Agenda No 3 AGENDA MANAGEMENT SHEET

Name of Committee Cabinet

Date of Committee 19 June 2008

Report Title Government Consultation: 'Eco-towns - Living a greener future'

Summary Government is consulting on its document ‘Eco-towns: Living a greener future’ including its short-list of 15 preferred locations for ‘eco-towns’. One of these is the Long Marston former MOD depot, the subject of a bid to Government last year by the landowners. The 12 week consultation period ends on 30 June and is to be followed by publication of a sustainability appraisal and a draft planning policy statement later in the summer for further public comment. The final planning policy statement, to be published later on in the year, will establish the principle and location of eco-towns. The Director’s report recommends an appropriate response to the consultation.

For further information Andy Cowan please contact Chief Planner Tel. 01926 412126 andycowan@.gov.uk

Would the recommended Yes/No decision be contrary to the Budget and Policy Framework?

Background Papers None.

CONSULTATION ALREADY UNDERTAKEN:- Details to be specified

Other Committees ......

Local Member(s) ...... (With brief comments, if appropriate)

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Other Elected Members X Councillor P Barnes Councillor M Jones Councillor P Morris-Jones for information Councillor B Stevens Councillor Mrs I Seccombe - The proposal of this Eco Town has considerable impact on WCC and its planned service delivery for the future. Concern over the redirection of strategic funding and the priority changes that may be necessary is just one of very many issues this raises, including problems of infrastructure, sustainability and appropriateness of this site for this size/type of growth.

Cabinet Member X Councillor C Saint – comments incorporated. (Reports to The Cabinet, to be cleared with appropriate Cabinet Member)

Chief Executive ......

Legal X I Marriott – comments incorporated.

Finance ......

Other Chief Officers X Chief Executive and all Strategic Directors

District Councils ......

Health Authority ......

Police ......

Other Bodies/Individuals ......

FINAL DECISION YES/NO (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 ......

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Agenda No 3

Cabinet - 19 June 2008

Government Consultation: 'Eco-towns - Living a greener future'

Report of the Strategic Director for Environment and Economy

Recommendation

That the response to the consultation document: ‘Eco-towns: Living a greener future’, includes the advice that Government should re-think its approach to reconciling housing growth and affordability with climate change objectives as set out in the consultation document, for the reasons explained in the conclusions of the Director’s report. In outline, the Council:-

1. Considers that these objectives can better be reconciled in the sustainable redevelopment and expansion of existing cities, towns and communities being brought through the statutory development plan process, starting with the Regional Spatial Strategy Phase 2 Revision and then followed through in local development frameworks.

2. Believes that the construction of an ‘eco-town’ at Long Marston Depot would undermine agreed strategic policy to bring about a ‘step-change’ in development of the Region and Sub-region, widen the gap between the less prosperous and more prosperous parts of the County, and bring about a fundamental and inappropriate change in the character of this rural area and, therefore

3. Concludes that the proposal for an ‘eco-town’ at Long Marston Depot should not be taken forward to the final list of proposed ‘eco-towns’.

1. Introduction

1.1 The Council’s engagement in the spatial planning for housing growth in the Region and the Coventry Solihull Warwickshire Sub-region is an important part of the background against which this consultation has to be viewed. In December 2007, the Regional Assembly presented Government with the culmination of two years work with its regional and sub-regional partners, including the County Council, to produce new housing growth proposals for the Phase 2 Revision of the Regional Spatial Strategy (RSS). However, Government has since declared that these proposals do not take account of higher levels of new housing development that it considers are needed to increase general affordability and has commissioned a separate study to identify

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where more housing could be built. This study is not likely to report until the end of the year, further delaying the Public Examination of the RSS proposals until Spring 2009 at the earliest.

1.2 The national context for this particular regional train of events was the publication last summer of the Government’s Housing Green Paper. Its main thrust is to increase the general affordability by increasing the supply of housing and, at the same time, address climate change. It launched the idea of ‘eco- towns’ as a means of fulfilling these objectives at the same time, inviting schemes to be submitted direct to Government (on a confidential basis) from anyone who could deliver a town of 5-20,000 new dwellings that met a list of ‘eco’ criteria.

1.3 The need for national level reconciliation of housing/ economic growth objectives with climate change objectives by Government has already been raised by the Council in consultation responses over the past year i.e. Cabinet meetings: 27 Feb 07 – Planning and Climate Change; 19 July 07 – Planning White Paper; 27 September 07 - Housing Green Paper; 13 March 08 – Planning for Sustainable Economic Development.

1.4 As part of this national ‘eco-towns' initiative, a proposal to develop a new settlement of 6,000 dwellings was submitted to the Government last Autumn by the private landowners of a 240 hectare site, largely comprising the former MOD Depot at Long Marston. On 3 April 08, Government published a short-list of 15 preferred locations for eco-towns that included the Long Marston proposal. (The full list is set out in Appendix A). In addition Government published a consultation document on 3 April, titled ‘Eco-towns: Living a greener future’, canvassing views by 30 June 08 on the initiative, its benefits, scope for innovation, and 15 short-listed locations.

1.5 This report outlines the Government’s ‘eco-town’ consultation proposals (in section 2); the particular ‘eco-town proposals for Long Marston (in section 3); the strategic policy context (in section 4); infrastructure implications (in section 5); sustainability and affordability implications (in section 6); and conclusions (in section 7). Appendix A provides maps of the context and the site of the Long Marston Depot; Appendix B gives the full list of the 15 short-listed locations; Appendix C includes an extract of the Government’s appraisal of the Long Marston Depot location; Appendix D shows area of high risk flood areas affecting Long Marston Depot.

2. The Eco-town Consultation

2.1 Government’s consultation document: ‘Eco-towns: Living a greener future’ seeks views on:-

(i) “the way in which the eco-towns concept is being developed and the different potential benefits that an eco-town could offer”;

(ii) “how particular features such as green-space or innovative approaches to housing can best be developed in an eco-town”; and

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(iii) “preliminary views on the 15 locations going forward for further assessment” (Part 1, para.2), and

(iv) More specifically, views are invited on the inclusion of ‘Middle Quinton’ in the short-list; other “potential benefits or challenges” that (the Council) would wish to see addressed for this location and whether there are particular issues which (the Council) “would like to see proposals for this location address”. (p.29)

Comment:-These questions are unusually ‘closed’, directing the reader towards refinement of what is proposed and away from more fundamental issues. For this reason, the following text addresses these questions as part of its wider discussion of the issues.

2.2 The key criteria for eco-towns, set out in the Eco-towns Prospectus published by Government in July 2007, are reinforced in the consultation document i.e.

(i) Eco-towns must be new settlements, separate and distinct from existing towns but well linked to them. They need to be additional to existing plans, with a minimum target of 5,000-10,000 homes;

(ii) The development as a whole should reach zero carbon standards, and each town should be an exemplar in at least one area of environmental sustainability;

(iii) Eco-town proposals should provide for a good range of facilities within the town - a secondary school, a medium scale retail centre, good quality business space and leisure facilities;

(iv) Affordable housing should make up between 30 and 50 per cent of the total through a wide range and distribution of tenures in mixed communities, with a particular emphasis on larger family homes;

(v) A management body which will help develop the town, provide support for people moving to the new community, for businesses and to co-ordinate delivery of services and manage facilities. (NB. Government has since indicated that it will reserve the option of establishing a ‘new town development corporation’ for cases where substantial transport infrastructure investment is needed).

2.3 The essential difference between eco-towns’ and existing towns, it is argued in the document, is that they present the opportunity to be radical in design and create net benefits to sustainability rather than just mitigate negative impacts. It indicates the minimum benefits that should be provided, in particular, the following:-

(i) Zero carbon – over a year the net carbon emissions from all energy use within all buildings is zero by 2016 (e.g on average each dwelling in Warwickshire currently emits about 6 tons of carbon p.a.). Comment: This does not cover the carbon emissions from transport – which increases with greater car dependence.

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(ii) Climate Change – demonstrate that the town will be sustainable under present conditions and resilient against predicted change (e.g. in rainfall, temperature, etc).

(iii) Water Efficiency - aim for ‘water neutrality’ (i.e. water use in the general area post development is no greater than it was prior to the town being built).

(iv) Flood Risk – no development in high risk areas (flood zone 3) and limit medium risk areas (flood zone 2) to uses compatible with flood storage.

(v) Waste Management – lead in minimising and recycling and extract value from waste on-site using state-of-the-art technologies; waste management linked to energy production; zero construction waste to landfill; off-site treatment balanced by recycled construction material.

(vi) Green Space and Biodiversity – demonstrate provision of high quality green infrastructure and protection of habitats, generally covering 20% of the town area.

(vii) More Sustainable Travel – between homes, services and jobs within the eco-town, nearby settlements and large urban areas – involving modal shift from car to public transport, walking and cycling to the extent that half the households do not rely on a car.

(viii) Homes improved in quality and delivery – with 30-50% affordable housing; sites for self-build groups; more flexible and higher standards of sustainable construction.

(ix) Jobs – harnessing the employment potential of the locality, including that of eco-technologies, with a supply of high quality business space, links to existing employment clusters in the sub-region; overcoming labour constraints by providing family housing; life-long learning opportunities through links with local universities.

(x) Public Services – piloting and testing innovations in delivery of public services as well as making them more sustainable and responsive to climate change e.g. meeting the target for all new schools to be zero carbon rated; co-location of children and family services with schools; co-location of GP-led services with diagnostic and social care services.

Comment:-Generally, the Consultation Document does not explain why these characteristics should not be applied to all development. Moreover, the example of Vauban in Freiburg, Germany used in the consultation document is completely different in nature, size and infrastructure than, for example the proposed site at Long Marston. NB. Vauban is an urban district within the city of Freiburg, a university town of over 200,000 population in the southwest of Germany, well known for it’s excellent public transport – based on the expanding web of tram routes.

2.4 This consultation is the first of four key stages in the process of establishing eco- towns through the planning process i.e.

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(i) This current 12 week consultation on preliminary views on eco-town benefits and the short-listed locations;

(ii) Further consultation this summer on a Sustainability Appraisal, which will provide a more detailed assessment of the 15 short-listed locations, and a draft Planning Policy Statement.

(iii) A decision on the final list of locations with the potential to be an eco-town and the publication of a final ‘Planning Policy Statement on Eco-towns’ in Autumn 2008 (Part 1 - 6 and Part 4 - 2 and 3).

(iv) Planning applications for individual schemes in these locations will need to be submitted and decided on the merits of the proposal.

2.5 Comment:-This process would appear to preclude debate on the principle of eco-towns and, more significantly, their location at the Public Examination of the Phase 2 Revision of the RSS. In any event, on current timetables, both the principle and the locations of eco-towns will have already been decided in the new final Planning Policy Statement. The RSS Public Examination Panel’s conclusions on future levels of housing provision across the Region will therefore have to take ‘as given’ any eco-town proposals reaching the third stage in the process (i.e. set out in 2.3 above) and their remit confined to testing “.. the longer term issues that arise from eco-town proposals – such as the ultimate size of new settlements.” (para 5, Annex 6).

2.6 NB. Your officers are responding to a Department of Communities and Local Government (DCLG) request to make a technical input to the assessment work being carried out under to inform step 2) of the Government’s process (outlined in 2.4 above) on a ‘without prejudice’ basis. In particular, we are working on a joint scoping study (with officers from and Gloucestershire County Councils) for the transport assessment to be carried out by the potential eco-town developers of Long Marston Depot. DCLG have agreed to consider funding additional expenses we incur in this work. Generally, it is important that officers participate in the assessment process - on a without prejudice basis - not only to ensure that, as far as possible, it is carried out properly but also to make sure that all the Council’s requirements are taken into account before any decision is made for the eco-town project to proceed. The transport issues outlined in paragraph 5.3 below define the scope of this study. A copy of the Transport Scoping Study is available on the Warwickshire website.

2.7 Annex A of the consultation document “..assure(s) local authorities that include an eco-town in their future housing plans that it will, of course, contribute towards those future housing targets, which in most places are likely to be more stretching.” (Annex A, para 6). However, the notes to editors accompanying the Minister’s 3 April 08 press release indicate that Government will only be prepared to let local authorities with an eco-town in their area count “an appropriate proportion towards the local plan target” if their development plan housing provisions already go a long way towards helping to deliver the additional housing Government is seeking. (Note 5 to Editors).

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Comment:-This suggests that authorities will not be allowed to rely just on eco-town housing numbers to make up for any perceived shortfall between what they plan for and new Government targets i.e. permission to include eco-town housing numbers in local targets will be as a reward for increasing housing provision overall.

3. The Long Marston Depot proposal

3.1 The Consultation document includes (in Part 5) short descriptions of the “.. 15 bids going forward for further assessment”. The ‘bid’ of particular relevance to the County Council is the former Royal Engineers depot at Long Marston, named ‘Middle Quinton’ by its promoters and landowners - St. Modwen (194 ha) and the Bird Group (46 ha). A short description is included in Appendix C, along with the map of the other short-listed locations (and, for comparative purposes, the description of the other short-listed ‘bid’ in the West Midlands – ‘Curborough’ at Fradley, north-east of Lichfield on the A38 to Burton-on-Trent – for which a planning application has already be submitted).

3.2 The information on the short-listed bids essentially summarises the Government’s assessment and reasons for selecting them from the other 40+ bids. In relation to ‘Middle Quinton’, the potential benefits, challenges and constraints identified include, in particular:

(i) “substantial employment opportunities”, claiming “the site is already a significant employment centre”;

(ii) “2,000 affordable housing units” in the context of high demand for rented affordable housing and low current rates of supply;

(iii) “.. no major issues regarding the strategic road network but the scheme would need to develop and support public transport links to surrounding centres and particularly Stratford-upon-Avon”;

(iv) a “SFRA (strategic flood risk assessment) to make sure there is no flood risk on site”.

3.3 Comments:-This information is, however, somewhat misleading as to the advantages of the location. In relation to:

(i) The site may be a significant employment centre (i.e. perhaps 500 jobs including many in activities subject to temporary permissions) in comparison with the small employment needs arising in the local villages, however, it cannot be regarded as significant in relation to the employment needs/ expectations of a town of 6,000 dwellings (i.e. about 4-6,000 jobs).

(ii) Affordable housing is a district-wide problem in a district with a widely dispersed population. Concentration of affordable housing provision in one location would only address the shortage in the central part of the District whilst undermining the supply of workers in service and tourist industries elsewhere.

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(iii) The glaring issue missed is that there is no part of the strategic road network within 7 or 8 miles (i.e. via C and B roads to A46 or A44). Long Marston Depot and the main road access is just the B4632. This is a serious and potentially fatal short-coming in the Highway Agency contribution to assessment of this location. NB. The ‘Curborough’ location is cited as having strategic road access problems (because of congestion) to the A38 dual carriageway trunk road – but, in common with virtually all the other short-listed locations, at least it is on, or very much closer to, the strategic road network than Long Marston Depot.

(iv) The strategic flood risk assessment (SFRA) for the County (carried out by Halcrow in connection with local development document preparation) shows that the Long Marston Depot site and its immediate surroundings are significantly affected by high risk flooding areas. (See extract in Appendix D). Since this SFRA is a ‘level 1’ assessment and it is to be expected that the more detailed exercise required will reveal even more of the site falling within the ‘high risk zone 3a’ (precluding most built development). There is also potential for this to be exacerbated by site contamination.

4. Strategic Policy Context

4.1 When the County Council’s Cabinet considered the Housing Green Paper on 27 September 2007, it concluded that, at that stage in the Phase 2 Review of the Regional Spatial Strategy, there appeared to be no need for an ‘eco-town’ in Warwickshire to assist in delivering sufficient housing to meet the latest household projections. At the same meeting, Cabinet endorsed the Coventry Solihull Warwickshire Forum (CSW Forum) advice that the levels of housing growth implied by the latest Government household projections can be accommodated most sustainable by focussing growth on existing towns in the corridor from / through Coventry to /Leamington and also Rugby. Moreover, it accepted that the districts of Stratford-on-Avon and are much less sustainable locations for large scale housing and associated growth because of their dispersed settlement patterns. This advice was subsequently taken on-board by the Regional Assembly who included it in the Draft Phase 2 Regional Spatial Strategy (RSS) Revision proposals submitted to Government in December 2007. These proposals were endorsed by Cabinet on 24 April 08.

4.2 The existing Regional Spatial Strategy, approved by Government in September 2004 (currently going through a three-phase review) provides for housing growth in rural areas – such as Stratford-upon-Avon District – to be limited to local needs and the Regional Assembly’s Draft Phase 2 Revision proposals seek to maintain this element of the strategy by providing for 5,600 dwellings to be built in the district over the 2006-26 period. At 6,000 dwellings, the proposed eco- town at Long Marston Depot would provide half the existing numbers of dwellings in Stratford-upon-Avon or Warwick but on about an eighth of the area that these existing towns occupy. In terms of housing growth, it would be equivalent to the total housing growth experienced in the whole Stratford-upon-Avon District over the past 10 years. The District and County Councils, CAW Sub-regional Forum and Regional Assembly propose that the

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total housing growth in the District over the period 2006-26 should be 5,600 dwellings.

4.3 Following the Regional Assembly’s submission of its proposals for the Phase 2 RSS Revision on 21 December 2007, Baroness Andrews, wrote to the Chair of the Regional Planning Partnership (7 January 2008). In her letter, the Minister pointed out that the Government was not satisfied that full account had been taken of its policy to improve affordability by increasing housing supply and it was therefore appointing consultants to look at ways of topping-up the numbers of houses being proposed by the Assembly. The results of this separate study are not now expected until late this year – with the result that the Public Examination of the Draft RSS Phase 2 Revision will be pushed back into 2009. However, the process proposed by Government for dealing with eco-towns can be expected to preclude Public Examination Panels from questioning either their principle or their location. (See Para. 2.5 above). Moreover, local authorities should not expect an eco-town’s housing numbers to be regarded by Government as contributing to their overall housing targets unless they have taken on-board part of the ‘topping-up’ proposals following the Baroness Andrews’ letter. (See Para. 2.6 above). Consequently, it is possible that if ‘Middle Quinton’ goes ahead, Stratford-on-Avon District Council may be faced with not only its current draft RSS housing figure of 5,600 and the eco-town of figure of 6,000 but also an additional number of dwellings arising from the Baroness Andrews ‘top-up study’. This would exacerbate the contradiction of and adverse impact on the strategy embodied in the Regional Assembly’s proposals for the CAW Sub-region and strike at the heart of the RSS ‘step- change’ strategy of focussing most housing growth on the major urban areas.

4.4 The question of what use Long Marston Depot should be put to has been addressed over the last 15 years. The strategic planning issues raised by the large redundant sites of former hospitals, airfields and military depots were recognised in the Warwickshire Structure Plan 1996-2011 (WASP). One of the very few WASP policies acknowledged by Government as having not been overtaken by events (i.e. ‘saved’) is policy GD.7 which was designed to address the issues raised by these very large ‘previously developed sites’. It specifically precludes development for strategically significant purposes that are planned to be met elsewhere in Warwickshire. Policy GD.7 provided the framework for Stratford-on-Avon District Local Plan’s policy CTY18 - the specific policy on the Long Marston Depot. This, in turn has provided the basis for the District Council to work on a Master Plan for the Depot site, in conjunction with the local community and St Modwen. This collaborative master planning process has not entertained the notion of a new settlement of the scale of the proposed ‘eco- town’, though a ‘linked-settlement’ of perhaps 3,000 dwellings had been one of several options explored by the agents acting for St Modwen.

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5. Infrastructure Implications

5.1 The infrastructure needed to support a new town of this scale falls into four broad categories: transport; flood alleviation; schools; and health and community facilities. The agents for the promoters are suggesting that the developers’ contribution to infrastructure costs would be “.. well in excess of £100m”. In terms of County services, transport and schools are essential to any town and even more so to an eco-town that has a greater reliance on jobs and services located elsewhere. Alternatively, a more balanced town with a higher provision of jobs and services will tend to be a focus for the concentration of local services as the eco-town takes on a ‘centre role’. A preliminary strategic assessment of the infrastructure implications of the ‘Middle Quinton’ eco-town proposal for Long Marston Depot follows.

5.2 The Long Marston Depot site is 7 miles from the nearest strategic highway and similarly remote from the strategic rail networks and services. In addition, the current infrastructure suffers from poor accessibility to both the strategic transport networks and the local towns of Stratford and Evesham. The location of Long Marston Depot is such therefore that it will not easily become an eco- town as far as transport is concerned and there is significant risk that unsustainable and environmentally damaging patterns of travel will become established by the residents of the new settlement. (NB. Government is looking for dramatically reduced reliance on cars for people who live in eco-towns).

5.3 At this stage (i.e. in advance of extensive and detailed studies), the broad strategic transport requirement needed to sustain an ‘eco-town’ of the scale proposed at Long Marston can be expected to include the following key elements:-

(1) Public Transport: It should be born in mind that the level of public transport provision for an eco-town should be expected to be significantly higher than would be expected to serve a conventional settlement of this size – especially given the Government aspiration for half the resident households not to need access to a private car. However, as a starting point (and in the absence of a full transport assessment), the conventional minimum requirements for a new settlement of this scale are likely to be as indicated below:-

(i) Whilst re-instatement of the railway line from Long Marston to Stratford- upon-Avon Station might be feasible, albeit at a high cost and severe disruption, provision of passenger services (as suggested by the promoters) is likely to also require substantial financial revenue support.

(ii) Although the alternative of enhancing the stations at Stratford-upon-Avon and Honeybourne and providing a frequent and fast bus service (in parts on dedicated/guided routes) to the two stations would provide a public transport access to nationwide rail services (e.g. to London Paddington and Birmingham New Street), it would be unlikely to meet the level of service consistent with an eco-town.

(iii) Enhancement to Honeybourne railway station and a substantial contribution to improve infrastructure and train services on the Cotswold Line, especially to London but also to Evesham and Worcester since,

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given the existing road network, a bus/train combination is likely to be the most effective way of connecting ‘Middle Quinton’ to Evesham and the west will be by public transport.

(iv) A substantial contribution to construction of Stratford Parkway railway station and to an improved and more frequent train service on the Stratford-Birmingham line.

(v) A substantial contribution to the construction and operation of a southern park and ride for Stratford.

(2) Highways:

(i) A western by-pass of Stratford-upon-Avon to be constructed to establish the necessary standard of road connection with the primary road network i.e. from the B4632 to the A46 west of Stratford. (NB. This may, in turn, make development of land at Stottery on the west side of Stratford-upon-Avon more, rather than less, likely).

(ii) Improvement to the B4632 between Long Marston Depot and Stratford-upon-Avon.

(iii) Improvement of the Greenway to provide a high quality cycle and pedestrian link to Stratford or its replacement if it used for a public transport (rail/guided bus) link.

(iv) Between Evesham and the Cotswolds transport is mainly dependent on negotiating C and B roads which pass through historic villages to access the A46 and A44. This is likely to give rise to a demand for local road improvements and traffic management costs that can be expected to be both substantial and on-going. Improvements may be necessary to the B4632 and B4035 as they provide the best route to connect Long Marston Depot to Evesham by road. (NB. These are, of course matters, for Gloucestershire CC and Worcestershire CC).

(v) Short, medium and long term arrangements for the management and routing of construction traffic, taking into account the scope for rail-based movements and the existing local highway network, including HGV restrictions (e.g. on bridges) in villages and towns along routes from the strategic highway network.

5.4 Lack of existing transport facilities to build upon will have significant implications for the phasing of transport investment and service support. To give the best chance of promoting sustainable and environmentally benign travel habits it will be important that attractive and effective public transport links to and from the eco-town are in place at the start of its occupation. This will be very expensive in terms of revenue subsidy required because at least initially the public transport will suffer low patronage levels. Prolonged and high levels of revenue support from the developers and/or Government for public transport provision will therefore be essential.

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5.5 Similarly, the scale and programming of services to young people and families, particularly school provision, for the residents of an eco-town at Long Marston will need to be explored in more detail and coasted. However, conventionally, a new settlement of 6,000 dwellings would require a 6 form-entry secondary school, fed by 3 x 2 form-entry primary schools, on completion (at current prices, costing around £60m-£75m). In practice, the arrangements for provision of primary and secondary education for the children living in the ‘eco-town’ in its early and middle stages of development are likely to impact on the existing provision in and for surrounding towns and villages. Lack of capacity at existing schools in the area will require early instalments of new school provision. This is also likely to apply to police, fire and rescue and other basic health and community services. In any event, the County Council would be likely to take the opportunity to provide for children’s education in the context of the ‘Primary Strategy for Change’ and ‘Building Schools for the Future’ programmes with integration of service provision within the wider community.

5.6 The ‘Strategic Flood Risk Assessment’ (level 1) commissioned by the CAW Sub-region’s eight local authorities indicates that there is a high probability that parts of the Depot and its surroundings site will flood (see Appendix D). The promoters are aware of the need for a detailed ‘Flood Risk Assessment’ of the site and locality to be carried out in conjunction with the Environment Agency before any planning applications can be contemplated. This should identify what mitigation works and/or restriction of the extent of development is necessary. In addition, a ‘Water Cycle Study’ is likely to be required to demonstrate how the water supply is to be secured to the development. This again will represent a significant cost to be carried by the development.

6. Sustainability and Affordability Implications

6.1 In relation to the land use distribution in a conventional town, the 240 ha. site of the ‘Middle Quinton’ proposal is very probably not big enough to provide sufficient land for a sustainable balance of employment, education, parks, shopping and other community services as well as 6,000 dwellings. In addition, space for development is likely to be squeezed by flood prevention and mitigation areas and the provision of on-site renewable energy features (wind turbines, solar panels etc) may tend to keep housing densities down. As a consequence, the high level of trips to jobs and services elsewhere are likely to damage the ‘eco-towns’ sustainability credentials.

6.2 To make a 6,000 dwelling ‘eco-town’ in this location sustainable, a significantly larger site area and/or very high average housing density is likely to be necessary to get the land uses more in balance – including a significant area of land for employment uses. Assuming a more efficient layout than in existing towns, the 240 ha Long Marston Depot site would probably have to be enlarged by at least 100 ha to provide for the range of land uses/services that would be expected of a town with a population of 12-14,000. (The former Long Marston airfield site to the north might provide scope for expanding the proposed site on this scale – although it also has a high risk flooding constraint - see Appendix D).

6.3 Part of the benefit of an ‘eco-town’ is claimed to be a high level of ‘affordable’ housing provision (i.e. ‘low-cost’ and ‘part purchase’ as well as social housing).

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In this instance, the promoters offer 30-50%. At its lowest level this would amount to an average of 90 affordable dwellings p.a. over 20 years – compared to the annual average of 170 built in the whole District in the past four years. Set alongside this clear benefit, there are a series of linked questions: in particular - where the residents of affordable homes are likely to find employment? Whether they will be able to afford to commute out-of-town to other places for work and basic services? And what impact would there be on labour supply for public and private services across the District if affordable housing is concentrated at Long Marston? Stratford-upon-Avon town itself has a significant miss-match between high house prices and low wage levels which is reflected in its high levels of in and out commuting (e.g. with about 60% of the resident workforce commuting out of the town to work and nearly 60% of the town’s jobs carried out by in-commuters). In this context, focussing affordable housing provision at Long Marston Depot is likely to increase in-commuting to Stratford-upon-Avon rather than contribute to a more sustainable relationship between housing and employment across the District.

6.4 Building a town from scratch is inevitably more expensive than expanding an existing town where development can be connected to (up-graded but) existing infrastructure and services. The more remote the location is from existing towns, the greater the initial costs. ‘Middle Quinton’ will be no exception. Moreover, as an ‘eco-town’, the proposal’s credibility will rely on advanced means of reducing its carbon footprint. However, if on-site jobs and services are limited then public transport facilities will need to be more high-tech (as the promoters accept) but also more expensive - than conventional solutions. Infrastructure capital costs could easily be two or three times the £100+m figure indicated by the promoters with additional high levels of revenue support required to establish and keep services viable. In addition, the comprehensive introduction of ‘eco-features’ such as higher specification of insulation and on- site or local renewable micro-energy production could add at least £20k to the average cost of each dwelling.

6.5 On this basis, the additional costs of infrastructure and eco-features would take the medium house price in the District (£235k at mid 2007 - Land Registry) to well over £300k per dwelling. A premium of this order would be a disincentive to both house-builders and first time buyers and unlikely to improve general housing affordability in south Warwickshire. However, to make it more affordable – to carry the burden of both housing costs and infrastructure – the size of the town would have to be increased, perhaps doubling the number of dwellings to around 12,000 – similar to the existing dwellings in Stratford-upon-Avon or Warwick. This in turn would require an even larger site area – perhaps four times as large (1000 ha) as the site of the current proposal.

6.6 Of course, whatever the dwelling target chosen for the eco-town (and the associated date), the town can be expected to generate household growth, probably at a rate much higher than existing towns (if past new town experience is anything to go by). Assuming that this growth is not to be ‘over spilled’ elsewhere, then the expectation is that the eco-town would need to expand to reflect this. It follows that the scale of the town, once started, will inevitably increase, creating demands for more services and for those services to the wider area being concentrated in the eco-town as the most efficient point for delivery.

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6.7 Of particular concern, looking over the longer term, an eco-town in this location is bound to be a new focus for private and public investment and running costs that can be expected to distract from the RSS ‘step-change’ at regional and sub- regional levels and from the Council’s aim to ‘narrow the gap’ between the quality of life in the northern and southern parts of the County. At more local level, the quality of life in southern Warwickshire can be expected to take on more of the characteristics of urban living – where higher levels of public and private services may well become available but the inevitable economies of scale will cause them to gravitate towards the eco-town and away from the numerous small towns and villages where still most of the area’s population will be living.

7. Conclusions

7.1 The need for eco-towns is justified by Government on the basis of bringing together its objectives to increase general housing affordability through increase housing supply and address climate change with new design and technical features, built-in from the outset. This is clearly not a ‘need’ that is particular to Warwickshire, the Coventry Solihull Warwickshire Sub-region or the West Midlands Region. It is a national need applicable to everywhere in the UK that is, in effect, seeking to reconcile some of the inherent conflicts between the Barker Review of Housing Supply (2006) and the Stern Report on Climate Change (2007). The need for national level reconciliation of this short and long term economic advice (respectively) has already been raised by the Council in its responses to national planning policy consultations over the past year. Therefore, any such attempt in this direction is to be welcomed.

7.2 However, the validity of achieving this reconciliation in the single concept of ‘eco-towns’ as “..new settlements, separate and distinct from existing towns ..” has to be demonstrated in each instance that it will be both sustainable and affordable. Without this, the results are likely to be exactly the opposite to those intended e.g. expensive housing estates, in inaccessible areas, with a large carbon footprint, requiring long-term support from the taxpayer. It is significant that the Consultation Document is not able to cite - among the many case studies to which it refers - any example of an existing ‘eco-town’ which is a new settlement, separate and distinct from existing towns. Moreover, whilst the Consultation Document draws most of its case study examples from schemes for the redevelopment and expansion of existing towns and cities, it does not consider the application of eco-features to all new development as an alternative to ‘eco-towns’.

7.3 The development of a 6,000 dwelling ‘eco-town’ at Long Marston Depot in the southern-most part of Warwickshire cannot be regarded as being compatible with the existing or emerging Regional and Sub-regional spatial planning strategies to which the Council has given its fullest support over the past 2/3 years. In particular, the Council, along with its Sub-regional partners has concluded that Stratford-on-Avon District (together with North Warwickshire Borough) have so dispersed settlement patterns that they are unsuitable for accommodating further large scale housing growth.

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(i) At best, therefore, this proposed ‘eco-town’ will be a distraction from the RSS’ step-change and the focus of growth at the Sub-regional level on the North-South Corridor from Nuneaton through Coventry to Warwick/Leamington and to Rugby.

(ii) At worst it will undermine our Regional, Sub-regional and corporate strategies by diverting private and public investment away from areas needing regeneration and, in so doing, widen the gap in the quality of life between the north and the south of the County.

7.4 In this context, the ‘eco-town’ would clearly be in the wrong place and, in any event, unnecessary given the commitment of the Council and its partners to support and deliver the regeneration of the Region’s cities and optimise both sustainability and affordability in the development needed beyond them. It is the inevitable consequence of adopting an approach for establishing ‘eco-towns’ that bypasses the unusual statutory development plan process for determining the scale and broad location of housing growth through the Regional Spatial Strategy, especially its robust and independent Public Examination stage.

7.5 Notwithstanding this fundamental policy objection, Government could change the strategic spatial planning policy through a national planning policy statement on eco-towns and provide for the principle of an ‘eco-town’ in the Long Marston Depot location. In such a context, Government needs to be advised of the likely implications in terms of infrastructure, sustainability and affordability set out in parts 5 and 6 of this report. In particular:-

(i) The high costs we expect to be associated with providing a proper connection to the strategic highway network and long term commitment to revenue support for extensive public transport investment and services;

(ii) The early provision likely to be required for schools and other community service provision and the establishment of public transport services;

(iii) The increase in site area likely to be needed to provide land for employment and other services to reduce the need for residents to have to travel out of town for jobs and basic services elsewhere – to minimise the eco-town’s carbon footprint;

(iv) The inevitable increase in scale of the ‘eco-town’ over the longer term to produce the economies of scale necessary to make it affordable to residents and viable for service providers and to accommodate its own expected high rate of household generation; and

(v) the financial guarantees and commitments from Government and the landowners/developers necessary to underwrite the consequences of any potential lack of sustainability and affordability (i.e. in the provision of jobs, infrastructure and essential services) that would otherwise fall on local government.

7.6 In conventional terms alone, this preliminary list questions the financial ability of the developers to fund the necessary infrastructure for a conventional new settlement of this scale from enhanced land values – let alone the higher costs

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that would be associated with an eco-town – without substantial long term public subsidy.

7.7 Even if an ‘eco-town’ at Long Marston Depot was able to deliver the objectives of affordability and climate change resilience set by Government, it would be at the price of turning the location from being relatively inaccessible to one that is much more accessible. Two main consequences are likely:

(i) It is inevitable that there would be a fundamental change in the character of the southern part of the County - from one associated with ‘Shakespeare Country’ of widely dispersed small market towns and historic villages to one more akin to that of rural areas situated next to bigger towns and cities. So, whilst an ‘eco-town’ may bring more services to the area they will inevitably be concentrated in the ‘eco-town’ making the residents of existing towns and villages only better off if they are able to travel to the ‘eco-town’ to use them.

(ii) A concentration of affordable housing in the ‘eco-town’ would exacerbate existing dislocation between homes and jobs in the district, both by attracting service industry employers who would draw workers away from other locations in the district and by creating a satellite commuter settlement at Long Marston Depot for Stratford-upon-Avon’s service industry workers.

PAUL GALLAND Strategic Director for Environment and Economy Shire Hall Warwick

9 June 2008

Cabinet/0608/ww1 17 of 17 Appendix A of Agenda No 3

Cabinet – 19 June 2008

Government Consultation: 'Eco-towns - Living a greener future'

Context – Map 1

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Context - Map 2

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Site – Map 3

Cabinet/0608/ww1a A3 of 3 Appendix B of Agenda No 3

Cabinet – 19 June 2008

Government Consultation: 'Eco-towns - Living a greener future'

Full short-list of Eco-town preferred locations published by Department of Communities and Local Government on 3 April 2008 (report author’s underlining and numbering):-

1. Bordon, Hampshire

2. Coltishall, Norfolk

3. Curborough, Staffordshire (i.e. Fradley)

4. Elsenham, Essex

5. Ford, West Sussex

6. Hanley Grange, Cambridgeshire

7. Imerys, Cornwall

8. Leeds city region, West Yorkshire

9. Manby, Lincolnshire

10. Marston Vale and New Marston, Bedfordshire

11. Middle Quinton, Warwickshire (i.e. Long Marston Depot

12. Pennbury, Leicestershire

13. Rossington, South Yorkshire

14. Rushcliffe, Nottinghamshire

15. Weston Otmoor, Oxfordshire

Cabinet/0608/ww1b B1 of 1 Appendix C of Agenda No 3 Cabinet – 19 June 2008

Government Consultation: 'Eco-towns - Living a greener future'

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West Midlands – MIDDLE QUINTON Stratford-upon-Avon, Warwickshire

Description The eco-town proposal comprises a 240ha brownfield site 6 miles to the SW of Stratford upon Avon between Long Marston and Lower Quinton. It is a former MoD Engineers depot with extensive warehousing, a rail system and a rail (freight use) connection to the main Worcester-Oxford- London line.

Proposed Benefits

A scheme of at least 6,000 zero carbon homes on previously developed land, with substantial employment opportunities, affordable housing and community infrastructure, including up to four schools, health care and retail facilities and high quality public transport links to surrounding towns and villages, all supported by leading edge environmental technology. [Housing Affordability Pressure – Very High.

The scheme would deliver 2,000 affordable housing units in comparison with current delivery of 170 annually and 3,000 households on waiting list. Stratford experiences very high levels of demand for rented accommodation in relation to its role as an international destination – an issue recognised in the Stratford World Class vision initiative.

Initial Summary of Challenges and Constraints

Environment The scheme will need to be developed with design sensitivity to its setting close to Cotswolds AONB and suitable mitigation measures. Would look for an SFRA to make sure there is no flood risk on site. Capacity of existing sewage network unlikely to be able to cope. The scheme will need to include a contaminated land survey and to carry out remediation sustainably.

Transport No major issues regarding the strategic transport network but the scheme would need to develop and support a substantial improvement to public transport links to surrounding centres and particularly Stratford upon Avon.

Employment The site is already a significant employment centre with scope for expansion around proposed eco-town technologies including recycling and sustainable construction. Conservation and historic constraints Historic settlements, listed buildings and landscape issues would need to be safeguarded and enhanced as the scheme is developed.

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West Midlands – CURBOROUGH Lichfield District Council, Staffordshire County Council

Description

The eco-town proposal is for a 314ha site, 7 km NE of Lichfield, part of former Fradley airfield and is 15km from Burton and 35km from Birmingham. Two existing residential communities lie to north and east – Fradley Village and South Fradley. A brownfield site with hardstanding and old airfield buildings. The potential for major new development in this broad location was previously identified in the Staffordshire and Stoke on Trent Structure Plan 1996-2011 although the relevant policy was not saved.

Proposed Benefits

A new community comprising 5,000 dwellings, secondary and primary schools, commercial, retail and community facilities; a new A38 junction, two new road links to Lichfield, a park and ride, and pedestrian/cycle provision; Eco-energy Park, and sports facilities.

Housing Affordability Pressure – Very High. An eco-town scheme would supply around 2,000 affordable houses over 10 years in comparison with recent annual supply in Lichfield of 100 and a housing waiting list of 3,000 households.

Initial summary of Challenges and Constraints

Environment There are high existing environmental pressures in the area which transport infrastructure for the scheme would need to take into account. Some flooding issues (two watercourses run through the site). Issue with water quality. Lichfield waste water treatment infrastructure would need upgrading.

Transport The scheme will need to develop proposals for sustainable and high quality public transport links to the eco-town, particularly taking account of existing congestion. The A38, in particular, would require a strategy to cope with additional traffic generated from the development.

Employment 7,000 jobs will be achieved from development at Fradley Park employment area (one of the largest employment areas in West Midlands), with potential for further growth which could reduce travel to work problems. Conservation and historic constraints Airfield and listed buildings. Historic canal features bordering the site will need to be safeguarded.

Cabinet/0608/ww1c C3 of 3 Appendix D of Agenda No 3

Cabinet – 19 June 2008

Government Consultation: 'Eco-towns - Living a greener future'

Flood Risk Map Extract – Long Marston Depot area

Source: WCC Strategic Flood Risk Assessment – Level 1 (Feb 2008) by Halcrow Group Limited.

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