Bordon Area Action Group

BORDON AREA ACTION GROUP

for sensible planning

RESPONSE TO THE GOVERNMENT’S CONSULTATION ON ECO-TOWNS:

SUSTAINABILITY APPRAISAL AND HABITATS REGULATIONS ASSESSMENT OF THE ECO-TOWNS PROGRAMME FOR WHITEHILL–BORDON 

Introduction

We represent a group of residents living in and around the Bordon and Whitehill area. 

We are concerned about the harmful impact of the eco-town proposals on Whitehill, Bordon and neighbouring communities, and the failure of the process to date to satisfy basic planning requirements.

AN ECO-TOWN AT WHITEHILL-BORDON WILL FAIL TO MEET THE GOVERNMENT’S CRITERIA:

§       It would not be a new, separate and distinct settlement, but an extension to an existing town;

§         The addition of 5,500 houses would more than  double the population to over 30,000, creating more urbanisation but no sense of living in a unified sustainable settlement.

§       There is no clear capacity for, or commitment to pubic transport links to a higher order centre, which lies over 20 miles away;

§        No rail link is proposed. The proposals include new road building, with more traffic on existing roads in an area where car use is already very high.  This conflicts with the eco-town objectives.

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Th  The extended town cannot be zero carbon without unsustainable spending to upgrade homes, shops and workplaces in the existing town, build new roads and develop other infrastructure.

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           There is no realistic prospect of or commitment to such a level of investment.

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       This town already has a high proportion of affordable housing. Building more would exacerbate the existing socio-economic imbalance in the town.

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           An eco-town will not solve these problems. The Council’s aim of attracting more executive housing conflicts with providing more affordable housing.

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     Residential development on the scale proposed lacks local community support.

East Hampshire District Council claims local people want this, but it has ignored the results of its own consultation.  Local people have voted for reuse of redundant military land on a scale much smaller than this proposal.  The Southeast Regional Assembly calls for abandonment of eco-towns unsupported by local people.

The Council has no mandate to promote an ecotown.

Only 130 people responded to EHDC’s Issues and Options ‘consultation’ while a petition to Parliament signed by1300 people supported Option 1- surplus MOD built land only, up to 2000 houses  

§        

           Expansion on the scale proposed would substantially and irrevocably damage the many sites of protected ecology and biodiversity. 

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           The Council’s threat  that a much larger amount of uncontrolled development would take place if an eco-town is not built is scaremongering, and contradicted by recent successful  MoD site development in Liphook.

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           All development proposals must be subject to the normal planning process, as the recent example of development of MoD land at Liphook shows.

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          The sustainable option for Whitehill-Bordon is to limit future development to redundant built up MoD land.  This can only accommodate up to 2000 new homes.

DETAILED RESPONSE TO THE SUSTAINABILITY APPRAISAL WHITEHILL-BORDON

This document lacks rigour and provides no basis for judging the advantages or disadvantages of an eco-town in this location.  There is no coherent methodology underpinning the Appraisal. The document contains many errors of fact, unsubstantiated assertions and omissions.

Factual errors include:

Para 2.2.3 refers to the settlement of Acton.  Acton is not in ‘close proximity’ to Bordon-Whitehill. 

Fig 1 shows the location of Whitehill-Bordon, but has Whitehill in the wrong place.

The A325 goes straight through the Woolmer Forest and not just within 200m of the designated area.

Alton, Bordon, Haselmere, Aldershot (which should actually read Farnham) Liphook and Liss are all urban areas, identified as towns on Figure 1.  Lindford, a village of over 5,000 people has been omitted.  The other areas on the plan are not ‘urban areas’.  They are all villages collections of houses set in rural locations.  There are not two ‘Conford’ village areas.

Fig 2 fails to identify the following environmental constraints:

• Sites of importance for Nature Conservation (SINC)

• The Deadwater Valley Local Nature Reserve

• Conservation Areas

• The proposed South Downs National Park

2.5.33  Bordon does not lie midway between the A3 and M3 motorways

2.5.36 There is no proven demand as claimed for new employment development.  Substantial existing floorspace is vacant and employment land is derelict.

2.7.31 University of Guildford does not exist.  The term “Planned talks” is meaningless.

Overall, the document points to obstacles that cannot be overcome without causing severe harm to interests of acknowledged importance.

Any proposal for development on this scale, let alone an appraisal of it, should, amongst other things, be preceded by a Strategic Housing Land Availability Assessment. We note that this is not currently available.  

COMMENTS ON KEY SECTIONS BY PARAGRAPH NUMBER:

Proposal Objective

Para 2.2 presents the sole objective of this eco town as developing 5,500 homes on 258 hectares.  But the available brownfield land amounts to just 80 hectares, some of which contains existing buildings which should be sustainably reused.  That amounts to over 70 houses/hectare with no allowance for anything else.  The location(s) of the additional 178 hectares required for housing has not been identified.  No figure of land allocation for 7000 new jobs, schools, retail, leisure, services, highways or the required 40% green space has been stated.  The figures simply lack credibility.

No reason has been advanced to support the Government’s minimum figure of 5,500 homes for this location.  Experience elsewhere demonstrates that almost any number can be zero carbon and sustainable.  There has been no assessment or sequential testing of alternative sites. 

3.2.5        The proposal  to integrate the new development with the established town of 15,000

people departs from the Government’s stated objectives for eco-towns

Policy context

2.3.2  Proposed changes to the South East Plan (July 2008) have only been made because of EHDC’s plans for town expansion. These do not have local support.

Environmental Constraints

2.5.3 notes that The South East Plan requires ‘respect for environmental constraints’, which are extensive in this area.  The appraisal acknowledgement of constraints on development imposed by designated areas appears to confirm that:

·         Productive agricultural land will effectively be sterilised if development on the proposed scale goes ahead.

·         Greenfield biodiverse areas will have to be managed as public recreation space if the development goes ahead.

In any event, all future development must achieve a higher standard than proposed for eco-towns by 2016.  Eco-towns deliver no greater benefit to climate change.

2.5.3 No evidence that water supply can cope with doubling population

Landscape and historic environment

2.5.13 - 21 This section lacks credibility. Any landscape character assessment should include a factual description of local topography, land use, built form, massing, urban grain, vegetation, including Ancient Woodlands (as identified on Figure 3); existing trees (including Tree Preservation Orders) hedgerows.  These key considerations are absent from this sustainability appraisal.

There is no mention of the River Wey, which forms an important local landscape asset in terms of its character, ecological value and history.  Furthermore, the River Wey forms part of a Conservation Area whose origins predate the Domesday Survey.

Despite all this baseline information, landscape is not considered in Table 5 of the Draft Eco-town Criteria.  Without the landscape appraisal, the fundamental driver of a parameters plan, there is no sound basis for this sustainability appraisal or any masterplan. 

2.5.15 identifies that the Whitehill-Bordon area has ‘experienced development post 1945 that has had adverse impacts on the wider landscape’, but there is no mention in the assessment of the likely impact of the proposed expansion on the wider landscape, which includes nationally designated landscapes of the Proposed South Downs National Park and the Area of Outstanding Natural Beauty.

Omission of importance and impact of development on historic land use, rural character, development (e.g. Wey Valley) ancient settlements, historic buildings, and conservation areas.  Conservation areas omitted from map.

Conservation areas include:

• Blackmoor

• Headley

• Arford

• River Wey

• Headley Mill

• Liphook

2.7   The situation with the eco-town

Biodiversity and green infrastructure

Impact on the wider landscape and local and national ecological designations has not been fully assessed.  There is no methodology for determining how the effects of the proposed eco-town on the landscape and its components.

A sustainability appraisal fails to assess how the existing and proposed new future population can benefit from the existing agricultural land, such as the ancient, high grade Standford Farm, in more ‘eco’ ways, such as creating a community farm, or allotments.

Overall biodiversity targets proposed have not been properly considered from the outset and cannot be delivered through the proposed eco-town. 

2.7.11 notes ‘… a range of indirect impacts on the biodiversity of the area, including as a result of pollution and recreational impacts.  This puts in doubt any certainty that the biodiversity value of these important areas can be increased…’ 

2.7.16 states “…the masterplan will safeguard the Hogmoor Inclosure and the land to the east of Bordon, resulting in over 200ha of land available for mitigation purposes…”  But, on the strength of 2.7.11, the likely result is harm, not mitigation.  Mitigation should be solely for biodiversity improvements which can stand side by side with sustainable farming.   Even if this 200 ha of land were genuinely for mitigation, that leaves just 80ha of land, as set out in Option WB3 of the Core Strategy, on which to accommodate the 5500 dwellings and supporting open space requirements. 

 2.7.21 – There is no evidence to substantiate the statement that there will not be any direct impacts on the surrounding landscape character.

Transport

2.5.33 - The town is not "set midway between the A3 and the M3".  It is some two miles north of the A3 and some 20 miles south of the M3.  

The Hindhead tunnel may reduce travel time from Bordon to Guildford,  nearly 25 miles away, but will generate substantial additional traffic on local roads beyond their capacity if the town doubles its population.  Unsustainable new and ‘improved’ road building will be required.  

2.5.34 / 2.5.37 – Bordon residents commuting to work in the Blackwater Valley area - where there is work but not enough houses - suggests that this area would provide a better site for an eco-town.  

The assertion that "the HIndhead Tunnel will increase pressure for development in the area", is unsubstantiated.  Even if there were pressure, no evidence is put forward in favour of Bordon as the right or only place for all development.  

 "… the town sits along the A325 which provides a strategic link to the Blackwater Valley" implies some advantage, but fails to note that the A325 is already an overcrowded route, passing through protected wildlife areas and therefore not  easily improved.

2.7.37  - notes the severity of Bordon’s existing transport problems .  

The “wish list” put forward has no practical or funding base and has not been evaluated.  It cannot compensate for the acknowledged inability to provide a rapid transit system worthy of any town of 30,000 let alone an eco-town aimed at reducing car dependency.

"sustainable transport links to higher order settlements" cannot be achieved, if, as in 2.7.37 it is assessed as unlikely to be viable.

Community infrastructure

2.7.29  No evidence is presented to show how growth will deliver better quality education, nor tackle the problems of the existing town, including anti-social behaviour, out-commuting and traffic

2.7.30 The proposed new town centre cannot be developed as EHDC assert, in advance of any handover of MOD land.  To achieve this it would need to have been already planned and started.  Furthermore, providing facilities comparable with nearby towns for double the population would require a distinctive, high quality town centre with varied character and twice the capacity of Petersfield or Alton, both of which have around 15,000 population. 

Community well-being

2.7.33  Contrary to this, residents do not support growth on the scale proposed.

Responses to the Council’s consultation exercise and questionnaire, Spring 2008, showed that the overwhelming majority were in favour of the Green Town Vision’s Option 1 - no more than 2000 new homes.  The largest number to date to have expressed their are the 1300 people who signed the Bordon for Option 1 petition, presented to Parliament in October 2008.

Although people when asked invariably favour better facilities, there is no support for doubling the size of the town to achieve them.  People don’t accept that the facilities enjoyed by similar sized towns cannot be provided without 5,500 extra homes.

2.7.34  The assertion that there will  be good opportunities for increasing the currently poor skills levels prior to the establishment of the eco-town, is not supported by evidence or defined measures to do so.

Employment and economy

2.7.41  There is no evidence of increased demand for industrial floorspace

2.7.42 -  Economic and Land Use Study cannot be relied upon in the absence of stated methodology, date and authorship.

Good intentions listed under "Spatial Issues" are not evaluated or assessed.  The possibility of sand extraction may need revisiting in the light of delays in the development programme.

Strengths and Weaknesses of the location

 2.8 There is no no coherent definition of strengths and weaknesses - they are actually Opportunities and Constraints

2.8.1 Under "Key strengths of the location from a sustainability viewpoint" are a number of points, not numbered. 

The Eco-town bid predates the South East Plan.  The latter cannot therefore justify the former.  

-  the need for regeneration cannot be a strength

- an opportunity (for redevelopment of brownfield land) cannot be a strength

- development of greenfield (“public sector”) land cannot be a sustainable strength

- "excellent access to high quality and biodiversity rich countryside, not least the proposed South Downs National Park." is a major constraint.

A consideration of key strengths could include:

• Investor commitment

• A viable, sustainable rapid transit system

• Sufficient facilities to serve 30,000 people

• A cycle network

• A good range of locally produced food

• A good range of employment opportunities

• Renewable local building materials

• Broad community support

However these are all absent from the proposal

2.8.2  Key weaknesses

- "potential for a range of biodiversity effects" means damage.

- "grafting on development to an existing town will pose particular problems" means irreconcilable conflict with the PPS definition of an eco-town

- there are no nearby higher order centres.

2.7.21 - an aspirational statement, makes no reference to the landscape character, community, settlement patterns or history

- no consideration is given to the harmful impact of large scale development on surrounding settlements.

2.8.3  Table 4  is not “an objective summary” or a coherent assessment of the sustainability f Whitehill Bordon as a potential eco-town location.  It does not present strengths and weaknesses.  It provides no objective measure for the B rating given to Whitehill-Bordon:

…Might be suitable for an eco-town subject to meeting specific planning and design objectives…” (Table 4)

Items listed as indicators are not.  They are incapable of measurement.  E.g. the ‘indicator’ for Water Resources and water quality is  “Minimise impacts on water resources and quality.” 

Sewage Treatment Works capacity - Yes" on a green (positive) background?

 In apparent contradiction, lack of sewage treatment capacity is referred to (2.8.5, 3.6) as a problem.

"Decent and affordable homes - Meet housing need - Demand for affordable housing - No" (on a brown) negative) background.   Demand for affordable housing is a ‘negative issue’ although it is a specific objective of the eco-town PPS

2.8.4  Key strengths:

This is simply a list of the promoters’ intentions, without comment.  Corresponding key weaknesses are absent.

2.8.5  This lists points for further consideration. To be added should be:

• Recreational needs

• CPULs

• Community eco-farm

• Allotments

Table 5

The "Draft eco-town criteria" titles do not correspond with the text of the document. Some Indicators are not indicators. For example against "Employment" the 'Indicators" consist of a long statement of intentions.

"Against Water efficiency and drainage" it is stated that "there in no reason why development at this location cannot achieve water neutrality " This statement is in conflict with concerns expressed in 3.5.

The whole analysis undertaken in this table seems to treat the development in isolation - as if it was "separate and distinct". In reality there are another 14000 people who need to be taken into account, who are in living in the town now.

The importance of biodiversity,  green infrastructure and ecological considerations in this area, recognized in  paras 2.7.3 – 2.7.16 and Section 3 Habitat Regulations Assessment, are given little weight here.

HRA

Para 3.9.2 is clear about effects on habitats as a result of the proposed eco-town: ‘It has not been possible… to conclude with confidence that the Whitehill Bordon eco-town would not lead to adverse effects on a number of European sites…’

 3.4.2  notes that the proposed eco-town will undoubtedly bring additional car use and an increase in traffic movements not only on the A325, but also the local roads.  This is in conflict with the principles of alternative means of travel set out in the SA and will seriously erode the landscape character of the area.

CONCLUSION

Whitehill-Bordon presents an extremely high risk of failure if designated as an eco-town with an additional 5,500 houses.

COMMENTS ON THE FINANCIAL VIABILITY APPRAISAL

FINANCIAL VIABILITY STUDY OF THE ECO-TOWNS PROGRAMME : RESPONSE IN RESPECT OF THE WHITEHILL- BORDON PROPOSAL

We understand this study has been designed to assist in the consideration of the deliverability and affordability of developing an eco-town at Whitehill-Bordon.  We consider this location to be high risk and do not consider that the high standards expected from an eco-town, attached as it would be in this case to an existing town, can be met without undue risk to public finances.  The promoter has failed to provide evidence to support the deliverability of any of the key features of their own proposals as set out in 3.3.2.

We enclose below our comments on the three questions set out on p. 7 Section 1.

• Do you consider that as a high level strategic assessment this study has identified the main issues affecting viability?

No - the assessment is based (as repeatedly acknowledged in the report) on material provided by the promoter, some of which is factually incorrect and/or unreasonably optimistic regarding delivery.

Examples of this include : -

3.3.2 . Land . The first statement in the table says that "The scheme at Whitehill Bordon is being promoted by a broad based partnership, led by the public sector. The Executive Group comprises Town, District and County Council representatives ....." and a list of other bodies including Natural England.  Natural England are on the Executive Group, but are opposing the the scheme.  Since the ecological sensitivity of the site is a major hurdle, this is a particularly misleading statement. The views of other members of the group are unknown.

3.3.2. Whitehill Bordon is not "midway between the A3 and the M3". It is some two miles north of the A3 and some 20 miles south of the M3.

3.3.2 Housing.  The calculation for delivery of homes is either incorrect or misleading.  Delivering 300 units annually over 30 years provides 9000 units - not the 5500 units proposed. At 300 per year 5500 would be achieved in a little over 18 years.

3.3.2. Key elements of on and off site infrastructure.  

Transport.   Several of these aspirations are interconnected and their viability is unsubstantiated. They are unreasonably optimistic in the light of Habitats Regulations, which place severe constraints on road improvements due to SPA protected sites straddling the A325 to the north and south.  

“Upgrading the A325 immediately” to provide a “fast bus link” between Petersfield and Farnham is not achievable without both harming the SPA and necessitating compulsory purchase and demolition of a large number of homes and businesses along the route.  Furthermore, any such solution would be unsustainable, promoting more car use and requiring unjustifiable public spending.  In addition another “fast bus link” is proposed along unclassified country lanes to reach Liphook Station and the A3.  This too is unsustainable because it requires road building or widening and is poor value for money. Further, there is no capacity for improvement in peak hour rail services on the Portsmouth line and no commitment from the rail provider to upgrade services.

The "Rapid Transit solution" is unreasonably optimistic. Linking Whitehill-Bordon to the Portsmouth rail line to the south is constrained by the need to cross Woolmer Forest SPA, while to the north bridges and embankments have been demolished and parts of the route of the old rail line are now privately owned.  This key feature is neither financially nor physically achievable. 

3.3.2 Key eco-elements.  Under Environment is the statement "Retro-fitting as many existing houses to PassivHaus standards over 15 years".(sic)  This is unquantifiable and meaningless.

3.3.2 Key elements of s106 package offered.  "Reuse of unused rail infrastructure to link the town to the wider network." This is an over optimistic and misleading statement, implying old but existing lines which might be refurbished. In fact all that currently exists are some cuttings and embankments, the path of the old system remains in places but there is no track, bridges or level crossings.  Some parts of the old track path are in private ownership.  Estimates for reinstating rail lines are in region of £5m/mile plus land acquisition costs.

3.3.3.2 The Base Case assumptions.  The same inaccurate point is repeated here, 300 units being delivered annually over a 30 year period = 9,000, not the 5,500 units on which the scheme is based.

P. 180 C3 1.9(a)  Public Transport.  "Improvement of existing ( but unused ) military rail connection to the network". A misleading and over optimistic statement.  See comments under 3.3.2 Key elements.... above.

• Are there major areas of cost or infrastructure provision and funding or

other issues affecting financial viability which are not identified and could be considered at this stage?

No costs have been included.  This is a major omission.  Much of this report has been based on the promoters' broad intentions with little detailed information provided. The financial information lacks any figures.  It is  essentially a shopping list based on broad assumptions.  There is for example, no demonstrated demand for housing or industrial units in this location.  Many existing industrial units are unoccupied.  The area of MoD land to be made available is uncertain, as is the dates when it may be released. 

Page 41.  The cost of the MoD land is identified in the report as a concern but it is still not clear what parts will be retained, and in consequence what areas will be affected by Habitats Regulations constraints. The retention and re-use of MOD buildings will also limit land availability.

Page 42.  The second paragraph states that "The promoter has advised that around 75% of the utilities infrastructure for electricity, potable water and foul drainage is already in place as part of the MoD site." In respect of water and drainage, this seems unreasonably optimistic, particularly in view of points made in paragraphs 2.7.23 - 2.7.26 of the Sustainability Appraisal and Habitat Assessment Regulations Assessment, which conflict with this statement.

Other issues

The social and economic impact on the existing town of nearly 15,000 people of phased withdrawal by the MoD, including the buildings freed up for reuse, falling school roles and job losses have not been noted, let alone assessed.  This is likely to adversely affect the viability of this scheme.

• Are you aware of evidence which would lead you to different conclusions to those set out here? For example, where the assessment shows a negative financial outcome are there additional public policy reasons (e.g. regeneration or site restoration) which would justify an alternative approach?

Yes, the major conclusion based on available evidence is that since this proposal fails to meet the PPS criteria in several important respects, it is hard to conclude that it should be encouraged to proceed further.  P42 states that "There are also a number of areas for which the Whitehill Bordon Scheme is still developing further strategies in order to meet PPS requirements".  It is currently clear that it cannot.  The proposal is not for a new eco-town as specified in the PPS, but a large extension to and refurbishment of an existing town.

Page 177 C3   The proposal is not "separate and distinct". It is entirely the opposite, in seeking to connect new development with the existing town and including the intention of "refurbishing up to 6400 existing homes."  

It is not "well linked to higher order centres", and cannot achieve this, due to constraints mentioned in 3.3.2 above and particularly since they are over 20 miles distant (Guildford and Portsmouth).

It is hard to see the cost benefit of the new homes proposed in this location. There is no financial or any evidence to support concentrating all of East Hampshire’s housing obligations in this one location.  There is no evidence of  demand for new business premises, as transport links are poor.  Many are currently vacant, and there is no evidence of public support for the proposal.