Draft Planning Policy Statement (DPPS) and Sustainability Appraisal Consultation:
North East Elsenham (NEE) Eco-town: Response to Consultation
Suggested Responses to Consultation Questions - See Part 3 of Draft Planning Policy Statement Pages 24 to 26
Please follow answers and include all suggestions where possible
1. Does the draft Planning Policy Statement (PPS) provide sufficient guidance on the consideration of eco-towns through the plan making process?
No - Far too much guidance:
1.) Contradicts Government assurances that decisions will be made through the ‘plan making process’; directs planning authorities to allocate sites and/or grant planning permission for the eco-towns; therefore takes away local democratic power from local authorities and local people.
2.) Produced by the Secretary of State and identifies sites for eco-towns, if the final decision is later taken by the same Secretary of State then she/he is already biased in favour, which is an unfair process.
3.) The Government has been advised by the same planning consultant who is now acting for eco-town developers; this raises the potential for a conflict of interest and seems an inherently unfair process.
2. Are the locational principles for eco-towns sufficiently clear and workable?
No.
1.) Sites have been chosen from proposals put forward by developers, not by an objective process.
2.) The sites have effectively been given outline planning permission without a planning inquiry.
3. Taking overall the standards set out in the draft PPS do you think that they achieve a viable eco-towns concept?
No.
1.) In many cases the proposals do not reflect local circumstances where many of the Government’s own “key criteria cannot be met; the location of “North East Elsenham” without a suitable road access is not viable’; it will be too small to make a secondary school or a supermarket realistic developments and would not create enough jobs, it will be a large housing estate for commuters.
2.) The high standards of housing energy efficiency and good design will be not be met in the new economic climate because they would make the houses even more expensive to build and to buy.
4.1, Do you consider that the standards provide a clear basis on which to make decisions on planning applications for eco-towns?
No.
1.) The pressure for cheaper houses means standards will drop and eco friendly features will not be provided the ‘standards’ are a ‘red herring’ to force local authorities to give planning permission when they are against the principle of the development; the ‘standards’ are ‘dressing up’ unacceptable development.
4.2, Do you consider that the cost of implementing the standards will undermine the viability of eco-towns?
Yes.
1.) These standards were devised before the economic recession, they will add to the cost of homes in eco-towns and buyers will go elsewhere that is why some developers have already withdrawn their proposals. 2.) There is a danger that eco-towns will not be finished because the houses are too expensive leaving residents stranded on an unfinished building site - this happened at Cambourne in Cambridgeshire
4.3 Are there any standards that you feel are missing? (That are not covered in other Government policy or guidance.)
Yes.
1.) The original intention to build on brownfield land has been dropped this was an important promise by Government at North east Elsenham the proposal is almost entirely a Greenfield Site.
2.) The original intention to site eco-towns in areas of high demand for affordable housing has been dropped this means that these houses will not be used to meet local housing need.
3.) There is no standard, which guarantees that the eco-town will have the schools, jobs and supermarket it needs this means that people will have to commute.
4.) There can be no standard, which stops people owning cars, although low car ownership is the false assumption on which eco-towns are based.
5.) In the case of ‘North East Elsenham’ there is no standard to ensure that proper road access will be provided, access is via country lanes
4.4 Are any of the standards not essential?
No – all are essential
1.) Eventually most of the standards will be seen as non-essential as market forces take over and the development will not be an eco town but a lower standard housing estate
4.5 The zero carbon standard attempts to ensure that carbon emissions related to the built environment in eco-towns are zero or below. Have we specified the calculation of net emissions clearly in a way that avoids perverse incentives and loopholes? Is this standard the most cost effective way to do this?
1.) Carbon emissions cannot be zero with gas, oil or solid fuel heating. The North East Elsenham site will not be able to maximise renewable energy technologies, which has been admitted by other current prospective developers in the vicinity of the village. The generation of electricity involves carbon emissions elsewhere as renewable energy will not be possible on many sites.
2.) The standards will not be met in the new economic climate; confusing ‘window dressing’
4.6 The climate change adaptation standard, alongside existing planning guidance, aims to ensure that eco-towns will be more future-proof. Is it sufficiently clear and workable?
No.
1.) Climate change will not be prevented by a tiny number of eco-friendly houses especially as the final carbon savings are questionable; the reasons for climate change are complex and confusing, eco-towns are being justified by ‘jumping on a bandwagon’
4.7 Should the PPS be more prescriptive than set out in paragraph 4.9 (e) in relation to energy efficiency? Do you agree that 70 per cent is an appropriate level of carbon mitigation through on-site means?
1.) How does anyone know what difference this will make? In many sites such as North East Elsenham there is no evidence that such savings would be possible; if this proves too expensive then houses will not be sold.
2.) How can this prevent future house owners putting in cheaper heating at a later date?
4.8 Is this employment standard sufficiently clear and workable?
No.
1.) This is just simplistic window dressing, it will never work.
2.) No standard or strategy can force employers to come to a town, nor residents to work there. A railway station will encourage commuting to other employment sites, no standard or strategy can prevent this.
3.) Local employment in a small eco-town will not be attractive nor able to compete with large scale job opportunities in larger nearby towns and cities
4.9 The transport standard attempts to support people’s desire for mobility whilst enabling low carbon living. Is it sufficiently clear and workable?
No.
1.) All past, and very similar, attempts to reduce car ownership have failed, there is no likelihood that eco-towns will be any different, cars will continue to be the predominant form of travel, no standard will make a material difference; people walk and cycle in big towns and cities, not in small rural ‘eco-towns’ whatever the ‘standard’; it will not work where public transport is poor, unreliable or non existent throughout the day.
4.10 The local services standard allows flexibility to reflect existing local provision and the size of the development. Does it cover the essential services which will be needed in eco-towns?
No
1.) No standard can force retailers to build and open shops if uneconomic, supermarkets will not establish unless their criteria are met, including a large local customer base; without a supermarket the eco-town will never be sustainable. Standards will not force education authorities to build new schools if there is existing school capacity in nearby towns.
2.) The facilities in paragraph 4.17 are a ‘shopping list’ with the planning system unable to ensure they are actually provided. Developers can only provide sites, they cannot make others actually provide the services
4.11 The standards proposed on green infrastructure and biodiversity aim to ensure that development is undertaken in such a way that it protects and enhances the best features of local landscapes for the benefit of both people and wildlife. Are these standards reasonable and deliverable?
No
1.) No amount of ‘green infrastructure’ or ‘biodiversity’ can replace lost countryside; landscapes and wildlife cannot be saved when the objective is to build new towns; only brownfield land should be used for eco-towns as the Government originally announced.
4.12 The water and flood risk standards aim to ensure that eco-town developments are planned so that they will minimise water use and flood risk, and raise quality. Are the standards proposed clear and deliverable?
No
1.) Eco-towns should not be built in areas of ‘water-stress’, if left to planning application stage then this is a cosmetic exercise Eco-towns should not be built in areas where there is any possibility of flood risk, including surface water run-off problems and especially where such problems are already experienced. If left to planning application stage then this is a cosmetic exercise
4.13 The waste standard aims to ensure that eco-towns manage their waste effectively, from their construction onwards. Is the proposed waste standard a clear and workable way of doing this?
No
These standards should apply to all developments, not used as a cover for eco-towns
4.14 The transition and development standard should ensure that initial residents will not live in un-serviced and isolating building sites. Does it get the balance right between supporting initial residents and enabling developers the flexibility they need to build and grow the town?
No
It is not clear what ‘transition’ means or how long it lasts; nothing can compel developers to build houses if they cannot be sold, this is an initiative created in an economic era which has passed. Developers do not build schools, surgeries or operate bus services, those bodies responsible will take these decisions and cannot be forced to fund provision where they are not viable. There are many current examples of half finished developments, why would eco-towns be different? Cambourne in Cambridgeshire is given as an good example of a new settlement, but in fact it is only half finished after 9 years.
4.15 The community and governance standard attempts to ensure that eco-towns will be successful communities, that residents will have a say in how their town is run, and that standards are maintained. Is this standard clear and workable?
No
Local democracy already exists, there are already district and parish councils and the existing communities are already fully involved in the process (and in Essex they do not want ‘North-East Elsenham’); This is not a new proposal, just another example of ‘dressing up’ a standard planning proposal with the eco-town principle. Is the ‘local community’ to decide where people work or shop, or how many cars there are?
5. Do you have any comments on the accompanying Sustainability Appraisal/Habitats Regulations Assessment or the Impact Assessment?
These assessments are too superficial and leave too much to the development control process, by when the principle of the eco-town has been established. There are too many examples where the data is incomplete or over optimistic or flawed. Where the assessments have accepted what developers have put in their proposals, they are not objective studies based upon independent evidence; there are numerous examples of subjective bias or selective references; the objective of the ‘assessments’ is to support the case for the eco-town
Specific points on ‘North East Elsenham’
6 Do you have any comments on the issues identified in the Sustainability Appraisal/Habitats Regulations Assessment of the locations for eco-towns?
6.9 North East Elsenham (NEE)
Whatever the outcome of the Judicial Review, there are concerns about the process whereby the SoS has produced locationally specific policy, then is the likely decision taker on planning proposals, this bias prevents an open minded approach. There is also concern about the fairness and potential conflict of interest in the process where a consultant seems to be advising both the Government and the NEE development promoter.
NEE fails the first test of the DPPS - it would not be a ‘new settlement’ nor be separate and distinct, but would represent coalescence of two Essex villages each with its own established character. Despite some suggestions in the EA, the NEE eco-town is not endorsed in the recently adopted EoE RSS nor the emerging UDC LDF. The ‘plan-led system’ is proposed to be bypassed.
The road system to serve a 5,000 dwelling, 11,000 population eco-town is wholly inadequate. Traffic would pass through a congested Stansted Mountfitchet or along unclassified country lanes. Reliance on a potential solution to be provided by new roads as part of the development of Stansted Airport Runway 2 is premature and just cannot be justified.The claimed advantages of the railway station are based on aspiration rather than evidence, and not likely to be real in practice.
The NEE eco-town is most unlikely to be big enough to support adequate services:
· The settlement is too small to provide adequate employment facilities for its population, resulting in an unacceptable degree of out commuting
· A secondary school is unviable, leaving pupils to travel elsewhere
· It is commercially not feasible to provide adequate retailing for daily needs within the settlement.
· The current proposer shows that most of the essential service will not be provided for years after the first houses are occupied
The impacts of Stansted Airport, one of the UK’s largest and within 2.5 km, have not been properly assessed even though the SA says there would be “severe implications”.
No adequate economic/employment strategy has been prepared or assessed - the most likely scenario, however, is out commuting by car, few employment opportunities on site and lack of community facilities and shops on site.
The regeneration of Harlow is a regional priority. Whilst the SA acknowledges that this may be harmed by the development of North East Elsenham, no proper analysis has been carried out.
There will be severe impacts on the historic village of Henham and the countryside around Elsenham and Henham. This is not a brownfield site as originally envisaged by the eco-towns initiative and is on the ‘best and most versatile’ agricultural land.