WALBERTON ACTION GROUP

Welcome

Meetings

Conservation

Reports

News

Projects

Ford Ecotown

 New WAG submission on Ford Eco-Town

15 The Meadows

Walberton

Arundel

West Sussex

BN18 0PV.

Tel: 01243 551829

The Eco-towns Team

Communities and Local Government

Housing and Growth Programmes Division

Zone 2/G9 Eland House

Bressenden Place

London

SW1E 5DU.                                                                                        10^th February 2009.

Dear Sirs

                                               Ford Eco-town Proposal.

We write to express our continuing severe concerns upon the Ford Eco-town proposal and do so in response to the invitation set out on page 8, paragraph 35, of the PPS Eco-towns consultation paper.

This response follows our earlier letter of 24^th June 2008 which, by oversight, was not acknowledged within the Summary of April Eco-towns consultation responses, Appendix . The objections that we then raised are in the main still not satisfactorily resolved, and a copy of the letter is enclosed in which Walberton Action Group’s purposes are explained as you request on page 9 (36) of your paper.

Firstly, we attended the recent road shows by DCLG at Littlehampton and Yapton, but it was most disappointing that the purpose of the visit was not to debate and hear local opinion, but to try to generate support in principle for the Eco-town concept. The immediate point of interest is not that. It is whether or not the concept at Ford Eco-town is welcome, necessary, the best option, sustainable and compliant with the identified Government criteria. In our view, Ford Eco-town fails on numerous points.

We emphatically sustain our earlier objections on all counts, and we also have further critical and important matters to draw to your notice upon items specifically in the PPS paper. They are:

• Page 10(2.1) - New settlements are separate and distinct: it is self evident that Ford Eco-town threatens to subsume the local villages of Yapton, Ford and Clymping.  Ford Eco-town (FE-t) fails.

• Page 10 (2.1) - Eco-towns are well linked to higher order centres: the two closest developments are Littlehampton and Bognor Regis but neither satisfies the description of being higher order. Both are now in urgent need of regeneration themselves. FE-t fails.

• Page 13 (3.2) - Eco-towns are expected to provide……infrastructure such as schools, shops and good transport links: Ford proposals in all areas are at best aspirational and current plans are vague and unspecific. We refer here to the Ford Sustainability Appraisal page 40 (2.7.37) on the lack of clarity, and there can be little question that very little will be in situ at Day 1.  FE-t fails.

• Page 13 (4.1) - Eco-towns are most appropriate near to major centres of employment, retail and leisure: no such local major centres exist: our comments above upon Littlehampton and Bognor Regis are pertinent in this context also and the closest suitable major centres are Worthing and Chichester, both significantly distant from Ford. FE-t fails.

• Page 15 (4.7) - Eco-towns are resilient to………climate change: we note particularly the comments on page 22 (2.5.6 and 7) of the Ford Sustainability Appraisal. Additionally, the important issue is to focus upon - and properly respond to - the expert opinions that confidently anticipate water levels at dangerous levels as soon as 2026, a short time away.  FE-t fails.

• Page 16 (4.11) - Eco-towns demonstrate how access to work will be achieved and…as a minimum …..access to one employment…per new dwelling..by walking, cycling or public transport: notwithstanding the Ford Sustainability Appraisal, page 43, the Developers have absolutely no credible employment strategy to offer beyond ever changing speculative ideas. FE-t fails.

• Page18 (4.16) - Eco-towns support children walking or cycling to school safely and easily: no plans, at least in the early years, for local schooling and other most proximate schools have no available capacity. FE-t fails.

• Page20 (4.27) – The location should reduce and avoid flood risk: the Ford locality flooded in May 2008 and there is abundant proof of a deteriorating flood exposure ahead. It appears that this widely reported (surface water) flood, including broad radio and TV coverage, was omitted by Arun DC in the content of page 34 (2.7.10) in the Ford Sustainability Appraisal. FE-t fails.

·        Page 21 (4.29) – Eco –town should include a sustainable waste and resources plan: Renewable energy generation is an Eco-town requirement. The only plan on offer is unsustainable without external waste deliveries, and would involve importing 100,000 tonnes of waste by road in HGVs. The Ford energy proposal is unsustainable and it cannot be maintained by local supplies. FE-t fails.

Additionally, we have equally important views upon items in the Ford Sustainability Appraisal. We will not comment again on areas that have fallen into the points already above, but residual points are:

• Page14 (2.2.3) - We resolutely refute any assertion that the location is anything other than being dominated by high-grade green field land, producing vital harvests of prime quality for domestic consumption. Ford is by any available measurable standard very dubiously the largest brown field site in Arun District.

• Furthermore, the phased development plan seems to be founded upon initial construction being on agreed green field land, leaving until much later - if at all - any development of the runways and their peripheral brown field at the airfield location. Preservation of the runways is a deliberate strategy of the developers to facilitate the perpetuation of two weekday Car Boot Sales and a Sunday Market, all attracting hundreds of cars, and like numbers of people. The events are completely unsustainable and eco-unfriendly.

• Page 17 (2.3.6) – We cannot omit yet again stressing the nearly insuperable difficulties of any development prior to the upgrading of the A27 around Arundel. It has long been identified that improvements to this road are critical to any developments in the Ford area.

• Page 21 (2.5.3) – In 2008 a detailed bird survey, in cooperation with RSPB, extending over 5 months, was completed in the Walberton parish. It established that no less than 15 red listed species (birds of high conservation concern) were reported, many of which were in the parish area closest to Ford and less than 500 metres distant from Ford.

      The appendix to this letter is verbatim from a commentary on the survey.                                                                               

      We particularly draw to your attention that “….areas of such unique               

      (ornithological) habitat are……..increasingly scarce….and must be

      protected……..Large scale development in the close proximity will be

            devastating.”

• Page 39 (2.7.34) – Local opposition has been vividly demonstrated by the (circa) 10,000 signatories to the petition organised by the Communities Against Ford Eco-town (CAFÉ) campaign group delivered to No 10 Downing Street in October 2008.

• Page 40 (2.7.39) – We wholeheartedly endorse the preference of families to settle in housing and employment in both Littlehampton or Bognor Regis where their ties, roots and community support facilities are already developed.

• Page 41 (2.7.43) – We understand that the developers’ negotiations and/or discussions with rail or bus/coach services are at extremely embryonic stages, that nothing is even close to being agreed, and that their aspirations may not be converted into reality.

We have deliberately written only in brief detail upon the important issues that concern us, and hence the Walberton community. We are well aware that probably none of these issues is new to you. Nevertheless, we are very conscious that there are still no solutions available other than vague promises, statements of intent, and optimistic aspirational suggestions in an attempt to drive through the Eco-town development for the personal profit of the few, and the despoliation of the locality for the majority.

Many of the key features to which we have referred in this letter are also included in greater length and analytical depth in the paper presented to you by Communities against Ford Eco-town (CAFÉ). We have, because of this, purposely expressed our views more concisely. We fully and emphatically support the opinions of CAFÉ in their entirety. 

In summary, the locality is plagued by persistent and increasingly frequent transport congestion; local demand for affordable housing in proximity to Ford is very limited; other housing projects are better suited to the true needs of residents; the rail/bus/coach networks would call for a disproportionate capital injection to service the project, and climate change has not been realistically recognised in an area specially prone to acute problems in years ahead. Thus, the residents of Walberton are in unison with the many other local communities in once more urging you to reject in its entirety this unwelcome, unwanted, unsuitable and unsustainable proposal. We believe this project to be gravely flawed, and recommend that Ford be removed from the list of potential Eco-towns.

Yours faithfully

Peter Brown

Chairman

Walberton Action Group.

Copies for information: The Rt Hon Margaret Beckett MP, Minister for Housing and planning.

                                           Iain Wright MP, Parliamentary Under Secretary of State.

                                           Messrs Nick Herbert MP and Nick Gibb MP.

                                           &  Mr Ian Sumnall, Arun District Council.

                              Extract from memorandum of 20^th December 2008

                                             Written by Mr David Hart.

During the Spring and Summer of 2008, I had the pleasure of conducting a bird survey on the most southern area of Marsh Farm, Binsted. This land borders Tortington on the east and Yapton on the south. What a rewarding experience it was – the water meadows being such for many a long year. The hedges dividing the meadows can only be described as ancient and are unusually high with great width.

A total of 55 bird species were recorded in only 5 walks (March to July), the duration of each being only 2.5 hours. No less than twelve red listed species (those that declined by more than 50% in the last 25 years) were recorded. Also sparrow hawk, buzzard and hobby were seen on all surveys, which prove beyond doubt that these shy birds were breeding in, or close to, that area. It is also beyond doubt this area is of extreme importance to breeding birds.  For instance, reed warbler nests are a favoured host for the cuckoo, snipe could well be encouraged to stay and breed – there are now very few breeding pairs in Sussex. Water meadows are also a very important habitat for breeding lapwing. Had more time been available, I am certain more species would have been recorded such as water rail, and even bearded tits as the density of reed increases. The frequency of kestrel sightings would indicate a very high small mammal population. Extremely important to tawny and little owl both of which frequent this area.

The areas of such unique habitat are becoming increasingly scarce in Sussex and really must be protected. Even minor disturbance will have a huge impact on this very special area. Large-scale development in the close proximity will be devastating.

·        Attachment to letter dated 10^th February 2009 from Walberton Action Group.

------------------------------------

Appendix 1

Eco-Towns Team

Housing and Growth Programmes

Communities and Local Government

2/H9 Eland House       

Bressenden Place

London

SW1E 5DU                                                                                                    24^th June 2008.

Dear Sirs                                    

                                               Ford Eco-Town Proposal.

We write to express our strong concerns upon the Ford Eco-Town proposals. We do so in response to the invitation set out in the DCLG consultation paper (Para 3 on page 6 refers).

Walberton Action Group:

Walberton Action Group (WAG) is an organisation whose purpose - inter alia - is to protect the natural environment of the parish of Walberton (which includes the villages of Walberton, Binsted and Fontwell), and improve the quality of life of residents by promoting the conservation of our countryside. Walberton is currently a pleasant location and it is the aim of WAG to ensure that the attributes that make it such are retained or extended. WAG is neither opposed to housing or industrial development, nor the general concept of Eco-Towns, provided any development does not impinge adversely upon its objectives.

In this instance WAG considers the proposals impact adversely upon Walberton and its residents, are ill founded in themselves and, if approved, would inevitably result in even more extensive development in the future.

We believe our opposition to the scheme is widely shared by neighbouring communities, and so we make no apologies if some of our thoughts are similar in tone to others that you may receive.

Impact upon Walberton:

(1). Roads & communications: An Eco-Town has to be well linked to other existing towns.  Unfortunately, the road network surrounding Arundel is well renowned as a major national problem arising from its overcrowding, congestion, and stress. Development of the A27 and the provision of a suitable by-pass are prerequisites to further urban development in the area, but the costs are considerable and improvement of the A27 we believe is not currently programmed and is considered unlikely to happen. There is also forecast worsened congestion on the A259 between Littlehampton and Middleton, the B2132 at Yapton will be over capacity, and there is a plethora of lesser – but significant – transport issues to be resolved. It is our belief that there is no prospect of remedial works before 2016, and the probability is that the best eventual achievable date will be 2020 or later. The most direct route from the proposed site to the A27 for those travelling westward is via the B2132 that passes through Walberton and has already seen a massive increase in traffic resulting in the need for speed restrictions. This road cannot readily be improved to take yet more traffic and every increase in traffic load is detrimental to local residents.

The highway infrastructure – or rather its absence – is infamous for its failings. Only as recently as 2007, the South East Plan EIP Panel acknowledged local concerns that large-scale development is inhibited, at Arundel particularly, by A27 capacity.  Furthermore, the WSCC says “No A27 Arundel By-pass – no development”- simply because of the sustained congestion that has now permeated other local roads, notably the A259.

The developers’ concept of a new road to take all traffic from Bognor Regis and Littlehampton to the A27, together with Eco-Town traffic, is a mirage.  The road after passing through the Eco-Town simply joins Ford Road at Ford railway station and then it takes the existing route into Arundel.  This is as narrow and congested as the B2132 with again little chance to widen or improve it as it reaches Arundel. In short, the proposed site is bounded on all sides by roads that are already overloaded with both commercial and private traffic

That said, our understanding of the road plan is not helped by the recent information that in the course of the Arun District Council Ford Eco-Town Select Committee proceedings the original proposed link road has been, without the least explanation, deleted in its entirety from the plan. There seems to be no way to alleviate the traffic bottleneck.

Furthermore, also in the course of those same proceedings it emerged that there have been no meaningful discussions upon the proposals for increased bus and railway facilities with the local providers. The proposals are little more than wishful conjecture.

(2).Planning policies: For nearly a decade proposals to build houses on Ford Airfield have been considered and rejected by various Planning Inspectors at both District and County Council levels,

justified by the harm caused to the rural character of the locality, access and transport problems, and failure to meet the definition of PDL status.  We continue to support those objections, and reiterate that Ford is totally inappropriate for an Eco-Town.

The two current development proposals are little more than representations of earlier unaccepted proposals, and if allowed will submerge Ford, Yapton and Clymping into one amorphous mass with the resultant total loss of the individual village identities so cherished by their residents.

The current proposals, if accepted, could lead over time to further requests to develop such green spaces as remain, so that other villages, such as Walberton, will be swept away as recognisable entities and the whole area south of the A27 will become urban.

(3).Landscapes & communities: The area of development was to a large extent described in papers prepared by CPRE as “landscape………of outstanding quality and rarity” and “CPRE

considers this ensemble to be of great national significance” and “countryside……..as a rare and impressive landscape” and “probably one of the most outstanding footpaths in West Sussex” These characteristics are treasured but would be lost forever, buried beneath the Eco-Town, together with the destruction of a valued habitat of rare and important fauna and flora. It is the openness of the landscape and the separation of the existing village communities by fields and woodland that is a valued aspect of living in a rural village. Separation of extensive areas of housing by a “green belt” comprising of little more than one field is not the same thing at all. Most of the residents of Walberton have settled in the area because they wish to live in the country and many of them actively cherish their environment.

The Eco-Town cannot provide the required preservation of a separate and distinct identity for local towns and villages.  On the contrary, it will destroy Ford, Yapton, and Clymping as they now exist and adversely impinging upon other surrounding villages including Walberton, Barnham, Binsted and Fontwell. This is not to mention the serious loss of visual attraction to the surrounding countryside around Arundel – a stunning view and a major attraction to visitors many of whom are tourists.

Proposals are ill founded:

The project fails to satisfy a significant number of the criteria of the DCLG’s Eco-Town documentation.  The failures include:

(1). Greenfield land: Ford development is 87% on greenfield land, presently grade 1 (i.e. top quality), used for prime productive agriculture.  This is an abuse of this land especially given the global forecasts of grain and food shortages, with a vital demand for us to protect and use productively such sites.

This most certainly is not a development on either surplus public sector or brownfield land. 

(2). Climate change: :Resilience of Eco-Towns to climate change is a key requirement.  In this instance, the terrain is subject to coastal, fluvial, and surface flooding together with a high risk of saline intrusion into the water table, which is already very high in places.  Indeed, DEFRA has already identified this region as an area prone to serious water stress, and we are not convinced that sufficient flood risk assessment has been provided to evaluate properly the work entailed.

As recently as the 26^th May rainfall caused extensive flooding throughout the Yapton area, with copious quantities of knee deep water clearly filmed and shown on BBC TV.

The Environment Agency has forecast that tidal surges of up to 6 metres could occur by the middle of this century, and that these would cause extensive flooding in parts of Littlehampton. As there is nothing to stop the tidal surge proceeding up the course of the Arun it could also cause extensive flooding in the area proposed for development and the surrounding roads.

No attention has been given to the drainage consequences of the new development upon areas that currently lose their surface and sub surface water towards the sea through the Ford area. Further concreting over of what is currently open land able to absorb water will exacerbate existing flood risks in various local villages.

(3).Schools: Eco-Town ventures should include the provision of a good range of facilities, including primary and secondary education.  A population of 5,000 dwellings is too small for a new secondary school to be sustainable. Until yet further houses are finished, the education will have to be arranged with other local schools, which have insufficient capacity to absorb this extra demand. This will lead to yet more traffic on surrounding roads as children are taken or bussed to locations beyond the boundaries of the Eco-town.

(4). Shops:Likewise, the requirement to provide a suitable retail centre is not met – or at least not until a much later stage in the development of the Eco-Town.  There is a resultant dependency upon external retail facilities with attendant inconveniences to residents for access, and a resultant compulsion to commute (by road) to other established retail centres.

(5).Affordable housing: Eco-Towns are intended to facilitate affordable local housing.  It can be presumed that for practicality such housing is proximate to the daily work place.  In fact, the housing need for this area is mainly in Bognor and Littlehampton so for people with jobs in those towns the Eco-Town at Ford is of absolutely minimal relevance. As to whether they could actually afford what will be provided at the Eco-town it should be noted that there is a substantial stock of unsold housing in Littlehampton from £150,000 upwards. Even such low prices are beyond the reach of many workers in the community who are in low paid work. What many people need is social housing for rent close to their workplace, at a price they can afford, and with long term tenancies.

(6). Aborted Science Park: The intended Science Park, with its promise of 4,000 high-tech jobs, is most unlikely to be realised. Similar developments elsewhere have failed and Ford would not, of itself, attract the highly qualified skilled staff needed.  Experience proves that the habitat sought by such employers is most likely to be available in proximity to university or similar academic facilities that have a strong applied scientific tradition.

Interestingly, we now understand, the proposals first offered have been totally amended and the concept of a Science Park was withdrawn with alacrity when its validity was challenged during the Arun DC Select Committee proceedings. The plan seems to be obscure, but may rely on business relocation from Littlehampton and Bognor Regis. That alternative simply is unacceptable to the communities of both towns and the surrounding villages.

Future extension of the Eco-Town:

 (7). Future Eco-Town extension It is apparent from some of the shortcomings in the existing proposals that they could only be rectified by building a much more extensive town than that currently proposed. Furthermore, once the development boundaries have been broken down there will be numerous applications to develop further pockets of land as individuals see the opportunity to realise value from their otherwise diminished environment. The effect of enlargement will be to create an urban sprawl that will ruin the area in the eyes of many existing and potential residents.

(8). Regeneration: Worthwhile and essential regeneration initiatives are under way in both Littlehampton and Bognor. Diversion of resources to the Eco-town either as currently proposed or as it might be extended could undermine the success of these initiatives that have been welcomed by those communities.

Summary:

In summary, the area is already plagued with acute transport issues, the local demand for affordable housing is limited, as is the demand for further employment in this area. Job opportunities created in the current plans are too few to satisfy the occupants of 5000 homes, many of whom will be compelled to seek work elsewhere. These proposals, expedient for housing development, do not by a long way comply with or meet the stated purposes and intended spirit of, the Government’s Eco-Town concepts. The development could only be achieved at the price of destroying a substantial area of what is currently greenfield land and the potential size of the development could in time completely change the character and attraction of the area and of the villages therein.

We are greatly encouraged to have general support in our objections from Lord Rogers of Riverside, internationally respected as an authority in such matters and who has acted as a Government adviser. He has criticised plans that encroach on green belt land and are unsustainable. The Ford plan fails the criteria of both credibility and acceptability on many counts as we have indicated above.

In conclusion, in our opinion this process is seriously flawed and we urge you to reject in its entirety this unsuitable proposal. There are other options that are more fitting for your purposes.

Yours faithfully

Peter Brown

Chairman 

Walberton Action Group.  

 Copies for information to:  Rt Hon Ms. Caroline Flint MP, Messrs Nick Herbert MP, and Nick Gibb MP.