West Midlands Business Council Response to DCLG Consultation Paper ‘Eco-towns – Living a greener future’ April 2008

Introduction

The West Midlands Business Council (BVWM) brings together the independent business representative organisations to speak with one voice on the key regional business issues. It is an umbrella organisation for the whole West Midlands region – covering Herefordshire, Shropshire, Staffordshire, Warwickshire, & Worcestershire together with Birmingham/Coventry/Wolverhampton and the West Midlands conurbation.

The West Midlands Business Council welcomes the opportunity to respond to the Government consultation on eco-towns. There has been much debate, and considerable variation in understanding, about the eco-town as proposed in the consultation document. However, whilst we support the concept of eco-towns we are clear that they must go well beyond large estates of energy efficient homes.  In terms of sustainable build, sustainable development and sustainable communities we consider that the proposals do not take an holistic enough approach and will fall well short of delivering this to best advantage. Eco-towns must not simply be ghettos of ‘green build’ housing estates. In particular we have grave reservations about location and design of the proposals, as well as the process.

Location

We are especially concerned that the requirement for eco-towns to be separate and distinct from existing towns or settlements is neither desirable nor practicable if sustainability in anything other than buildings is to be achieved. Even then there is the question as to how sustainability is defined – if it is looking for carbon neutrality does it take into account the carbon attributed to the sourcing and manufacture of the building’s components or does it just refer to the energy efficiency of the building?

Developing eco-towns away from other settlements essentially leaves them isolated, requiring a range of transport links which are not readily available on all of the sites proposed and access to services, facilities and employment that are most likely to be ‘off-site’. For both sites proposed within the West Midlands the car is the most obvious mode of transport for every day linkage – this does not bode well for reducing carbon emissions. Options such as heavy or light rail will be cost prohibitive to deliver and indeed existing road networks will need significant investment to satisfy so many dwellings.

Indeed the real ‘mixed use development’ which one might argue is potentially the most sustainable does not fit at all readily into this consultation’s vision of eco-towns.

We firmly believe that the future for eco-towns should be the incorporation and development of the eco-towns concept as an essential and mainstream part of local redevelopment and regeneration. An example of this is what Birmingham is doing with the redevelopment of the Longbridge former car factory site. Here, all elements of a sustainable community are being addressed in order to make the phoenix from these ashes, a place that offers not just green buildings, but the prospect of a green and sustainable lifestyle in terms of access to and provision of facilities, services, education and employment.

Sustainable communities require a proper mix of population from a range of backgrounds, households and employment. There is a great emphasis on the inclusion of affordable homes in eco-towns, however there insufficient reference paid to other types of ownership or occupation such as private or social rented sectors. We do not have confidence that either these sectors, or the commercial, retail, employment or other services provision, will be adequately addressed or catered for in order to create balanced communities.

Eco towns must have commercial property in order to encourage business investment and avoid them becoming dormitory towns. This must be varied in range in order to both serve the community, in terms of retail and leisure, and provide employment of all types. This would be an ideal opportunity to provide starter units within a development and encouragement for businesses with a ‘green focus’ would be particularly apt.

Numbers  

We have grave concerns that this is driven by a numbers game to meet government targets. However, the number of dwellings proposed are in effect ‘a drop in the ocean’ in relation to those required overall and this initiative is just providing yet another diversion from the real task of delivering dwellings under the current RSS. Nationally we are failing to deliver up to target year on year, thus effectively increasing the deficit. If we add to this the impact of the current economic and financial climate that is adversely affecting construction, and very specifically house-building sector, then we face the serious prospect of even lower delivery in the current and next year at least. Eco-towns may, on the face of it, seem an easy option by offering the prospect of house-building in greener areas but with the necessity to provide infrastructure and services we suspect that they are rapidly becoming less attractive to any developer.

Process

We have very considerable concern that the proposed eco-towns seem to be out of the loop of normal planning procedures. They do not fall under current RSS proposals and indeed in the West Midlands at least, run completely contrary to the key tenet of the RSS of delivering urban renaissance - with the majority of dwellings within the key urban areas and appropriate additional capacity shared out amongst smaller settlements that have the capacity. It is particularly unclear as to whether the eco-towns will replace an authority’s existing RSS commitment or be additional to it. This could have a severe impact either way and has certainly not been subjected to the robust sustainability scrutiny and consultation required through the RSS.

For example, if an eco-town of 5000 dwellings is built just outside an existing settlement that already has a commitment under the RSS to a similar number of dwellings carefully parcelled out around area, can the local authority renege on its RSS commitment? We know from the extensive work that has been carried out in order to place RSS housing numbers that infrastructure and services will be unable to cope with the additional numbers of the two proposed here without significant investment, planning and development.

We would also suggest that if the proposal intends that the process for these settlements should be fast tracked, that it runs roughshod over all sectors of the community, including the business sector that have contributed to the RSS process. It also is far from guaranteeing any delivery at all and we would certainly not condone any move towards preferential treatment from government to achieve such development.

Response to questions within the document

Low and Zero Carbon energy sources requirement

We believe that whilst energy production on site is an option that should be given full consideration, it should not be either mandatory or the automatic choice. There should be opportunities to use both on and off-site production depending upon suitability, location and, above all, which solution gives the best all round low or zero carbon emissions. This should be driven by a range of issues that include cost effectiveness, efficiency, reliability and practicality. Funding mechanisms, whether public or private, should not be able to be used as ‘get out clauses’ for avoiding addressing this issue properly.

With regard to energy efficient construction we support the ambition to require build quality to high energy efficiency. However we believe that there needs to be some pragmatism and reality taken on board, that recognises the very significant cost differentials for taking build from Sustainable Homes level 4 to either 5 or 6. The incremental benefits need to be fully justified and they could perhaps be achieved by focus on alternative things such as encouraging lifestyle changes. There is also the necessity of ensuring that energy efficiency measures will take account of climate change so that a highly insulated house will not then need energy intensive air conditioning as our climate gets hotter.

With regards to terminology we feel that it is important that terms such as ‘zero carbon’, and indeed ‘sustainable’, are clearly defined for these purposes so as to give clarity and consistency to their interpretation and application.

Water and flooding

These are concerns that exist for all communities whether existing or proposed eco-towns. However in this current context we are clear that both mitigation and avoidance will be necessary here. Obviously the preference should be to avoid building on flood plains, however we recognise that is not always possible and besides which we have more recently seen that flooding is not always confined to such areas. Therefore appropriate measures for mitigation from design and build to grey water harvesting should be actively considered.

In the West Midlands, future water supply is also a matter of considerable concern to deliver current obligations let alone additional dwellings. There would need to be recognition of this alongside guarantees of additional resources that are both timely and adequate.

Homes/ housing

Settlement densities:

We believe that density levels of development within the eco-towns should be variable throughout the development for differing types of housing, commercial and other land use. However, we do feel that it is particularly important that there should not be obvious differentiation between types of housing (ie private, affordable or social) by reference either to density or build as this can be divisive.

Construction materials:

We believe that consideration in terms of carbon emissions should be given to construction materials, balancing locally sourced versus long distance alternatives. There are many aspirations to seek more local ‘green’ material yet they are often beyond reach as the supply chain is not or can not be established.

We also consider that whilst innovative and radical design can be exciting and desirable, it is not always so. Whilst there may be a desire for certain elements of the eco-towns to have a different look and feel about them there is also a need to create places where people can feel comfortable and literally ‘at home’ so that use of materials and styles that fit with the local architecture have a place too.

Conclusion

As stated at the beginning of this response we support the concepts behind eco-towns, however we feel that there are significant issues with the proposals contained within the consultation document. We remain convinced that the most effective, cost efficient and practical way of delivering greener homes and exemplar settlements is by ensuring that any redevelopment and regeneration that takes place is planned so as to achieve sustainable communities in the widest sense of the phrase. This will also enable the retrofit of existing dwellings (by far the greater part of our housing stock, that contributes very significantly to CO2 emissions) to be included rather than excluded in the drive for sustainability.

If you wish to pursue any points raised in this submission, please contact:
BVWM Executive Director, James Watkins, on 0121 245 0138/0776 5803582

F: 0121 245 0141
E: j.watkins@businessvoicewm.org.uk  
www.wmbusinesscouncil.org.uk

FOR INFORMATION

The member organisations of BVWM are:

Asian Business Forum
Association of Colleges
British Ceramic Confederation
Business in the Community
Chartered Institute of Building
Confederation of West Midlands Chambers of Commerce
Co-operatives West Midlands
Country Land and Business Association
Engineering Employers’ Federation
Federation of Small Businesses
Institute of Chartered Accountants in England and Wales
Institute of Chartered Secretaries and Administrators
Institute of Directors
Institution of Civil Engineers
Midland Association of Restaurants, Caterers and Entertainment
National Farmers' Union
National Federation of Retail Newsagents
Royal Institution of Chartered Surveyors
UK IT Association
West Midlands Developers Alliance
West Midlands Higher Education Association
West Midlands Learning and Skills Councils
West Midlands Minority Ethnic Business Forum