'Eco-Town' Fight Continues
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'Eco-Town' Fight Continues

Peter has joined forces with John Maples MP and Geoffrey Clifton-Brown MP in the latest fight against plans to build an 'eco-town' at Long Marston and issued this joint letter:

Mrs Pam Perceval-Maxwell
WRMSS Panel Secretary
c/o Government Office for the West Midlands
5 St Phillips Place
Colmore Row
B3 2PW

7th May 2009

Dear Mrs Perceval-Maxwell,

Response from Mr J Maples MP (357), Mr P Luff MP (231) & Mr G Clifton-Brown MP

Sub-Matter 8E: Coventry and Warwickshire – (iv) Stratford-upon-Avon District: Middle Quinton Eco-town proposal (including parts of the site within Worcestershire/ Gloucestershire)

In his letter of 17th April 2009, Henry Cleary, Deputy Director of the Housing and Growth Programme at the Department for Communities and Local Government, states that ‘a range of alternative options including eco-towns, new settlements and urban extensions have been put forward by the Panel.’ This represents a manipulation of the deliberative processes of the Examination in Public and is illustrative of the confusion plaguing the eco-town programme. Examination of Middle Quinton has been retro-fitted into the RSS as an afterthought. This has not afforded the Panel time to review the mass of information relating to Middle Quinton or the draft PPS submitted to the government in the process of the eco-town consultation.

As the three MPs affected by the Government’s proposal to build an eco-town at Middle Quinton, we would like to address the question of Middle Quinton within the context of the RSS. It is important to point out that this is an issue affecting three counties, Warwickshire, Worcestershire and Gloucestershire and two regions. Two thirds of the Middle Quinton site is located in Stratford District, while the other third is within Wychavon District. Furthermore, the proposed eco-town abuts onto the Gloucestershire boundary which is in the South West Region. Whilst the Cotswolds is outside the remit of the WMRSS, it would be a serious oversight to ignore the implications Middle Quinton would have on Cotswold District in terms of essential services and future expansion. In submitting this evidence it seems to us that it must be relevant to consider the effect of this eco-town on the whole of the surrounding area.

Whilst we appreciate that it is highly unusual to submit a response after the consultation deadline, recent events necessitate this late intervention. It was only after the deadline that we learnt that the Secretary of State intended to delay the decision on Middle Quinton until after she had considered changes to the draft revision of the RSS.

The premise behind the WMRSS is to address the development needs of the West Midlands. In the Sustainability Appraisal of the Draft PPS, the RSS is identified as the process through which the location of eco-towns should be determined. Given this policy, it seems wrong for the Government to have taken so long to concede that the WMRSS is the appropriate forum for this discussion.

The hallmark of the eco-town policy has been its examination of settlements as discrete entities yet this approach undermines the plan led system, particularly regional planning. Any development should be borne out of regional housing needs, in conjunction with other regional objectives such as employment, retail and leisure policy. As a result of the Government’s approach, alternatives to Middle Quinton have not been fully debated. We are sure that had the eco-town been subject to the full scrutiny of the Panel from the start, then we would have had a full appraisal of the sustainability of the Middle Quinton site. We also believe that examining the idea of eco-towns through the EiP is made very difficult as the final eco-town PPS has not yet been published. The Government has asked the panel to judge eco-towns against criteria, which have not yet been approved, and which should therefore be deemed provisional.

The PPS defines eco-towns as separate and distinct settlements of more than 5,000 houses but both housing need and climate change need to be looked at within the regional context. Existing urban settlements or eco-towns as urban extensions have not been fully considered. Again the question of how best to tackle these issues has been marred by failure to address the regional context. Alternatives would support the RSS and its ethos of urban renaissance, not serve to undermine it.

Would the Middle Quinton Eco-town proposal for some 6,000 additional dwellings represent a sustainable form of development?

It is clear that Middle Quinton is not a sustainable development. It is in a remote rural location far from centres of employment, leisure and retail with poor transportation links. There is currently no rail-link and one small B road to serve an estimated 20,000 additional people. Six thousand new homes would require a whole new infrastructure - road, rail, schools–where services are already overstretched. In addition, the developer’s vision of transportation and infrastructure development cannot be guaranteed and its economic viability is questionable. A Strategic Transport Assessment carried out by the local authorities has questioned the deliverability of links to Honeybourne and Stratford.

The site’s remoteness would result in a high level of car dependency, which would run counter to the objective laid out in the PPS of 50% of all journeys being undertaken without a car. This would make it impossible to fulfil the zero-carbon ambitions of the programme. It would also lead to the urbanisation of rural roads in an area in close proximity to the Cotswold Area of Natural Beauty. Middle Quinton has significant ecological value and it was recently considered for designation as a Site of Interest for Nature Conservation.

Middle Quinton will fail to generate sufficient employment for residents, thereby exacerbating the phenomenon of out-commuting. Based on the DCLG’s own standards, Middle Quinton will in fact produce a shortfall of 1276 jobs and fail to reach the Government’s target of generating one employment opportunity per new dwelling. This factor is bound to increase the number of people commuting by car, which is contrary to the Government’s policy on reducing car usage and significantly reduces the eco-town’s claim to be sustainable.

The site is not previously developed land by PPS3 definition and is in fact a mix of majority greenfield and minority brownfield (166 hectares out of 258 hectares). Furthermore, the developer’s promise to make 40% of the site greenspace includes 18 hectares of private gardens, which is unacceptable given that this is deemed to be previously developed land under PPS3.

It is difficult to see how Middle Quinton would constitute the linked settlement underlined in the PPS document. The sustainability appraisal of the site has been thoroughly criticised by leading Environmental Policy expert William Sheate who concluded that based on IEMA criteria, both the sustainability appraisal of the draft PPS and programme SAs were ‘exceptionally poor.’

We believe that BARD have already submitted the documentation they sent to the government in its eco-town consultation and we would expect all these submissions to be fully considered in the Examination in Public and circulated appropriately.

How would such a proposal fit within the RSS spatial strategy and what would the implications be for both urban and rural renaissance?

Middle Quinton is completely at odds with the strategic objective of the preferred option of the Phase 2 RSS and the current RSS Phase 1, which emphasise the need for urban renaissance. Both these documents highlight the importance of developing Major Urban Areas in the West Midlands and tackling the phenomenon of out-migration and the decentralisation of jobs. The area around Middle Quinton is relatively prosperous and focusing regional development there would disadvantage urban areas in desperate need of regeneration. In paragraphs 3.45 to 3.65 of the Preferred Option, it is clearly stated that housing around Stratford-upon-Avon and Evesham should be limited to local needs. It is also notable that Middle Quinton is outside the ‘strategic foci’ of economic activity in the region.

In Coventry and Warwickshire, affordability is a key concern. The case for the eco-town has been premised on the need for affordable housing both in Stratford District and South Worcestershire. Providing so many affordable homes in one place is however wrong, since the emphasis has always been on meeting local requirements as and when they arise. Putting 2,000 affordable houses in one place is sheer madness as people in need of this housing often rely on family social networks for child care, have jobs close to where they live and are also less likely to have cars. Stripping them from their support networks to live in the middle of nowhere is clearly unwelcome and ill-advised.

Is the proposal deliverable in terms of economic viability and provision of appropriate transport (and other) infrastructure?

The economic viability of the site has come under close scrutiny from the Joint Working Group of Local Authorities, who commissioned an independent assessment from CB Richard Ellis based on a detailed analysis of both construction costs, infrastructure estimates and an assessment of the property market. The report concluded that construction of Middle Quinton would produce a £373 million deficit. Section 106 contributions from the developer would be unsustainable, which would provoke recourse to public subsidy. The DCLG-commissioned PWC report found that the site would probably not require public subsidy but it only refers to "potential" viability. Such considerable cost uncertainty still leaves the question of the financial viability of Middle Quinton unanswered; the cost assumptions made in the PWC report were unrealistic in comparison to the CRBE report. If an eco-town at Middle Quinton is to be included in the RSS, then the Examination in Public will have to address this issue.

Should additional housing be warranted in the District over and above the preferred option, as suggested by NLP (4,500 plus 1,500 in Wychavon District) are there preferable alternatives such as an urban extension or extensions to Stratford-upon-Avon?

We do not believe that either the Stratford or Wychavon District have any suitable locations for a new settlement of this scale. If there are to be additional houses in the region these will have to go elsewhere, preferably in the MUAs in accordance with Government strategy.

The NLP Report is one piece of evidence commissioned by the Government to inform discussion during the Examination in Public. However we are concerned that it has been given too much weight in the face of other evidence presented.

Stratford District has previously responded well to delivering its housing numbers but the increase proposed by NLP is ill-conceived. An additional 4,500 dwellings in all three scenarios, to give a total of 10,100 over the period 2006 – 2026, is completely unfeasible. This increase is in direct contravention to regional policy and the preferred option of the Phase 2 RSS, which states that local need should be the engine behind housing provision.

In the NLP report, the sum of the additional housing numbers for South Worcestershire and Stratford is 6,000, which happens to be the housing projection for the eco-town. It is hard not to conclude that this number was arrived at solely with Middle Quinton in mind and in complete disregard of local demand. A development of this size would merely serve to promote out-migration from the MUAs. The report is noticeably thin on alternative proposals to provide 6,000 additional houses and it does not address the viability of the eco-town. It also fails to make a case for additional housing needs or reference existing regional policy.

Stratford District and the three councils of South Worcestershire will submit their Core Strategies later this year. There is capacity within the urban areas of those Districts for some growth but Stratford has reached saturation point and further development would compromise the very nature of the town. Development would have to be spread around the main rural centres of the District and in rural areas to meet local need.

What additional infrastructure requirements would be critical should higher provision be proposed whether at Middle Quinton or any alternative location? Would any such alternative require Green Belt alteration?

Middle Quinton would require extensive infrastructure provision, including construction of the Stratford Western Relief Road, a guided bus way, improved access to Honeybourne and Stratford railway stations as well as education and health facilities. The economic viability of these plans are thrown into doubt by the CB Ellis report. It is clear that Stratford’s service provision would be compromised if Middle Quinton was given the go-ahead.

In South Worcestershire, the RSS requires construction of 24,500 homes, and the South Worcestershire Joint Core Strategy (SWJCS) proposes 9,100 of these for the Wychavon area, principally around the main urban areas of Droitwich Spa, Evesham and Pershore with the rest pepper-potted around established villages in the area.

This is where they should be built, as there is already the infrastructure in place to cope with such additional development, as well as the demand for housing. The largest proposed individual settlement around these established areas is 1,500 homes (to the north-west of Evesham). The SWJCS recognises individual developments larger than this are not sustainable in the area.

An additional 1,500 home share of a 6,000 home eco-town in a non-established area, with little existing infrastructure and no current or foreseeable demand is therefore not sustainable.

Wychavon is also being forced to absorb significant housing growth around Worcester since the city does not have the space to accommodate more than a few hundred of its allocation. Indeed, the very large housing numbers planned in the Norton/St Peter's area (and in Malvern Hills), if they proceed, could be built as eco-suburbs.

Middle Quinton is within a mile of the Cotswolds Area of Outstanding Natural Beauty and just a short distance from the market towns of Chipping Campden and Moreton-in-Marsh and as such there will be effects felt in Gloucestershire through this development. During the phased building of the eco-town, there will inevitably be times when there is not sufficient capacity on the site itself and this will put a strain on educational and health facilities nearby. It is highly likely that there will be a permanent increase in demand for places at Chipping Camden School.

Furthermore it is inevitable that there will be an increase in demand for services in the two market towns which are already over congested with traffic. This development is bound to exacerbate problems in this respect, particularly in terms of parking. The Cotswolds has a higher proportion of listed properties than any other rural area in the country. Damage caused by traffic, in particular HGVs is a great concern in many fragile Cotswolds villages close to the development and there will be a certain increase in HGV movement during and after the building of the eco-town.

We believe that an eco-town at Middle Quinton should be rejected as part of the RSS and that the RSS should stick to its original strategy of putting new development into major urban areas. New housing in rural areas should be to meet local need alone and therefore the housing target for Stratford-upon-Avon District should remain at 5,600 and for Wychavon at 9,100.

Yours sincerely,

Signed by:
John Maples MP
Peter Luff MP
Geoffrey Clifton-Brown MP

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