Matter 3 Part B2 ECO TOWN

Matter 3 Strategy and locations for major growth in the NPA (policies 9 and 10, and Appendix 5), including consideration of related access & transportation issues (policy 6) and other infrastructure issues Part B MATTER 3 ITEM B-2 Part B Old Catton/Sprowston/Rackheath/Thorpe St Andrew growth triangle (part policy 10 and appendix 5) Soundness of the proposal B2 Is this strategic allocation justified, effective and consistent with national policy? No The concentration of development in this sector of the NPA is unjustified because the location is remote from the employment sources, it was selected because of the ECO Town, the infrastructure costs of development are unjustifiable. It will also increase the urban sprawl of the suburbs and draw in an undesirable proportion of available investment. This will be to the detriment of the remainder of Norfolk 1. The origins of the ECO town at NORWICH The decision to launch an initiative to create ECO communities was taken by the Labour Government principally through the office of the Deputy Prime Minister and later brought into the public domain following a headline visit to Sweden by Gordon Brown. The essence of these developments in Europe were re-generation schemes involving run down or de-industrialised urban locations where by linking high density, low energy housing with good facilities, they were able to reduce the carbon footprint of residents. However there was a marked difference between these and the plans put forward in this country. Here the sites were largely rural in nature and many were not brownfield sites as proposed by the PPS. There were originally a list of some 57 locations and the reasons most of these would be excluded would be equally applicable to Rackheath. A report in the Independent newspaper at the time noted that the only real difference was the level of high profile celebrity opposition which some locations could muster. Rackheath which despite early claims had been returned to agriculture was a not a brownfield site. Disused airfields were a favoured choice, many of them still in state ownership. The land at Rackheath was used as a hostilities only American Base and is now owned by German interests. The proposal for an eco town at Coltishall in Norfolk was put forward in 2007 by a developer following the closure of RAF Station in December 2006. The Government accepted this into the programme and it was was still the preferred solution in April 2008 when Caroline Flint launched Eco-towns – Living a greener future.1 The Coltishall plan 2 was eventually abandoned, apparently when the developer, withdrew. In July 2008, a review of ecotowns described as Session 2 of the eco- challenge had excluded Coltishall but still contained no reference to Rackheath3 1 www.communities.gov.uk/documents/.../pdf/livinggreenerfuture.pdf 2 Appendix 2 Planning Daily 1st August 2008 This alternative scheme at Rackheath was promoted by the Department for Communities and Local Government. After comparing the merits of Rackheath and 4 Coltishall , the Department came out in favour of relocating the ECO town to Rackheath. The Greater Norwich Development Partnership was instrumental in facilitating this change. In an extract from the Encyclopedia Brittanica on-line the following report was submitted by Katie Daubney in August 2008. In it she said that ‘last week, the Greater Norwich Development Partnership (GNDP) put Rackheath forward for the DCLG eco-town programme. The timing in the middle of the summer break meant that this announcement had little impact. The eco-town at Rackheath in Broadland, north-east of Norwich, looked, she said, set to replace Coltishall as a contender on the government's shortlist.’ Also in November the Government responded to the Coltishall e-petition, with only 340 signatures and announced that they would be taking forward the alternative proposal of Rackheath. The time scale and the fundamental change represented here calls into question the reasons why Rackheath was any more suitable for this purpose than Coltishall, since most of the negative criteria applied equally to both. It certainly did not meet the requirements set out in PPS12. It was not a development of more than 5000 dwellings, the lack of infrastructure was common and Rackheath could not be considered a brownfield site as it had been returned to agricultural use shortly after the war. It is also worthy of note that it was incorporated into the ECO town plans before any of the criteria for its inclusion were agreed. The consultation on the Sustainability Assessment was not issued until November 20085 and a Water Study has only just been undertaken., though there still remain questions about its outcome. So by March 2009 when the Rule 25 Consultation commenced Rackheath had already been included in the Government’s ECO town programme. It is clear from the timing of these announcements and the way in which Government and Ministers drove these proposals that any subsequent consultation was meaningless. There has been no appraisal of this proposal which does not start with a presumption that whatever its merits, the scheme would go ahead. It was therefore not subject to any meaningful analysis and it has been progressively extended throughout the development of the Joint Core Strategy. The question now posed is whether or not this aspect of the Joint Core Strategy so distorted the overall outcome that it has rendered the whole process void. 2. The Rackheath Plan The decision to allocate the eco town to Rackheath may simply have been because it was within the Norwich Planning Area. Once the decision about Rackheath was taken the whole development plan was fast tracked through the system. The Greater Norwich Development Partnership had been 3 www.communities.gov.uk/documents/housing/pdf/ecotownchallenge.pdf 4 DCLG-Sustainability Appraisal and Habitats Regulations Assessment of the draft Planning Policy Statement: eco-towns – Addendum dated july 2009 5 www.communities.gov.uk/documents/planningandbuilding/pdf/greaternorwich.pdf created in 2006 in order to exploit the bid made by the Councils for Growth Point Status6. The creation of an extraordinary planning group combined Councils who in normal events are individually responsible for planning. None of these Councils had an LDF which met the requirements for this Growth Point designation but pursued the Growth notwithstanding and to the extraordinarily high levels which are contained in this JCS. They also did this without any public consultation. When it later appeared in the Joint Core Strategy it was presented as agreed policy. It also allowed the Councils to limit the debate at the responsible level to that of rubber stamping the decisions made beyond the democratic process by officers and a few members of other councils A legal opinion sough by the Local Government Association stated that if these housing commitments wer included within the housing targets there was no justification for them being fast tracked or even being given any other treatment that normal planning process. Therefore, to have rushed through the planning process within eighteen months and curtailed the usual development processes surely renders this process clearly unsound. This is pertinent in relation to Rackheath. North Norfolk District Council are not in the GNDP but the Council was instrumental in the decision in respect of the Coltishall eco project. The Coltishall airfield site is not in Broadland but almost exclusively in North Norfolk. It is also worthy of note that North Norfolk challenged this project on the basis that it was unsound. So why was it sound when presented as part of the Joint Core Strategy. This information about soundness was reported to Councillors in Broadland at an Extraordinary meeting held on 25th February 20107; despite the fact that this was accompanied by a letter from Natural England which stated that there was not sufficient certainty for them to consider it legally compliant with the HRA; despite this they later approved the JCS. 3. Credible evidence There are a number of documents provided by the GNDP which include consultants reports on Housing Viability An assessment of this evidence shows that the recommendations are not supported by the text and that the claims made in the JCS are flawed. High Density housing is claimed not to be a problem but the so called examplar will be constructed at a density which is double that in the surrounding rural area. This appears to be necessary to make financial justification of affordable houses. We overlook the fact that these settlements are going to be permanent at our peril and should not be swayed by short term priorities when considering whether or not these developments are appropriate. Energy This was a desk study which gave rise to the claim that the potential for renewable energy in the GNDP area was 177% of the demand. There is no practical way that 734 large wind turbines will be built around Norwich. An accompanying map shows that one of the unconstrained areas for wind turbines includes Rackheath which is on the Norwich Airport Flight path. The proposed CHP plant requires 88,000 tonnes of feedstock which is not quoted as annual but appears to be so. This is 6 Appendix 3 DCLG New Growth Points Norwich 7 Appendix 3 The Extraordinary Meeting of Broadland District Council dated 25 February 2010 Papers and minutes not available locally which destroys a large part of the rationale. No reference is provided for the material or the source but it has been suggested that this will be imported and brought in to a rail head. Even so the principle reason for using this as a power source is for its carbon neutrality, what is omitted is that it is also very inefficient and wastes much of the available heat resource.

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