Memorandum submitted by Cambridgeshire
Horizons
MEMORANDA
The proposed Eco-town development
at Hanley Grange will have a negative impact on planned developments
in Cambridgeshire and in particular on the delivery of the prototype
Eco-town of Northstowe.
There are a number of issues around
accessibility and the remote location of Hanley Grange.
As our currently proposed Eco-towns
will have a limited effect on reducing the environmental impacts
of housing and by-pass the plan-led system which has been strongly
promoted by the government.
Enforcement of the code for sustainable
homes and zero-carbon targets may prove challenging and resource
hungry.
"Zero carbon" should be
measured from whole community impacts, and not just housing.
1. INTRODUCTION/SUMMARY
1.1 Cambridgeshire Horizons is the local
delivery vehicle charged with delivering sustainable housing growth
and additional infrastructure for the Cambridge sub-Region. This
response sets out our views on the emerging Eco-towns agenda,
and has been agreed with our local authority partners in Cambridgeshire
(Cambridgeshire County Council, Cambridge City Council, South
Cambridgeshire District Council, East Cambridgeshire District
Council, Fenland District Council and Huntingdonshire District
Council).
1.2 Cambridgeshire Horizons and its local
authority partners support the principle of developing low and
zero-carbon growth, and we are actively seeking to create exemplary
sustainable new homes and communities in the Cambridgeshire area,
one of the fastest-growing parts of the country, which will meet
housing needs, mitigate impacts on the environment and adapt to
the challenges posed by climate change.
1.3 There is a need to ensure our understanding
of the term "zero-carbon" includes all the major carbon
impacts of growth (such as transport and provision of key services)
and does not focus solely on impacts arising from the design of
the new homes themselves. New developments cannot be treated in
isolation, as their carbon footprint will depend on their relationship
to existing communities and infrastructure already in place. Furthermore,
we should be seeking to ensure lessons learnt from delivering
low or zero-carbon growth can then be applied to deal with the
much bigger problem of reducing emissions from the existing housing
stock. In relation to these points, Cambridgeshire Horizons and
the local authorities of Cambridgeshire have very serious concerns
regarding the proposed eco-town at Hanley Grange in South Cambridgeshire.
1.4 Cambridgeshire Horizons, South Cambridgeshire
District Council, and Cambridgeshire County Council are already
fully engaged in bringing forward an ambitious growth agenda,
including the prototype Eco-town of Northstowe, planned for around
9,500 houses on a former airfield site to the north of Cambridge.
Northstowe will be the largest new town to be developed in the
UK since Milton Keynes, and needs to provide an example of what
can be achieved in terms of sustainable growth for the new settlements
will follow. It is a massive and challenging project, which will
require significant effort and resources from all concerned if
it is to be the kind of development all want to see delivered.
Northstowe will be located on a guided busway is currently under
construction and represents a significant investment (£92.5
million) of public resources. High-level sustainability principles
will be built into all our planned growth sites, and the proposals
for Hanley Grange jeopardise our ability to deliver on these ambitions,
as they will (and indeed already have) resulted in the diversion
of already scarce resources within the public and private sector,
which in turn will slow down the delivery of homes at Northstowe
and the other already-planned development sites around Cambridge,
and put at risk the quality of those developments. Local planning
and technical resources are already severely stretched by the
complexity and ambition of the current growth programme. In particular,
placing an additional new settlement within South Cambridgeshire,
which is the planning authority for Northstowe and for several
other major sites on the Cambridge fringes, would stretch beyond
breaking point their resources, and diminish their ability to
deliver the significant growth already planned.
1.5 The Hanley Grange site is isolated from
the existing public transport network and is bounded by a number
of major roads, all of which are already showing signs of strain
from increased usage. It is likely this isolation from existing
major settlements would result in a car-dominated settlement,
putting further pressure on congested roads and worsening our
carbon emissions problem. The site is relatively close to the
overstretched Liverpool Street to Cambridge rail line, but not
so close to avoid rail corridor being most likely to be accessed
by car by the new residents. It is also fairly close to Stansted
Airport, and it seems predictable this would make the new town
primarily desirable to long-distance commuters, further raising
questions about its ability to deliver sustainable growth and
the promoters' promises of high levels of local employment. The
proposed site overlies an aquifer which supplies drinking water
to the Cambridge area and rather than being previously developed
land, it is almost entirely high quality grade 2 agricultural
land.
1.6 The Environmental Audit Committee has
stated its concerns recently built settlements risk becoming "climate
slums" unless changes to the planning system are made. The
process used for Hanley Grange by-passes the current regional
and local plan-led process, and has not allowed for democratic
input and detailed public comment, or technical analyses, which
could enable a proper assessment of whether an eco-town here could
contribute to the overall growth strategy for the area. We would
hope the Committee could support our arguments against this unwelcome
development.
2. REDUCING CARBON
EMISSIONS FROM
NEW HOMES
2.1 Is the target for all new homes to be
zero-carbon by 2016 on track to be achieved? Does the Government
need to do any more to deliver this target?
The planned new settlement of Northstowe
is intended to be an exemplar of zero carbon development and sustainable
design techniques There will be a number of cost impacts, and
it will be crucial the government provides funding support to
allow ambitious carbon targets to be deliverable within a commercially
viable package. Promoting Northstowe to full Eco-Town status and
making additional growth area moneys available for zero-carbon
development to be delivered earlier than 2016 would help test
building techniques and technologies, which could then benefit
future development elsewhere in the country.
2.2 How should "zero-carbon" be
defined? What role should carbon offsets play in meeting this
target?
Zero-carbon should be measured from
"whole community" impacts, taking into account transport,
services and connectivity, not just housing.
2.3 What impact will the progressive tightening
of energy efficiency building regulations have up to 2016? Are
the targets for 2010 and 2013 achievable?
The ambitions in the regulations
are welcome, but there remain difficult issues around the extent
to which these targets can be met within the bounds of commercial
viability.
2.4 How should compliance with the targets
be measured and enforced?
It seems likely local authorities
will be given responsibility to measure and enforce zero carbon
targets, but additional funding would need to be provided to enable
enforcement to be effective.
2.5 What is the likely scale of environmental
impacts (especially carbon emissions) of the construction of three
million new homes (ie, irrespective of where they are sited)?
How should these impacts be reported? What should be the role
of central Government in minimising them?
Impacts need to be reported on a
national basis, and again it will be crucial to capture the wider
picture around carbon emissions from new developments, not just
looking at housing in isolation. The principle of sustainable
development must include looking at these "whole community"
carbon costs, which puts further emphasis on locating major new
developments in the most sustainable places, generally close to
public transport nodes and existing urban areas, rather than in
isolated areas.
3. ECO-TOWNS
3.1 As currently envisaged, how big a contribution
will they make to reducing the environmental impacts of housing
in England-both in their own right, and in the development of
design and techniques could be rolled out in other developments?
Freestanding small new towns, such
as Hanley Grange, proposed in the Government's Eco-Towns initiative
may be too small to be relatively self contained for employment,
services and facilities, and of insufficient size to support internal
public transport services. A much more sustainable approach is
to expand existing towns and cities, building on the relative
sustainability, and developing those towns which are too small
to be truly sustainable to a size which will enable them to be
more self contained.
Potentially, eco-towns could make
a major contribution to reducing the environmental impacts of
development, but only where town expansion is not feasible and
where they will complement existing settlement patterns and transport
networks. They need to be contributing more than just additional
numbers of dwellings by providing a balance of homes, jobs and
services. These objectives can normally be best achieved by taking
any new town options forward through the plan-led system, with
the backing of local authorities wherever possible. Northstowe,
already a prototype eco-town, will be critical in showing what
is possible, and must not be derailed by the proposals for a far
less sustainable development at Hanley Grange which is proposed
on similar timeframes. Future eco-towns will be able to learn
from the techniques and results of Northstowe, which is why we
must ensure we do not jeopardise our ability to deliver excellence
there, and indeed our other major development sites. Eco-towns
should link in with the local authorities' place-shaping agenda,
rather than being parachuted in from above.
4. CODES FOR
SUSTAINABLE HOMES
4.1 What impact is the Code for Sustainable
Homes likely to have on the construction and purchase of new homes?
How well is the mandatory rating likely to be enforced? Should
the Code be changed in any way?
In general the CSH should have a
positive impact, however enforcement may prove challenging and
bring additional cost impacts on local authorities. It would be
helpful if resources to be channelled into eco-towns could be
reconsidered for helping to promote faster take-up of higher environmental
standards in new communities already in the planning pipeline.
5. GREENFIELD
AND GREEN
BELT DEVELOPMENTS
5.1 To what extent do, and should, planning
controls protect greenfield and green belt land from development
of new housing? How adequately are environmental considerations
(for instance, biodiversity and rural landscapes) being taken
into account in deciding the location of new developments?
Cambridgeshire has already been engaged
in reviewing greenbelt provision and has removed some land off
green belt protection to enable us to meet housing targets. A
more sophisticated approach than blanket bans on greenbelt development
may be useful for bringing forward future sustainable developments,
but a focus on retaining sufficient high quality green infrastructure
alongside new housing development is central to maintaining quality
of life for new and existing residents, as well as protecting
and enhancing biodiversity and mitigating wider climate change
impacts. The Green Belt should remain a key planning tool to protect
those qualities for which are designated, and should not be seen
as a means to stop development.
6. INFRASTRUCTURE
6.1 What progress has the Government made,
in the two years since EAC's last report on this issue, in ensuring
new developments are being built with adequate infrastructure
in order to make them successful and sustainable?
The jury is still out. Transport
and water are particular issues in the East of England, especially
if we are committing to zero carbon for the huge scale of growth
we are trying to deliver in Cambridgeshire and the wider region.
The funding provided to assist in the delivery of the guided busway,
from Cambridge to Northstowe and beyond, has been of great assistance
in underpinning the environmental credentials of Northstowe. We
believe eco-investment should be consolidated here and in other
growing communities rather than dissipated in speculative proposals
such as Hanley Grange.
25 April 2008
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