) remains opposed to this proposal. The provision of detailed response provided by the Council (s) on the questions posed in the draft PPS, should in no way be taken as an acceptance ‘in principle’ of the ‘Middle Quinton’ eco-town proposal. 5.3 The key elements of the proposed response are summarised below: • That the PPS include a clear statement that because of their strategic significance eco-towns would only be acceptable where they have been considered within and supported by the development plan process. • Changes are sought to the proposed locational principles set out in the draft PPS which would enable the consideration of smaller eco-communities within or adjacent to existing urban areas. • Detailed comments are provided on the proposed Eco-town standards set out in the draft PPS seeking clearer, more robust standards and the use of performance phasing to ensure compliance with the standards. • Detailed comments are made on the Sustainability Appraisal (SA) for the Middle Quinton. These conclude that the weaknesses of the location are such that the SA should have rejected the Middle Quinton location outright. • Should the proposal proceed, contrary to the strong objections of the local authorities, then the provision of sustainable transport links and the impact of the proposal on the local road network will be critical. This requires a much more thorough assessment than the Strategic Transport Assessment undertaken to date, and the proposal would need to deliver a step change in the provision and utilisation of all forms of public transport in the local area.
Contact details:
Colin Staves Eco-town Project Coordinator Planning Services
Stratford on Avon District Council, Elizabeth House, Church Street, Stratford upon Avon, Warwickshire, CV37 6HX Switchboard 01789 267575, Direct 01789 260333, Fax +44 01789 260330 email [email protected]
APPENDICES: (to follow..)
Arups Assessment of the Strategic Transport Assessment Viability Assessment by CB Richard Ellis Colliers Assessment on Retail Impact Economic Impact Assessment commissioned by AWM
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