Suffolk Coastal District Council Melton Hill, Woodbridge, Suffolk IP12 1AU Tel: (01394) 383789 Fax: (01394) 385100 Minicom: (01394) 444211 DX: Woodbridge 41400 Website: www.suffolkcoastal.gov.uk
Programme Officer - Annette Feeney Please ask for: Hilary Hanslip Room 123 Direct Dial: (01394) 444761 Council Offices E-mail address: hilary.hanslip Melton Hill @Suffolkcoastal.gov.uk Woodbridge Our Ref: PJR/EIP2 IP12 1AU Your Ref: letter 6th June 2012
6th July 2012
Dear Mrs Feeney,
SUFFOLK COASTAL CORE STRATEGY AND DEVELOPMENT MANAGEMENT POLICIES
I refer to your letter dated 29th June 2012 in which the Inspector has outlined a number of further queries on which he is seeking a response ahead of the Pre-Hearing Meeting to be held on 12th July and the Exploratory Meeting which is scheduled to precede it.
Attached to this letter is the Council’s detailed response to each of the matters raised for the EM.
You will recall that the Council had previously indicated that it was proposing to submit a schedule of suggested main modifications with this letter. Correspondence to date has indicated where a main modification is being suggested. The same approach has been taken in this letter also.
Reflecting further on this matter, the Council is now of the opinion that a detailed schedule of suggested modifications is actually best left to submission alongside the hearing statements on 28th August 2012. This will provide the opportunity for the Council to discuss suggested rewording with some respondents and also link the changes to specific matters and issues through the hearing statements.
However, if the Inspector would prefer to see an initial schedule, or specific, main modifications at this time, please let me know.
Yours sincerely
Philip Ridley BSc (Hons) MRTPI Head of Planning and Coastal Management - Suffolk Coastal & Waveney District Councils
Suffolk Coastal…where quality of life counts
Council response to Inspector’s Exploratory Meeting Questions – 6th July 2012
1. Housing
Identifying the objectively assessed housing needs
1.01 Two evidence documents provide the assessment for market and affordable housing for the District through the plan period. Both documents were prepared at a time when the EoEP (core document reference: C7a-1) was close to or just adopted. It is the EoEP which provided the objectively assessed scale of development and the policy context for each document (510 per annum for Suffolk Coastal between 2001 - 2021).
1.02 The Suffolk Coastal Local Needs Assessment (LNA) (core document reference: C1a-1) identifies affordable housing requirements for the District. Figure 136 (p. 126) provides details of the 5-year housing requirement by property type and size. This confirms the requirement for 24% of all new homes to be affordable. It does not specifically address how this should be provided in practice. This is the role of the CS.
1.03 CS paragraph 3.53 makes specific reference to the study. Paragraph 3.54 picks up the recently adopted policy from the Suffolk Coastal Local Plan 2nd Alteration, adopted March 2006 which sets the thresholds as to when affordable housing will be required to be provided which are on developments of 3 or more homes in villages and 6 or more homes at towns. This picks up on viability issues, recognising that not all sites will be capable of providing affordable housing, or providing it on site. Policy DM1 takes this provision a step further on rural exception sites in that it would allow one in three new homes to be open market. This new approach, which was very well received by Members, is now interestingly picked up in the Framework.
1.04 Chapter 2 of the LNA provides useful information in relation to housing market areas (see Figure 5 p. 19). It confirms the influence of Ipswich within the district.
1.05 The second evidence base document which provides an objective assessment of needs is the Ipswich Housing Market Area Strategic Housing Assessment; and associated key findings report and viability study (core document reference: C1a-2 to C1a-4). The report was jointly commissioned by the four Ipswich Policy Area authorities, Ipswich Borough, Babergh, Mid-Suffolk and Suffolk Coastal District Councils. The requirement was for the consultants to produce a robust study report to help the authorities to understand the housing market within which they are operating; and to better influence supply issues in order to help produce a balanced housing market. Again levels of development were based on those within the EoEP. It confirms the sub-market areas which operate within the District which the LNA had also picked up. Core document C1a-2 provides a summary of the Key Findings.
1.06 The findings from each of these documents are picked up more generally in the CS in Chapter 2 Portrait of Suffolk Coastal – ‘Where we are now’. This chapter also provides an important link with the Local Strategic Partnership and the Sustainable Communities Strategy.
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1.07 As noted, the policy context for both evidence documents and the objectively assessed scales of development envisaged was the EoEP adopted May 2008. It remains the case, that for any comparative work undertaken now, or later under any duty to cooperate on strategic matters, that the EoEP as adopted, provides that objective assessment for all Suffolk authorities.
1.08 It has also now been clarified at the national level, that for the purposes of policy preparation, that regional spatial strategies (the EoEP) are still a formal part of the Development Plan and CS’s are therefore required to be produced in broad conformity with them. This followed the confusion as to the legal status of the RSS’s following the challenge by Cala Homes to the Secretary of States decision on 6th July 2010 to abolish them with immediate effect (core document reference: B3-3).
1.09 In light of the above, it is the view of the Council that the objectively assessed need for the District should be for a mix of house size and type as set out in CS Table 3.5 (p. 31)* using evidence which was based on a scale of development of 510 per annum as set out in the EoEP. The scales of development in the adopted EoEP were themselves objectively assessed and tested through independent examination. It is perhaps a grey area though, as to whether that objective assessment can be said to extend beyond the timeframe of the EoEP ie. post 2021. (This is addressed in more detail in response to the following question). Of the total number of new homes, 24% should be affordable.
* Table 3.5 is subject to a minor modification due to a drafting error at publication stage and should read as follows:
Table 3.5 TARGET PROPORTIONS OF HOUSE SIZES Bedrooms Open Market Housing Affordable Housing All Sectors 1 6% 43% 13% 2 32% 31% 32% 3 39% 16% 35% 4+ 22% 11% 20% Due to rounding columns may not add up to 100% Table to be updated on a regular basis to reflect latest published guidance
Objectively assessed housing needs and the CS
1.10 The question as phrased makes specific reference to needs in the District. The Council has interpreted this as meaning all of the District including those needs and scales of development which are attributed to the Suffolk Coastal part of the IPA.
1.11 It is accepted that the EoEP housing numbers as rolled forward to 2027 is the starting point for objectively assessing the need for the whole plan period. The residual requirement for the period 2010 – 2027 would therefore be 7,910 compared to the 7,590 in the CS. This is a marginal shortfall of 320 dwellings over a 17 year period, i.e. a shortfall of only 2.5% overall, or 19 dwellings per annum. The Council considers for reasons set out below that this minor difference still confirms that the CS is in general conformity with the RSS but that if the Inspector has
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concerns about the rationale for the approach set out below the Council is prepared to propose a modification that increases the figure to 7,910.
1.12 The Council considers that there is a small element of doubt in terms of what can be considered to be properly objectively assessed need post 2021, the end date for the EoEP.
1.13 For housing, EoEP Policy H1 confirmed that the annual requirements should be rolled forward beyond that date in order for LPA’s to be able to provide a 15 year housing land supply in accordance with the then national policy guidance PPS3. For Suffolk Coastal this meant a continuation of the 510 dwellings per annum. Reference was made to the imminent review of housing numbers to update them to 2031.
1.14 EoEP Policy E1 provides indicative targets for job growth. For the District and the IPA, this is included within a Suffolk Haven Gateway figure of 30,000. Linking the two elements the section: Vision and Objectives (p. 6) states:-
(ii) To address housing shortages in the region by: • Securing a step change in the delivery of additional housing throughout the region, particularly the key centres for development and change; and • Giving priority to the provision of affordable housing to meet identified needs, (iii) To realise the economic potential of the region and its people by: • Facilitating the development needed to support the region’s business sectors and clusters…. • Providing for job growth broadly matching increases in housing provision and improving alignment between the locations of workplaces and homes; …… • Ensuring adequate and sustainable transport infrastructure
1.15 The CS, as written, fully reflects this approach of linking jobs with homes. The strategy proposed is essentially the same as that in the Interim Core Strategy which was agreed in March 2010. The Interim CS would have been submitted for independent inspection but for the change of national government and with it the recent changes to the planning regime.
1.16 In response to the consultation which sat behind the Interim CS, the Council was in receipt of comments from EERA as follows:
“The Standing Committee is asked to consider that the Suffolk Coastal district Council’s focused Core Strategy review does not give rise to any conformity issues.” (Full text attached as Appendix 1)
1.17 This effectively endorsed the distribution strategy set out, in accordance with the EoEP, and which remains substantially unchanged.
1.18 Looking forward in the context of the submitted CS, the question to be asked therefore, is to what extent / degree the housing numbers in the EoEP can be said to be objectively assessed post 2021 to the end date
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for that plan. It could be argued that post 2021, the evidence on which the numbers were calculated is becoming more out of date. The roll forward in terms of the housing numbers is not matched by any similar suggestion that new job growth figures should be similarly re-assessed. This would be left to the review.
1.19 The evidence which sits behind the CS confirms that it is employment provision which is the significant factor driving the requirement for new homes and the Inspector has sought evidence on employment trends during the current economic climate – see later. The reduction in numbers proposed in the CS reflects the fact that key employment sectors within the district envisaged growth taking place but over a longer timeframe.
1.20 If it is accepted that the objectively assessed need is in fact only to 2021, then the housing trajectory included within the CS (Table 7.6 p. 147) and the data which sits behind it, confirms that at 2021 even with a reduced annual housing requirement as now proposed, it is anticipated that housing provision will be 10,870 some 670 above the minimum 10,200 required by the EoEP.
1.21 The EoEP also sets a housing requirement for the IPA part of the District, to support development at Ipswich which it identifies as a Key Centre for Development and Change. The plan is required to provide for some 3,200 new homes over the period to 2021. As at 2010, 2,223 new homes had been built within the area leaving a residual requirement of around 1,000 between 2010 and 2021. Table 7.5 page 146 of the CS estimates some 1,275 new homes being provided over the period 2010 to 2022.
1.22 The Council would therefore robustly argue that the CS for the period to 2021 is in conformity with the EoEP so it is the period beyond 2021 where there is some very minor difference and the Council’s view is that evidence justifies the marginal reduction.
1.23 To conclude, the Council is of the view that the proposal for 7,590 new dwellings more than meets the objectively assessed needs for the district to 2021. It is marginally short (2.5%) of objectively assessed needs if the EoEP housing requirement to 2027 is the figure adjudged to be the more appropriate one. If it is considered that additional housing is required to be identified in the CS to make up this shortfall, the Council would suggest that this could be addressed by means of a main modification to CS Table 3.1 in the form of a reasonable increase in estimated windfall provision. (See below for evidence)
Forecast modelling and ‘maximum capacity’
1.24 The EEFM modelling undertaken is a ‘trend based model’ based upon historic observations in data. The historic data trend throughout the late 1990’s and up to the 2007 recession was that economic growth (and housing) was rapidly increasing in Suffolk Coastal and so the model has assumed a general continuation of this pattern as a major influence. The Council’s term ‘maximum capacity’ is intended in this context ie. a high rate of growth (which appears to have somewhat slowed, or become delayed, in more recent years).
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1.25 Whilst the OE study states that Suffolk Coastal is expected to have a resilient economy to the effects of the recession, it is acknowledged that an effect will be felt. It will therefore take some time for the full extent of the recession impacts to be reflected in the local trend data and thus have a more pronounced impact on the model projections. It is common when running local forecast modelling that economic Gross Value Added figures can be quite sensitive to variance, resulting in large differences in the final output projections.
Slow down in economic growth
1.26 In relation to Felixstowe Port, a planning application had been submitted (C07/2350) to vary a number of conditions, the effect of which was a re- phasing of works over a longer time frame. Permission was granted in April 2008. The summary of reasons noted:
“The Council accepted the urgent need for the expansion of Felixstowe Port and the likelihood of the scheme being constructed in two distinct phases. The applicant would not now be able to meet its requirements in respect of railway works. The Council was satisfied that the revised timetable for the delivery of compensation and mitigation measures was acceptable. This included the earlier delivery of road improvements at both Dock Spur Roundabout and the Copdock junction and the delivery of temporary improvements to View Point Road”.
1.27 These road improvements to the A14 and A12 have recently been completed.
1.28 National Policy Statement for Ports (core document reference: B6-2) p. 12 refers to Demand Forecasts. Paragraph 3.44 makes specific reference to the impact of recession.
1.29 Felixstowe Port Logistics Study (core document reference: C2b-2) p. 6 Growth Drivers, confirms that it is growth rates for deep sea traffic which is a core market for Felixstowe. “Container growth is driven by in-bound trades, especially from the Far east serving domestic consumption.” What is happening at the national and global levels is therefore of major relevance to this employment sector.
1.30 With regard to Innovation Martlesham, the Council was involved with this project from its earliest stages in 2009. Currently the lead organisation is Haven Gateway Partnership. The innovation hub has its own website - www.innovationmartlesham.com
1.31 The purpose of the innovation hub included providing space for business incubator / start up units. These were seen as complementary to other efforts being made to broaden out the IT / high tech business cluster within the Adastral Park complex bringing in larger companies. The initial concept to house companies in a new “iconic” building was shelved and has switched instead to the refurbishment of two existing buildings.
1.32 As with Felixstowe port, business at Innovation Martlesham is still expanding, but there is currently continuing anecdotal evidence of an apparent slowdown in the number of business start-ups.
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Overall housing number and IPA split
1.33 Table 1 below sets out the housing split as requested. Two assumptions have been made with regard to these figures:
• That the EoEP IPA apportionment would remain the same, whichever option was chosen ie. 160 per annum, as there has never been any suggestion to the contrary in any discussion on the matter. There is also no other jointly agreed figure amongst the IPA authorities which could be substituted. This would have been a matter for the EoEP Review. The work on the Review had not progressed that far before it was abandoned.
• That if the EoEP annualised requirement for 510 dwellings per annum were to be rolled forward post 2021, then the overall requirement for 2001 to 2027 should be based upon the residual requirement (2010- 2027). In the case of Suffolk Coastal, this means taking account of the cumulative “over provision” [relative to the EoEP target] for the period 2001 – 2010 (+759 dwellings). The total housing completions in Suffolk Coastal district from 2001 to 2010 was 5,350 and completions in the Ipswich Policy Area were 2,223. On this basis the actual revised EoEP annual district requirement for the remaining plan period 2010 - 2027, was 465 per annum ie. 19 per annum greater than the proposed 446 figure.
Table 1 – Comparison of dwelling requirement approach in Suffolk Coastal district from 2001 - 2027
Rest of District IPA
Core Strat (446pa) 8389 4543
EoEP (510pa) 9100 4160
0 2000 4000 6000 8000 10000 12000 14000 Total Dwellings
1.34 The percentage difference between CS approach and EoEP approach is as follows:
• Rest of District: - 7.8% • Ipswich Policy Area: + 9.2% • Total housing: - 2.5%
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1.35 The actual difference in housing numbers is 328 dwellings over 17 years (i.e. 19 per annum), and will very likely be more than made up for by windfall provision. Table 2 below provides the evidence in support of this assertion. There is moreover a realistic confidence that the overall provision by the end of the plan period, based on current evidence and a reasonable assessment of windfall provision, will exceed the CS total and match, if not exceed the EoEP number (on a roll forward basis). The Council would be open to changing the annual completion target (and end figure) through this Examination process should this be the most appropriate course.
Table 2 – Windfall completions in SCDC 2005 - 2010 Monitoring Year Windfall completions Windfall completions – Ipswich Policy Area
1st April 09 – 31st March 10 227 64 1st April 08 – 31st March 09 450 114 1st April 07 – 31st March 08 292 125 1st April 06 – 31st March 07 495 114 1st April 05 – 31st March 06 395 39 TOTAL 1,859 456
1.36 The Council has indicated a low windfall provision in the CS of 540 in the final 5 years of the plan. Actual average windfall provision (completions) for the period 2005-2010 was 1,859. Even assuming a lower delivery rate of some 60-70% of this figure, windfall provision could be in the order of 223 - 260 per year.
2. Appropriate Assessment
Potential locations for green space improvements
2.01 The Council has an indicative, but realistically achievable, list of possible schemes / locations where potential improvements to green infrastructure and the green space network could be provided. This has been incorporated within the Haven Gateway Green Infrastructure Strategy (HaGGIS) (Core document reference: C4e-2). In particular, please refer to Figures 18 and 23 of that document for more detailed information on each potential enhancement project.
2.02 In addition, the Council, as a key local authority partner supporting the Greenways Countryside Project has actively promoted the protection, development and improvement of green infrastructure and green space within Ipswich and throughout the surrounding parishes. Working co- operatively with the various local authorities (Ipswich Borough Council, Babergh District Council and Suffolk County Council), Government agencies (Natural England), voluntary organisations and local communities over a period of almost 18 years, this project has established an effective mechanism for community engagement that can be readily applied to ensure the delivery of either green infrastructure or green space required in the main areas of development (core document reference: C4e-1). The appended Greenways Annual Report (Appendix 2)
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helps to illustrate the effectiveness of the project and demonstrates that there is already a significant network of green spaces and access links which could be further improved or enhanced with any new provisions.
2.03 Taking into account the above, such locations / schemes which will be candidates for green infrastructure improvements may include:
• Ipswich to Kesgrave/Martlesham Green Corridor • Long Stropps Open Space • Foxhall Road Green Corridor • Foxhall/Brock Hill Wood • Ipswich Northern Fringe Green Corridor • Rushmere Common – Access and Management Improvements • Bridge Wood, Braziers wood ANG extension • Purdis Heath and Martlesham Heath SSSI • Improvements to Public Rights of Way network at Newbourne, Brightwell, Sandlings, Martlesham Heath and Foxhall Heath
• North Felixstowe Fringe Green Corridor • Felixstowe – ANG deficiency • Trimley Marshes Extension • River Orwell to Mill River Green Corridor • A14(T) Trimley Green Bridge
2.04 If it is considered helpful to the Exploratory Meeting the Council can provide an indicative map for the above potential projects on request.
The threshold for green space provision
2.05 The development of the Core Strategy Appropriate Assessment (AA) (core document reference:D2b-5) and proposed mitigation measures has been undertaken in close co-operation with Natural England. There is currently no specific identified threshold where increases in residential development will be adjudged to cause specific and significant harm to European designated sites. However, in paragraph 7.2.8, the AA document identifies that proportional additional green space provision and enhancements should take place to precede or coincide with the strategic housing allocations in the Ipswich and Felixstowe areas. It is therefore considered essential that appropriate mitigation measures, including open space improvements, are phased alongside large developments. In the case of policy SP20, it is the Council’s intention in due course to supply a main modification to this policy stating the infrastructure / mitigation needs in accordance with the request listed under “Other Matters” of your letter dated 29th June 2012.
2.06 Through discussions with the potential developers for the area south and east of Adastral Park the Council is confident that mitigation measures, including suitable and substantial green space provision, can be delivered in proportion to the phasing of new housing. This will ensure that new residents will have every opportunity to develop appropriate recreational habits from the outset. The effectiveness of the regimes will continue to be monitored (through developing a visitor management plan) and further measures can and will be undertaken, if the monitoring reveals that it is appropriate to do so, to avoid the potential for significant adverse impacts
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on European designations. By way of example, attached at Appendix 3 is a letter from the potential developers, as part of a draft HRA submission which demonstrates that over 50ha of land in the area south and east of Adastral Park can be delivered on-site for additional green space and phased accordingly with housing delivery. Furthermore, a significant amount of enhancements, such as Public Rights of Way improvements, can be undertaken off-site as demonstrated above and in Appendix 3, so that there can be a suitably high level of confidence that new development in this area will not have an adverse impact upon European designated sites.
2.07 It is not considered that there will be a de facto embargo on additional windfall development in the Ipswich and Felixstowe areas. Individual planning applications will have to consider HRA impacts on their own specific merits, but it is not anticipated that relatively modest windfall sites across Ipswich, cumulative or otherwise, will have a negative impact upon the European designated sites which would require additional provision to that which is envisaged to meet the overall dwelling provision. In addition, CS policy SP17 – Green Space, seeks to ensure that communities have well-managed access to green space without detriment to wildlife and landscape character.
2.08 The Council also considers that given the ‘package’ of mitigation measures, there are steps which can be taken (wardening, signage etc) almost immediately which will assist in reducing the potential impact of any new housing residents and until such time as a substantial provision of wider green infrastructure comes online – these measures can be developer funded. In the future the contribution from new dwellings to these costs can be set out in the Community Infrastructure Levy which the Council intends to adopt by 2014.
The required size for green space provision
2.09 As above, the HaGGIS study has indicated a broad level of green space schemes which could be delivered in the IPA area. In addition, there remains a significant network of existing sites, footpaths and links which could be improved for accessibility as well as a further number of green space potential sites. Natural England have indicated that in their opinion, in combination with other mitigation measures, additional green space provision could be effective either through a single additional green infrastructure area, or an improved high quality network of green space.
2.10 Whilst the Council has not yet identified a particular site, or sites which may be allocated for green space, it is interpreted from the AA document that new green space provision up to 2027 will be to the equivalent of a country park. Natural England has produced a guidance document (Appendix 4) entitled “Country Parks Accreditation Handbook” (April 2009) where it is stated in the criteria that a country park must involve amongst other things, an area of at least 10 hectares in size. Ipswich Borough Council are currently engaged with the production of a Northern Fringe Area Development Brief SPD which includes the provision of a country park in those proposals and it is further expected that additional green space can be embedded early in the process there due to existing potential. The Council has been invited by Ipswich Borough Council to actively participate in the preparation of the Area Development Brief.
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3. Other matters
Infrastructure
3.01 The Council is working on this and will provide information in due course.
Superseded policies
3.02 It is the Council’s intention to provide this information as an Annex to the adopted plan. This will be a straight copy of information included in Statement of Compliance (core document reference: E-11). A main modification is suggested to this effect.
Strategic policies
3.03 It is the Council’s intention that the CS strategic policies (SP1 to SP30), the ‘model policy’ on sustainable development, and CS policy DM9 (Gypsies, travellers and travelling showpersons) will apply for the purposes of guiding the production of Neighbourhood Plans.
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Chairman: John Reynolds
Chief Executive: Brian Stewart
Planning Policy & Development Manager Please ask for: Paul Bryant Suffolk Coastal District Council Direct Dial: 01284 729448 Melton Hill Fax: 01284 729429 Email: [email protected] Woodbridge th Suffolk Date: 6 November 2009
IP12 1AU
Dear Sir / Madam
EERA response to Suffolk Coastal District Council’s Core Strategy: Proposed Changes to Housing Distribution consultation document
Thank you for inviting the Assembly to comment on the Council’s proposal to amend the broad distribution of new housing within the district.
The Regional Planning Panel Standing Committee considered a report on this matter at its meeting on 6th November 2009 before endorsing the recommendation that the proposed changes do not give rise to any specific conformity issue.
This letter and attached report constitute our formal response to this consultation.
If you have any queries concerning the content of the report or any other issue relating to conformity with the East of England Plan, please either myself or James Cutting, Team Leader: Strategy & Implementation on tel (01284) 729434 or e-mail ‘[email protected]’.
Yours sincerely,
Paul Bryant Assistant Planning Officer Strategy & Implementation
Flempton House - Flempton - Bury St Edmunds - Suffolk - IP28 6EG Tel: 01284 728151 Fax: 01284 729429 ______
The East of England Regional Assembly exists to promote the social, economic and environmental well being of the region through a partnership of elected representatives and other regional stakeholders. It is designated as the voluntary regional chamber under section 8 (1) of the Regional Development Agencies Act 1998. AGENDA ITEM: 4 Regional Planning Panel Standing Committee
6th November 2009
Subject: Suffolk Coastal District Council Core Strategy: Housing Distribution – Updated Preferred Option 7/09
Report by: Report by Regional Secretariat
Purpose
To give a response to the Suffolk Coastal District Council’s Core Strategy: Housing Distribution - Updated Preferred Option 7/09 consultation document.
Recommendation
The Standing Committee is asked to consider the recommendation that Suffolk Coastal District Council’s focused Core Strategy review does not give rise to any conformity issues.
1. Introduction
1.1 Suffolk Coastal District Council (SCDC) is consulting upon a focused review of its emerging Core Strategy’s housing distribution policy. Whilst the number of new homes being planned (7,710 by 2025) remains unchanged, the Council is seeking to alter the distribution of new housing, most notably through an increase in that proposed to the east of the A12, at Martlesham, and a reduction in the amount of housing planned for the Felixstowe and Trimley areas. Other minor changes will affect some market towns and smaller settlements.
1.2 The closing date for comments is the 18th November 2009. Further details can be found on the Council’s website at:
http://www.suffolkcoastal.gov.uk/yourdistrict/planning/review/corestrategy/housing/default.htm
1.3 A map showing the relevant part of Suffolk Coastal District Council, neighbouring Local Authorities and the Ipswich Policy Area is included at Appendix A
2. Regional / Local Policy and background to this review
2.1 Regional planning guidance is set out in the East of England Plan (May 2008) (the ‘Plan’). Policy H1 sets out minimum district housing provision targets from 2001 to 2021. Suffolk Coastal is expected to provide at least 10,200 new dwellings, a figure that includes about 3,200 homes expected to come forward as part of the Ipswich Policy Area (IPA) (see appendix A). Policy H1 also requires that local authorities plan for delivery of housing for at least 15 years from date of adoption of relevant development plan documents.
2.2 Suffolk Coastal’s Core Strategy has reached the Preferred Options stage, having undergone public consultation during the winter of 2008/091. It is also anticipated that the Core Strategy will be adopted in 2010, and it therefore plans to 2025.
1 RPP-SC 2009-01-23 - Report on SCDC’s Core Strategy Preferred Options document
RPP-SC 2009-11-06 (4) 1 Suffolk Coastal Hsng Distribution
2.4 The Core Strategy stated that the focus for housing growth will be towards the east of Ipswich and at Felixstowe, the Major Centres. In terms of distribution, the Preferred Option document allocated some 1,050 new dwellings to the Ipswich Policy Area and 2,260 to the Rest of the District (of which some 1,660 relate to the Felixstowe and Trimley Peninsula). The Core Strategy also stated (in para. 4.20) that Regional Policy is quite clear in terms of identifying a specific number of houses to be located within the IPA – a point that was corrected in the both the Assembly’s formal response and in subsequent, communication, i.e. all H1 figures should be treated as minimums.
2.5 In brief, SCDC are now proposing that:
the IPA allocation be increased by 950 units to 2,000 (allocated at Martlesham); that delivery at Felixstowe and the Trimleys be reduced by 650 units to 1,000 – and that delivery be phased with the first new homes restricted to previously developed land and, if necessary, one small-scale greenfield site, and that there be changes to the amount of housing coming forward in the market towns (up from 400 to 870) and that anticipated from small windfall sites (down from 1,320 to 540).
3. Comments
3.1 As noted, regional housing figures should be treated as minimums. Regional policy also requires that housing, and other development, should come forward in appropriate locations. Both Ipswich, as a Key Centre for Development and Change and as a focus for the ICT/telecommunications industry, and Felixstowe, as a major port, are prime examples of such locations. This review retains the priority for growth to these two areas.
3.2 The precise distribution of new housing within Suffolk Coastal is ultimately, a matter for local determination. By increasing the amount of new housing allocated to the IPA the Council states that this will bring positive local benefits in terms of terms of transport and community facilities. The Assembly is also aware that an outline planning application exists for this same area which seeks to deliver some 2,000 homes as part of a mixed-use community on land east of the A12.
4. Recommendations
4.1 The Standing Committee is asked to consider that Suffolk Coastal District Council’s focused Core Strategy review does not give rise to any conformity issues.
Contact: Paul Bryant Assistant Planning Officer Tel: 01284 729448 E-mail: [email protected]
RPP-SC 2009-11-06 (4) 2 Suffolk Coastal Hsng Distribution Appendix A
Map showing relevant parts of Suffolk Coastal District Council, neighbouring Local Authorities and the Ipswich Policy Area
RPP-SC 2009-11-06 (4) 3 Suffolk Coastal Hsng Distribution
Annual Report April 2010 to March 2011
Extract from Local Wildlife News, September - December 2011, pages 12-14,
(http://www.greenlivingcentre.org.uk/greenways/lwn1109/) Stable Block, Holywells Park, Cliff Lane, Ipswich IP3 0PG Office: 01473 433995 [email protected] www.greenlivingcentre.org.uk/greenways The Greenways Countryside Project exists to protect and enhance the countryside, landscape and open space across an area of about 100 square kilometres in and around the town of Ipswich, and home to around one quarter of the population of Suffolk, for the benefit of wildlife and local people. The project relies on volunteers to complete much of its practical conservation work. The Greenways Project is a very successful and well-established partnership between Ipswich Borough Council, Suffolk County Council, Babergh District Council, Suffolk Coastal District Council and the local community. Annual Report – April 2010 to March 2011
The map shows the sites where the Project and its Routine maintenance can include litter picking, path volunteers have carried out practical management work cutting, cleaning information boards, repairing fences, between April 2010 and March 2011. The management boardwalks, bridges, hedge trimming, coppicing etc. work is intended to maintain and improve wildlife The case studies here try to capture some examples habitats and access for local people. Most of the of the more significant improvements that have sites listed will have had routine maintenance tasks been carried out in the year. If you would like further carried out in addition to more major work and new information on any of the sites, please contact the infrastructure. Project. Greenways Project Area Map
12 Key Achievements
• The second year of grant funding from the Haven Gateway Partnership (HGP) has allowed considerable improvements to be made at Alderman Canal and in Belstead Brook Park (see case studies). © Margaret Regnault • The HGP funded River Ranger has been in post for most of the year, helping to manage the river corridor and involve more people in its management.
• Funding this year from the HGP has totalled over £173,000 – a massive amount by the Project’s standards – allowing considerable infrastructure to be put in place or improved. © Dave Davies
• 1624 days of volunteer time given by regular volunteers, local groups and others – across the sites. This represents a colossal effort (the equivalent of more than 7 full time staff!) for which we are extremely grateful to all of those who have helped.
• The first year of the Big Lottery Funded ‘Access To Nature’ partnership with CSV has seen the project grow and involve a wide range of people who have not been interested in nature conservation and the countryside previously. The project has benefited from a grant (administered by Natural England) of List of sites more than £350,000 over three years.
Belstead Brook Park Northern Fringe 1 Spring Wood (LNR) 32 Whitton Footpath Link • Funding was secured from the Big Lottery via Mind 2 Millennium Wood (LNR) 33 Grundisburgh Millennium Meadow for a partnership with CSV and Family Action to 3 Bobbits Lane Meadows (LNR) 34 Lyttleton’s Meadow, Grundisburgh provide opportunities for people accessing mental 4 Ashground Plantation (LNR) 35 Kiln Farm Meadow (CWS), Gt 5 Bobbits Lane – upper area Bealings health care to get out into the countryside and get 6 Butterfly Ride 36 Former St Mary’s Convent site, involved in our work. The ‘Ecoroutes’ project has 7 Stoke Park Wood (LNR) Woodbridge Rd. 8 Ellenbrook open space and 37 Fonnereau Way been running since June 2010 with great success – Playing Field see case study. 9 Thorington Park open spaces Western Fringe and the River 10 Belstead Meadows 38 Alderman Canal (LNR) 11 Belstead Lower Meadows (CWS) 39 River Path – Stoke Bridge 12 Thorington Hall Farm area 40 River Path – Princes St to West 13 Belstead Heath End Rd 14 Bobbits Lane Allotments 41 River Path – West End Road 42 River Path – West End Rd to Southern fringe Handford Rd 15 Netley Close open space 43 River Path – Handford Rd- © Margaret Regnault 16 Belmont Road Wood Yarmouth Rd 17 Belmont Road open space 44 River Path – Yarmouth Rd to 18 Braky Wood Riverside Road 19 Maidenhall Allotments 45 River Path – Boss Hall (Community Garden) 46 River Path – ex-Sugar Factory 47 River Path – A14 to Sproughton Eastern Fringe 48 Churchman Way 20 Purdis Heath (SSSI), Purdis Farm 21 Martlesham Heath (SSSI) Wider Area 22 Sinks Valley (SSSI), Kesgrave High 49 Priestley Wood (SSSI), Barking School. 23 Martlesham Common (CWS) 24 Mill Stream (LNR), Rushmere St Andrew 25 Sandlings, (LNR), Rushmere St Andrew 26 Warren Heath (CWS) • Future Jobs Fund – during the year, the Project has 27 Farthing Wood, Kesgrave benefited from the help of six FJF employees for six 28 Long Strops Pond, Kesgrave 29 Cedarwood Green, Kesgrave months each - entirely funded by the scheme. The 30 Legion Green, Kesgrave six individuals have worked extremely hard assisting 31 Chestnut Pond, Rushmere St Andrew with our larger than normal workload. Many thanks are due to Mike Baldwin, Colin Snell, Sean Howard, Margaret Regnault, Adrian Garlick and Matt Mudd.
13 20010/11 Annual Report continued Case Studies
Ecoroutes Alderman Canal Local Nature Reserve During the year, volunteers have been very busy at Alderman Canal LNR, utilising the grant funding from the Haven Gateway Partnership to build two new footbridges and over 200 metres of raised timber boardwalk. The new bridges allow more choice for people walking through the reserve, making the site feel safer. The boardwalks provide all-weather paths across some of the wetter areas and have worked well at ‘pulling people in’ from the recreation ground area. The main path alongside the Canal has also been resurfaced by contractors – a major task, involving the A partnership between Greenways, CSV and Family need for new fencing between the path and the Canal. Action has attracted grant support from the Lottery via The new bridges and paths were officially opened by the mental health charity Mind. Each week the scheme the Mayor of Ipswich, Councillor John Le Grys on 21st provides opportunities for people accessing mental June 2011. health care to join us on one of the sites to carry out practical conservation work. A number of volunteers have helped by supporting the scheme’s participants Belstead Brook Park – Ellenbrook area – ensuring that there are many benefits, including exercise, motivation, social interaction, sense of achievement and learning new practical skills. The scheme has been very well attended and has seen several of the participants develop substantially. CSV have produced a short film about the project – itself involving more volunteers, filming and editing.
Bobbits Lane Local Nature Reserve – wildlife
viewing tower © Margaret Regnault Following the extensive wetland improvement works of last year, the Friends of Belstead Brook Park had The former playing field alongside Ellenbrook Road long wanted a way to be able to see into the wetland has had a ‘face-lift’ – including a new path from by way of a raised platform. The metal tower was end to end (with viewpoints of the Brook, where constructed by a local contractor, with volunteers kingfishers can be seen); a new timber fence (much building the boardwalk link to it. From the tower, one more welcoming than the old chain-link fence there can look over the wet meadows, the Brook itself, and before) and new access gates. Across the road a new into the trees of Ashground Plantation. footbridge and tarmac path leads into the Ellenbrook open space with access to the play area. The bridge © Margaret Regnault and paths help to link the two sites across the road, further strengthening the connectivity of Belstead Brook Park.
How to get involved If you would like to be involved in any way with the work of the Greenways Project, or would like any further information about the Project, its aims and its work, please contact the Project on 01473 433995, or email [email protected] Some further information can be found on our web pages at: www.greenlivingcentre.org.uk/greenways
14
Mr. Philip Ridley Head of Planning Services Suffolk Coastal District Council Melton Hill Woodbridge Suffolk IP12 1AU
4 July 2012
BTP012/lr
By email and post
Dear Philip,
ADASTRAL PARK: Draft Habitat Regulations Assessment and SSSI Mitigation Strategy (Application no. C09/0555)
I write in relation to the above planning application. As you will be aware, BT submitted a Habitats Regulation Assessment (HRA) to Suffolk Coastal District Council in January 2010 as part of a Regulation 19 submission. It is intended that the final draft report enclosed will update that earlier version of the HRA.
The updated version has been produced to ensure that it is consistent with the findings of Suffolk Coastal District Council’s updated Appropriate Assessment (November 2011) and submission version of the Core Strategy and Development Management Policies (May 2012). The HRA reflects the additional information and refers to the outcome of discussions with both yourself and John Jackson of Natural England.
It is important to re-emphasise that BT remains committed to the delivery of a high quality and sustainable development on the land immediately adjacent to Adastral Park and trusts that the draft document provides certainty that the proposed development can be delivered without significant adverse impact on the integrity of the Deben Estuary SPA Ramsar Site, Deben Estuary SSSI or Ipswich Heaths SSSI.
The range of measures proposed includes:
1. alternative greenspace on-site within the redline boundary comprising the delivery of 54.13 ha of public open space phased alongside housing development;
2. off-site mitigation measures including improvements to public rights of way encouraging movements away from the SPA and;
3. additional measures directly related to the Deben Estuary to offset any residual impacts. This includes wardening, signage and control of access.
Davi d Lock Associ ates Li mi ted 50 NORTH THIRTEENTH ST REET, CEN TRAL M I LTON KEYN ES, M K9 3BP t: 01908 666 276 f: 01906 605 747 e: mai l@ davi dl ock .com www. david lock. com
VAT Reg. No. 486 0599 05. Registered in England No. 2422692. Registered Office as above.
Mitigation measures are explained in detail from page 30 of the draft report with accompanying figures, but for ease I set out a summary below.
On-Site Measures
The planning application proposals include 54.13 hectare of high quality open space provision on-site comprising public open space, existing and new woodland and perimeter planting. The majority of this will be accessible to walkers and their dogs. This provides around 4 hectares (7.5%) more than would be required by the Thames Basin Heaths standard for Sustainable Accessible Natural Greenspace. Approximately 46% of the application site falls within Natural England’s definition of Green Infrastructure.
In addition, once built, the proposed pedestrian and cycle networks within the development will include around 32 kilometres of publicly accessible space. This figure does not include footpaths within residential parcels and, if these are included, the total figure will be significantly higher.
The measures coming forward alongside the first phase of housing will include:
1. a circular walk around the entire site boundary perimeter. Additional perimeter planting can enhance that which is already in place;
2. open space suitable for off-lead dog exercise;
3. a car park on the southern boundary on the site to enable new residents to access both the perimeter walk and surrounding network of Public Rights of Way to the south and south west of the site;
4. enhancements to Barrack Square improving north south movements and connections; and
5. new leisure routes through Spratts Plantation.
The remaining on-site provision would be phased alongside housing delivery and the aggregate works, the detail of which can be agreed through condition and legal agreement.
Off-Site Mitigation
Off-site works to Public Rights of Way should also be in place alongside the earliest phase of housing development. This will encourage new residents to adopt more sustainable patterns of access and movement. The draft Heads of Terms detail includes a commitment to improvements to off-site Public Rights of Way. We have identified the following priorities for improvements to access away from the sensitive areas to the north, south and west. This could include:
1. improved connections to Newbourne and Brightwell the south; 2. improved access to the Sandlings to the north; and 3. improvements to the A12 crossing centred on stronger connections westwards to Martlesham Heath and Foxhall Heath.
This package would provide a linked network of footpaths and open spaces to enable residents to access land away from the Special Protection Area. Plans showing the likely improvements are included in the HRA.
Additional measures
In addition to the provision of on-site greenspace and improvements to local Public Rights of Way, a range of additional measures are proposed to off-set any residual impacts. These measures include funding for the employment of a warden to promote responsible access and for the compilation of a visitor management plan to minimise impacts.
The warden’s ongoing duties would include:
• enforcing restrictions on where dogs are allowed to be let off their leads; • provision of signage and publicity material promoting responsible access, places to visit etc.; • provision of additional board walks or way marked routes to direct people away from sensitive locations; • controlling access to sensitive areas of saltmarsh, either by appropriate signage or fencing; • zoning of activities and provision of enclosures to prevent access where there are important concentrations of birds; • installation and maintenance a barrier at Waldringfield Sailing Club car park to prevent unauthorised use of this area by non-members wishing to use it in order to access the estuary and; • monitoring of visitor numbers to the Deben Estuary and the impacts on wintering birds.
In addition, the Habitat Management Plan of Ipswich Heaths SSSI would be reviewed and funds provided to assist in the management of the heathland.
In conclusion, this mitigation will ensure that the development will have no significant adverse impact on the integrity of the Deben Estuary SPA Ramsar Site, Deben Estuary SSSI or Ipswich Heaths SSSI.
It is BT’s intention to formally submit the HRA to the Council in due course but welcome any comments you or John Jackson may have at this stage.
If you have any queries please do not hesitate to contact me.
Yours sincerely
LAWRENCE REVILL Managing Director email: [email protected] cc John Jackson, Natural England (by email and post) Sally Leonard, BT (by email) Ian Buxton, BT (by email) Nigel Reid, Telereal (by email)
Country Parks Accreditation Handbook Chapter 3: CRITERIA CHECKLIST
This chapter sets out the criteria for core facilities and services sites must demonstrate to be eligible to be considered as an Accredited site.
Sites must demonstrate all 15 Essential criteria and 10 Desirable criteria. These criteria form the core of the Application form for the scheme and should be considered alongside the Evidence requirements (see Chapter 4)
Ref Ref ESSENTIAL DESIRABLE No: No:
1 Area 1
At least 10 hectares (25 acres) in 1A1 size
Must have an identifiable 1A2 boundary
2 Accessibility 2
Readily accessible to the Green transport policy or plan for the 2A1 population which it is intended to 2B1 site serve
Additional facilities for less able visitors e.g. easy going trails, 2A2 Entry free of charge accessible seats and picnic benches, 2B2 relevant site information in an accessible format, play equipment
Evidence of a Site access plan in place that has been developed following an access audit and addresses the requirements of the DDA (Disability Discrimination Evidence of progress towards the Act) to ensure indoor and outdoor 2A3 next level of equality standards or 2B3 facilities provided are inclusive equivalent level of delivery and accessible
Evidence of commitment to Equality Standards or equivalent level of delivery
Page 1 of 3 24th April 2009 Country Parks Accreditation Handbook Chapter 3: CRITERIA CHECKLIST
Ref Ref ESSENTIAL DESIRABLE No: No:
3 Character 3
Must predominantly consist of Management and promotion of the natural or semi-natural landscape, 3A1 site’s biodiversity, geo-diversity and 3B1 e.g. woodland, grassland, historical environment wetland, heathland, parkland
Less than 5% total area of 3A2 buildings
4 Facilities 4
Easily followed paths, bridleways Outdoor recreation facilities e.g. 4A1 and cycle paths, e.g. waymarked 4B1 water sports, adventure sports or with a leaflet
Toilets on site or within 2 minutes Promoted self-guided health 4A2 4B2 walking distance promoting activities
Visitor centre 4B3
Play facilities 4B4
Catering provision 4B5
Cycle or horse trails 4B6
Art or sculpture 4B7
5 Links to local communities and neighbourhoods 5
Opportunities for the local community to have an influence Outreach programme to engage and 5A1 5B1 over the management and involve local people development of the site
Active promotion to less represented sectors of the community 5B2
Outreach programme to engage and involve local schools and lifelong 5B3 learning delivery
6 Links to the wider countryside 6
Page 2 of 3 24th April 2009 Country Parks Accreditation Handbook Chapter 3: CRITERIA CHECKLIST
Ref Ref ESSENTIAL DESIRABLE No: No:
Links from the site to the rights of way network, permissive access routes or other adjoining public open space or open access areas 6B1 Connectivity between site and where people live
7 Management 7
Permanent staff presence during the 7A1 Daily staff presence 7B1 daytime
Opportunities for community 7A2 Up to date management plan involvement in practical or 7B2 management tasks
Annual Action Plan / Work Plan 7B3
Achieved or working towards Green 7B4 Flag Award (GFA) status
8 Activities 8
Available for public or educational 8A1 Programme of walks or events 8B1 events
Programme of activities and events that promote healthy living and 8B2 environmental awareness
9 Information and interpretation 9
More detailed information and 9A1 Clear entrance signage interpretation about the site and other 9B1 issues
Information about where visitors Brown and white tourist directional 9A2 9B2 can go and what they can do signs
Shown on OS map 9B3
Page 3 of 3 24th April 2009