Archive for April, 2014

Representation from Tony Dixon to all Arun councillors

April 26, 2014 8 comments

Here is the representation from Tony Dixon to all Arun councillors

“Dear members

You are being asked to make the most far reaching decision you will ever be called upon to make in your time as District Councillors – a decision that will have a major impact on the economic and environmental wellbeing of future generations.

Should you support the officers’ “vision” for the district? Or, as members, do you feel there is a better way forward for our district?

Please consider the following points:

Access to/from the A27

Any development at Barnham, Eastergate and Westergate (which will be necessary to fund the road) is instantly flawed because of the additional traffic that will be caused by the development itself. A development of 2,000 plus houses located between Bognor Regis and the A27 could bring up to 3,000 extra vehicles onto the A29 (based on 1.5 cars per household). These extra vehicles will be located slap-bang between Bognor Regis and the A27.

How will the residents of 2,000 new houses join the new road ? … more roundabouts perhaps?

Is the replacement of one level crossing and a mini roundabout with up to 6 new roundabouts, and around 3,000 extra cars feeding in to them, an improvement on the current situation?

This will almost certainly make access to/from Bognor Regis worse and act as a disincentive to potential employers!

Has the council provided you with any evidence to show that the proposed new road will be an improvement on the current situation? Where’s the modelling?

Has the council considered the possibility of a third and additional route to/from the A27 for Bognor Regis, linking the A259 at Comet Corner to the A27, bridging the railway line at Ford, and connecting Bognor Regis to the SRN in the east (A24 and A23 – both of which are dual carriageway)? This would spread existing and new traffic over three routes rather than the current two. It would also combine with the A27 and A259 to form a “ring road” around the Five Villages.

Have your officers even considered linking Bognor Regis to the SRN in the east?

Duty to co operate

What happens if the Inspector at the EiP increases the housing number? Would it be better to identify a location that can accommodate future growth?

By excluding the largest brownfield site in West Sussex from the Local Plan, will this make it more or less likely that Arun is required to make provision for additional housing on behalf of Worthing and others?

Brownfield land

One of the 12 core planning principles of the new NPPF is that planning should “encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental value;

Paragraph 13.1.14 of the draft Local Plan states:  The development of land that has not previously been developed (greenfield) should only be considered where brownfield land cannot be developed.”

By prioritising greenfield development ahead of brownfield development could that jeopardise the Local Plan?

Cabinet and Officers will argue that only the runway counts as brownfield. The old PPG3 definition used to include the curtilage. (Presumably the curtilage was included to avoid runway shaped developments!!). Within the curtilage of the airfield there are 268 acres of brownfield land (making it the largest available brownfield site in West Sussex). I’m not sure if the new rules would include land up to the curtilage or not?

Developer contribution for an Arundel Bypass

The NPPF makes it clear that local planning authorities should take account of the need for strategic infrastructure including nationally significant infrastructure within their areas.

The then Transport Minister Philip Hammond brought our local infrastructure deficit into sharp focus when he advised a delegation from Sussex in 2011 that, although there was no funding available for an Arundel Bypass, if it was possible to get developer contributions the government would be more willing to look at doing something.

Can your officers demonstrate to you that they have properly explored the possibility of a developer contribution towards an A27 Arundel Bypass?

(By contrast, in order to make progress in these difficult times Chichester and WSCC are putting up £20 million towards improvements to the A27 to be funded through a combination of developer contributions and provident loans).

The A27 Arundel Bypass Wider Economic Impact Study by Parsons Brinkerhoff in March 2013 said:

“Based on the extensive Business Survey undertaken in the area and initial analysis, the preliminary results indicated the following:

An additional £493m would be added to total West Sussex GVA of £15.257bn;

Employment Impact: an additional annualised total of 12,600 jobs would be added throughout the seven districts in West Sussex;

Personal Income Tax Receipts: across all seven districts, an annualised total of £82m would accrue to Government in the form of personal income tax receipts from new employment;

Reductions in Jobseekers’ Allowance: across all seven districts, Government would gain approximately £38m from reductions in Jobseekers’ Allowance payments;

Increase in Disposable Income: the increases in employment will support additional disposable income being spent in the county. The preliminary estimate of this is £108m throughout all seven districts;

Attracting investment: the existence of the Arundel Bypass will remove the current bottleneck on the A27 and will significantly improve the ‘attractiveness’ of the corridor in terms of attracting investment and inducing land development (through distribution centres and business parks etc);”


The main objective with village extensions (albeit in this case dressed up as a new settlement!) is to utilise and therefore increase pressure on existing infrastructure like health facilities, schools, roads, sewage etc.

Genuine new settlements, on the other hand, provide their own infrastructure – placing much less burden on existing infrastructure, effectively spreading the pressure.

For instance, the existing sewage network across the district already struggles to cope. A new settlement at Ford would utilise the adjacent sewage works, placing no additional pressure on the existing network.

A new settlement on Flood Zone 1 land at Ford would reduce the risk of flooding in areas like Felpham and Middleton (which are downstream from the council’s proposed strategic allocation at Barnham, Eastergate, Westergate) – with easy drainage to the River Arun.

Members should demand that any strategic locations identified in the Local Plan MUST

  • Be on flood zone 1 land
  • Have no urban areas downstream
  • Provide easy drainage to the sea
  • Not utilise the already overburdened rifes for drainage
  • Not, in any way, add to, or make worse, any existing flood risks/problems

The Local Plan is unlikely to resolve the existing flooding issues but we can try to make sure it does not add to the risks/problems.

A single new settlement can offer infrastructure contributions on a far greater scale than a number of smaller developments peppered across the district.


Arun’s main industries are traditionally horticulture/agriculture, tourism and retail. In essence Arun is a low-paid and largely seasonal economy compared with other parts of West Sussex.  Our problem is not unemployment – it is low pay.

To drive average wage levels up Arun will need to focus on creating better paid employment outside the tourism, retail and horticultural/agricultural sectors.

The lower the average wage the greater the need for affordable housing is likely to be. Arun has a deficit of affordable housing.

Low wage levels create an unacceptably high level of outbound commuting. Currently around 37 per cent of the working population leave the district each day to work creating substantial road congestion, particularly at peak times.

The Living Wage is a voluntary rate of pay designed to enable workers to afford a basic but acceptable standard of living.  The rate is currently £8.55 an hour in London and £7.45 outside – compared to the national minimum wage which stands at £6.31. New research for KPMG shows that Arun District has the highest number of people earning a salary below the living wage in the south east.

Over 34% of the 31,000 jobs in Arun pay less than the living wage, which means that Arun has the lowest living wages in the entire south east. By contrast, nationally 21% of jobs pay below the living wage. The south east average is 18%.

According to Nomis the average gross weekly wage for those working in Arun in 2010 was £399 – the lowest of the seven councils in West Sussex. This compares to a West Sussex average of £479 (20 per cent higher) and a South East average of £523 (31 per cent higher). The national average is £500 (25 per cent higher).

Arun ranks 63rd out of 67 local authorities in South East England when it comes to the ratio of jobs to population aged 16-64. (Jobs Density).

The 2003 Local Plan has failed to attract employment interest for the Oldlands Farm site. In spite of this, the council remains committed to planning its employment provision in this area.

Proposals for Airfield Park (or is it now Enterprise@BognorRegis) seem fanciful and the council does not appear to have a strategy to attract employers to Airfield Park.

Most of Airfield Park is in Flood Zone 3 (land most at risk from flooding). What businessman in his right mind will locate his business in Flood Zone 3?

In a choice between Tangmere and Airfield Park employers will choose the one that is nearest to the A27. A local company Respironics (now owned by Philips) moved from Bersted to Tangmere to be closer to the A27. The council appears to have learned no lessons from this. Any business park needs to be close to the A27 to succeed.

One of your cabinet members is promoting a horticultural hub – yet at the same time existing viable horticultural employment sites at Angmering (80 jobs?), North Littlehampton (200 jobs?) and Eastergate (100 jobs?) are to be closed so that the sites can be used for housing? That’s minus 380 jobs before we even start creating more low paid horticultural jobs!

There are many pressures on members now. There is a risk that the council is in such difficulty that it has reached a stage where anything will do – as long as it’s quick! There is a genuine risk that you will now be pressured into a bad decision.

For those of you who are open-minded enough to have read this far – thank you.

Good luck with a very difficult decision – I hope that you will make the only sound decision available to you and reconsider Ford Airfield!”




Cabinet Office has recommended that Arun District Council should initiate a new OJEU process

Following an investigation through its mystery shopper scheme (an informal investigatory service for suppliers and other interested parties who have concerns about the conduct of a procurement process), the Cabinet Office has recommended that Arun District Council should initiate a new OJEU process with regard to the Bognor Regis regeneration proposals.

The cabinet Office said:

“Many thanks for bringing the Bognor Regis Town Centre development agreement to our attention. 

On the basis of the information you have provided we have discussed your concerns with Arun District Council, who have informed us that the development agreement has been extended to 31 December 2014 and that they are continuing to explore a number of options.  

Cabinet Office has subsequently recommended that a new OJEU process should be initiated, and the Council’s representative has confirmed that they will make all officers and members dealing with the matter aware of this recommendation.”

This is the text of two e-mails from Tony Dixon to the Cabinet Office:

E-mail sent to Cabinet Office 26th December 2013


I am concerned that Arun District Council is in breach of the OJEU directives on public procurement.

I raised this with DCLG and they advised that, after consultation with colleagues in the Cabinet Office,  the best way for me to raise this matter was through the Mystery Shopper channel, which, I am advised is open to the public.

DCLG also advised me that I can raise an infraction complaint with the EU commission, which I will also do.

Arun District Council, awarded a contract to a developer called St Modwen in 2006. The value of the winning bid was over £100 million.

Since then the project has been substantially changed from the original winning bid and Mr Tim Seddon of St Modwen advised Full Council in November that the project was now valued at £25-£40 million.

This is a substantial deviation from the winning bid and I am concerned that it constitutes a breach of the OJEU directives.

I have attached:

a) The original invitation to tender

b) The contract award notice

Could you please investigate this matter.

I would appreciate it if you could acknowledge receipt of this complaint.

Yours sincerely

E-mail sent to Cabinet Office 4th January 2014

Dear Stephen

Many thanks for your response.

I understand your scope and remit much better now and fully understand why it is not possible to consider such a matter through both routes.

I would like to request that the Cabinet Office does investigate this matter through the mystery shopper route, and so, to facilitate this, I have written to the EU to withdraw my infraction complaint.

I want to take this opportunity to expand my concerns a little more:

As you are already aware, I am concerned that Arun District Council may be in breach of the OJEU directives on public procurement. The council awarded a contract to a developer called St Modwen in 2006. The value of the winning bid was over £106 million.

Since then the project has been substantially changed from the original winning bid and a representative of St Modwen advised Full Council in November that the project was now valued at £25-£40 million. (You will see that the figure debated in the council minutes is £40 million. In fact, the figure quoted by St Modwen was £25-£40 million and that is what was reported in the Bognor Observer on November 14th 2013). See here for the minutes

At the Special Full Council in November the council voted to extend the period of the development agreement for another year, in the full knowledge that the scheme is now valued substantially lower. It has, in essence, accepted the £25-£40 million figure.

This is a substantial deviation from the winning bid and I am concerned that it may constitute a breach or infraction of the OJEU directives.

I want to draw your attention to a Freedom of Information request on – see . and to comment as follows:

The council’s Senior Regeneration/LSP Manager, in internal correspondence, states that “… the basic elements of the scheme are the same, but without all the flashy add-ons …”. That would value the “flashy add-ons” at somewhere between £66-£81 million! This is “spin” to disguise the fact that something like 86% – 69% of the scheme is being removed.

In the FOI information the council advises DCLG of the consultations it has undertaken, but does not make it clear whether this was for the £106 million “winning bid” or the scheme now reduced by £66-£81 million. I am concerned that the final scheme cannot possibly be close to the scheme the council has already consulted on and that the council may now be using those consultations inappropriately to justify a much smaller scheme.

I note from the FOI correspondence that DCLG has stated “it is not the role of DCLG to intervene in local matters. It is very important that local authorities act independently of central government …” I assume that is why DCLG has suggested the mystery shopper channel instead.

Kind regards

Tony Dixon said in a statement today;

“The fact that the Cabinet Office has recommended that Arun District Council should initiate a new OJEU process with regard to the Bognor Regis regeneration proposals clearly calls into question Arun’s conduct in this public procurement process.  

I call on the council’s leader, Cllr. Mrs Brown, to accept full responsibility and resign.”