Woodbridge Housing Market Area Maps

C - 5474 - 3083 - Bawdsey - None 5474 Comment Woodbridge Housing Market Area Bawdsey

Respondent: Mr Desmond O'Grady [3083] Agent: N/A

Full Text: I would like to have Site 401, which forms part of my garden, included within the physical limits boundary of the village.

I have no immediate plans for the development of the site, and therefore do not wish to see it included specifically at this stage as a potential housing site within the next ten years. ie the life of this current Plan. But I may want to have the site included in a subsequent revision of the Local Plan. Summary: I would like to have Site 401, which forms part of my garden, included within the physical limits boundary of the village.

I have no immediate plans for the development of the site, and therefore do not wish to see it included specifically at this stage as a potential housing site within the next ten years. ie the life of this current Plan. But I may want to have the site included in a subsequent revision of the Local Plan.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5486 - 3105 - Bawdsey - None 5486 Object Woodbridge Housing Market Area Bawdsey

Respondent: Mr Robert Gold [3105] Agent: N/A

Full Text: The following are our COMMENTS re the above recent SCDC Public Consultation.

1. Draft Sustainability Appraisal Summaries/Bawdsey Site 303

17: To conserve and enhance biodiversity and geodiversity: the impact on the landscape is likely to be limited. Comment: Bats, barn owls and rare plants have been identified on and around the site, which was the tree nursery for the Quilter Estate,and a wildlife haven thereafter, and an ecological survey should be carried out.

19: To conserve and enhance the quality and local distinctiveness of landscapes and townscapes: While the site is located within the AONB and Heritage Coast, existing development can be found to the west, north and east. Comment: this does not take into account the historic and landscape value of all the adjacent buildings - to the East the VIctorian School and School House, to the West, the Quilter Estates' Forresters Lodge and Coachhouse/Stable Block and the Avenue of trees, and to the North the soon to be Listed 1960's houses designed by architect Rudy Mock.

Impact on Landscape and Protected Trees: No. Comment: Correction: the site is adjacent to Protected Woodland in an AONB.

Capacity at local schools: Both Bawdsey Primary School and Alde Valley High School have capacity. Comment: Alde Valley High School is a fifty mile round trip so should be discounted.

Please also note: the area of SITE 303 (BAWDSEY) is 0.64ha (as amended in your SHLAA November 2014), and NOT the area now for some strange showing up in the Supplementarty Guidance of over 2 ha - kindly amend this urgently - it's a mistake. Summary: 17: To conserve and enhance biodiversity and geodiversity: the impact on the landscape is likely to be limited. Comment: Bats, barn owls and rare plants have been identified on and around the site, which was the tree nursery for the Quilter Estate,and a wildlife haven thereafter, and an ecological survey should be carried out.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5487 - 3105 - Bawdsey - None 5487 Object Woodbridge Housing Market Area Bawdsey

Respondent: Mr Robert Gold [3105] Agent: N/A

Full Text: The following are our COMMENTS re the above recent SCDC Public Consultation.

1. Draft Sustainability Appraisal Summaries/Bawdsey Site 303

17: To conserve and enhance biodiversity and geodiversity: the impact on the landscape is likely to be limited. Comment: Bats, barn owls and rare plants have been identified on and around the site, which was the tree nursery for the Quilter Estate,and a wildlife haven thereafter, and an ecological survey should be carried out.

19: To conserve and enhance the quality and local distinctiveness of landscapes and townscapes: While the site is located within the AONB and Heritage Coast, existing development can be found to the west, north and east. Comment: this does not take into account the historic and landscape value of all the adjacent buildings - to the East the VIctorian School and School House, to the West, the Quilter Estates' Forresters Lodge and Coachhouse/Stable Block and the Avenue of trees, and to the North the soon to be Listed 1960's houses designed by architect Rudy Mock.

Impact on Landscape and Protected Trees: No. Comment: Correction: the site is adjacent to Protected Woodland in an AONB.

Capacity at local schools: Both Bawdsey Primary School and Alde Valley High School have capacity. Comment: Alde Valley High School is a fifty mile round trip so should be discounted.

Please also note: the area of SITE 303 (BAWDSEY) is 0.64ha (as amended in your SHLAA November 2014), and NOT the area now for some strange showing up in the Supplementarty Guidance of over 2 ha - kindly amend this urgently - it's a mistake. Summary: 19: To conserve and enhance the quality and local distinctiveness of landscapes and townscapes: While the site is located within the AONB and Heritage Coast, existing development can be found to the west, north and east. Comment: this does not take into account the historic and landscape value of all the adjacent buildings - to the East the VIctorian School and School House, to the West, the Quilter Estates' Forresters Lodge and Coachhouse/Stable Block and the Avenue of trees, and to the North the soon to be Listed 1960's houses designed by architect Rudy Mock.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5488 - 3105 - Bawdsey - None 5488 Object Woodbridge Housing Market Area Bawdsey

Respondent: Mr Robert Gold [3105] Agent: N/A

Full Text: The following are our COMMENTS re the above recent SCDC Public Consultation.

1. Draft Sustainability Appraisal Summaries/Bawdsey Site 303

17: To conserve and enhance biodiversity and geodiversity: the impact on the landscape is likely to be limited. Comment: Bats, barn owls and rare plants have been identified on and around the site, which was the tree nursery for the Quilter Estate,and a wildlife haven thereafter, and an ecological survey should be carried out.

19: To conserve and enhance the quality and local distinctiveness of landscapes and townscapes: While the site is located within the AONB and Heritage Coast, existing development can be found to the west, north and east. Comment: this does not take into account the historic and landscape value of all the adjacent buildings - to the East the VIctorian School and School House, to the West, the Quilter Estates' Forresters Lodge and Coachhouse/Stable Block and the Avenue of trees, and to the North the soon to be Listed 1960's houses designed by architect Rudy Mock.

Impact on Landscape and Protected Trees: No. Comment: Correction: the site is adjacent to Protected Woodland in an AONB.

Capacity at local schools: Both Bawdsey Primary School and Alde Valley High School have capacity. Comment: Alde Valley High School is a fifty mile round trip so should be discounted.

Please also note: the area of SITE 303 (BAWDSEY) is 0.64ha (as amended in your SHLAA November 2014), and NOT the area now for some strange showing up in the Supplementarty Guidance of over 2 ha - kindly amend this urgently - it's a mistake. Summary: Impact on Landscape and Protected Trees: No. Comment: Correction: the site is adjacent to Protected Woodland in an AONB.

Capacity at local schools: Both Bawdsey Primary School and Alde Valley High School have capacity. Comment: Alde Valley High School is a fifty mile round trip so should be discounted.

Please also note: the area of SITE 303 (BAWDSEY) is 0.64ha (as amended in your SHLAA November 2014), and NOT the area now for some strange showing up in the Supplementarty Guidance of over 2 ha - kindly amend this urgently - it's a mistake.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5548 - 3102 - Bawdsey - None 5548 Object Woodbridge Housing Market Area Bawdsey

Respondent: Mrs Caroline Gold [3102] Agent: N/A

Full Text: Thank you for inviting comments re the above.

1. I consider the SHLAA School Lane site inappropriate because new residents would need to travel some distance by car to other villages or towns to gain access to facilities needed on a regular basis such as secondary schools, shops and employment and this is contrary to government guidelines to promote sustainable transport and housing. The nearby Alderton shop continues to struggle despite the provision of a new housing estate in East Lane. There is no certainty that the residents of an additional housing estate in Bawdsey will use the shop or primary school so these arguments should not be used to justify new development as they have been proven not to work in this location.

2. The site is outside the village in an AONB and although there is development on three sides, it is important to note that these are historic buildings in a parkland setting of protected trees, facing open countryside and the sea. The housing to the North by a respected mid 20th century architect is separated from the site by a 0.25ha area of privately owned land so the site cannot be described as adjacent to the village or sitting well with it. It is difficult to understand why it was accepted in the first place given the number of sites that were discounted for the same reasons. Perhaps the fact that the site was incorrectly described as 2.34 Ha in the 2010 SHLAA instead of 0.64 influenced the decision to include it and is also responsible for the recent planning application for 20 houses, as turned out to be the case with Hopkins homes in . 3. With tourism one of the few local growth industries, it would be a great shame to detract from the tranquility and uniqueness of the area with inappropriate housing allocations, when these are the very qualities that attract visitors to Bawdsey and environs in the first place. 4. With the exception of a future enabling development, there is no formally identified local need for housing in the countryside outside Bawdsey and I don't consider the lack of 5 year housing supply to be an exception as it is the new normal both In and the rest of the country. Please correct wrong information re Bawdsey site 303 which is not 2.35 Ha but is 0.64 Ha, as per your November 2014 SHLAA which had already corrected earlier misinformation. 2.25 Ha includes three freehold houses,including ours, three plots of land, and a school and was submitted by the landowner in 2009 incorrectly. As this is the sixth time we've pointed this out to you since 2009 we hope you will now provide accurate information in your next round of documents. Summary: I consider the SHLAA School Lane site inappropriate because new residents would need to travel some distance by car to gain access to facilities needed on a regular basis such as secondary schools, shops and employment and this is contrary to government guidelines to promote sustainable transport and housing. The nearby Alderton shop continues to struggle despite the provision of a new housing estate in East Lane. There is no certainty that the residents of an additional housing estate in Bawdsey will use the shop or primary school so these arguments should not be used to justify new development.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5569 - 3150 - Bawdsey - None 5569 Comment Woodbridge Housing Market Area Bawdsey

Respondent: Mr Graham Smih [3150] Agent: N/A

Full Text: 1. Draft Sustainability Appraisal Summaries/Bawdsey Site 303

17: To conserve and enhance biodiversity and geodiversity: the impact on the landscape is likely to be limited. Comment: Area has significant use by bats, barn owls and rare plants, these have been identified on and around the site in recent years. Recommend year time line analysis of the bio-diversity activity.

19: To conserve and enhance the quality and local distinctiveness of landscapes and townscapes: While the site is located within the AONB and Heritage Coast, existing development can be found to the west, north and east. Comment: the developments in the last five years has met a significant proportion of the recommended development of the village and no more is required. Previous 'low-cost' housing failed to sell to identified social need groupings due to failure of other aspects of the infrastructure.

Impact on Landscape and Protected Trees: No. Comment: Correction: the site is adjacent to Protected Woodland in an AONB.

Capacity at local schools: Both Bawdsey Primary School and Alde Valley High School have capacity. Comment :Farlingaye High School is the designated catchment area secondary school. Farlingaye does not have capacity. New children could not access Alde Valley High School as no infrastructure and travel time would be in excess of that recommended for school travel.

Data Error: the area of SITE 303 (BAWDSEY) is 0.64ha (as amended in your SHLAA November 2014), and NOT the area now for some strange showing up in the Supplementarty Guidance of over 2 ha. Summary: 17: Wide bio-diversity in area which has not been analysed and impact of any development could significantly change the area as no substitute environs. 19: Substantial amount of Village 'quota' for development delivered in the previous five years. Low-cost housing failed to provide for target audience due to cost and infrastructure failure. Capacity at local schools: Farlingaye HS in Woodbridge is catchment school and has been 'over-subscribed' for last fifteen years. FHS operating beyond design capacity.

Data Error: site is 0.64ha not 2+ha

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5602 - 3172 - Bawdsey - None 5602 Object Woodbridge Housing Market Area Bawdsey

Respondent: Kathy & Brian Jennings [3172] Agent: N/A

Full Text: In response to your invitation for comments regarding the above, we consider the School Lane site to be totally unsuitable for the following reasons:-

1. School Lane is a quiet, single track country lane which is used by farm vehicles and the occasional car. Quite unsuitable for the extra traffic these proposed plans will bring.

2. The actual site is only 0.64 hectares in size as apposed to 2 hectares+ as shown on plans.

3. This site is in an AONB and adjacent to protected woodland.

4. The impact on the surrounding landscape would be devastating to the flora and fauna, apart from, the complete obliteration of our scenic views - i.e. the beautiful architecture of the Victorian School and across the fields to the Martello Tower and the sea beyond.

5. The village already has a new housing estate on East Lane and we consider yet another would totally destroy the character of this quiet and unique little 'spot' that visitors are drawn to because it's so 'special'.

If these plans proceed it will be to the detriment of Bawdsey and a permanent "blot on the landscape". Summary: The impact on the surrounding landscape would be devastating to the flora and fauna, apart from, the complete obliteration of our scenic views- i.e. the beautiful architecture of the Victorian School and across the fields to the Martello Tower and the sea beyond. The village already has a new housing estate on East Lane and we consider yet another would totally destroy the character of this quiet and unique little 'spot' that visitors are drawn to because it's so 'special'.

If these plans proceed it will be to the detriment of Bawdsey and a permanent "blot on the landscape".

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5855 - 3297 - Bawdsey - None 5855 Comment Woodbridge Housing Market Area Bawdsey

Respondent: Mrs J Smellie [3297] Agent: N/A

Full Text: In regards to your Site Allocations and Area Specific Policies Local Planning Document, Issues and Options Consultation, which I have read carefully. I have 2 Issues. 1 The proposed site for housing in School lane- I would like to see houses for young families at this location, especially as the School is close by. Also Bawdsey needs younger people. 2 I live at East lane, it is a very old lane, quite narrow and already has more traffic than the lane can take. Farm vehicles and trucks for the coast work go up and down. Summary: In regards to your Site Allocations and Area Specific Policies Local Planning Document, Issues and Options Consultation, which I have read carefully. I have 2 Issues. 1 The proposed site for housing in School lane- I would like to see houses for young families at this location, especially as the School is close by. Also Bawdsey needs younger people. 2 I live at East lane, it is a very old lane, quite narrow and already has more traffic than the lane can take. Farm vehicles and trucks for the coast work go up and down.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5985 - 3102 - Bawdsey - None 5985 Support Woodbridge Housing Market Area Bawdsey

Respondent: Mrs Caroline Gold [3102] Agent: N/A

Full Text: 3.34: Q.8 We think the changes suggested to the Physical Limits in Map 2 are sensible and we would support them.

Summary: 3.34: Q.8 We think the changes suggested to the Physical Limits in Map 2 are sensible and we would support them.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6182 - 483 - Bawdsey - None 6182 Comment Woodbridge Housing Market Area Bawdsey

Respondent: Anglian Water (Sue Bull) [483] Agent: N/A

Full Text: Thank you for the opportunity to comment on the Issues & Options Consultation document (December 2014).

Neighbourhood Plans Whilst Anglian Water (AW) has no comment to make on the neighbourhood area designation stage of a Neighbourhood Plan we are pleased to be consulted on the plans once they progress to draft plan stage. We are currently considering the Neighbourhood Plan and will make comment within the consultation period.

Felixstowe Area Action Plan Anglian Water are submitting representation on this consultation.

Site Allocations

Please find attached RAG spreadsheet summarising Anglian Water's comment on each site. It is important to note that this assessment does not take account of the cumulative impact of all the sites on the capacity of the Water Recycling Centres; the sites are assessed individually.

Asset Encroachment

Please note Sites 12ucl,13ucl,350,350b,408a,583a,672a,776i and 776L and WE04 are within the 400m consultation zone of the Water Recycling Centre (WRC) (formally referred to as Sewage or Wastewater Treatment Works). Initial assessment has indicated that there is an odour risk. Further discussion with Anglian Water is needed. Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage.

If a landowner or potential developer wishes to pursue an enquiry for development it is recommended they contact AW at the earliest opportunity to discuss the level of risk and the requirement for an odour risk assessment to be carried out.

Anglian Water does not want to thwart development or apply a blanket embargo on all development within 400 metres of our WRC, however we must balance this with protecting our new and existing customers from the risk of nuisance/loss of amenity whilst allowing us to provide the essential sewage treatment service to our customers and for this reason we take a risk based approach.

Similarly, development should be located a minimum of 15 metres from Pumping Stations to avoid the risk of nuisance/loss of amenity . With development proposals close to a foul pumping station,(site 693), it may be the layout of the site can be adjusted so as not to encroach on the 15 metre protection zone. The landowner/developer is advised to contact AW at the earliest opportunity to discuss.

Where there are sewers crossing the site, the site layout should be designed to take these into account; this existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The sewers should be located in highways or public open space. If it is not possible to accommodate the existing sewers within the design then diversion may be possible under section 185 of the Water Industry Act 1991 or entering into a build over/near agreement may be considered.

Details of Anglian Water encroachment policy can be viewed at: http://www.anglianwater.co.uk/developers/encroachment.aspx

Sewerage Network

The foul (or used water) flows from future growth will have an impact on the existing foul sewerage network. As outlined within the attached RAG sheet, upgrades to the network is likely to be required for a number of developments . The foul infrastructure requirements will be dependant on the location, size and phasing of the development.

We would want to see policy to ensure necessary infrastructure to serve allocations is planned and implemented before development proceeds (and dwellings occupied). To ensure this is carried through to a tactical level, we would at planning consent stage request the use of appropriate conditions to ensure infrastructure is in place before development is connected to the public sewerage network.

Surface Water and Flood Risk

Appropriate management of flood risk and the consideration of climate change is critical for long term resilience.

Whilst fluvial flooding is a significant constraint to the location of development, other forms of flooding such as surface water should be a consideration.

All developments should seek to reduce flood risk and incorporate Sustainable Drainage Systems (SuDS). We would

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6182 - 483 - Bawdsey - None 6182 Comment Woodbridge Housing Market Area Bawdsey

wish to see in policy that all developments should adhere to the surface water management hierarchy outlined in Part H of Building Regulations with disposal to a surface water sewer seen as a last resort. Under no circumstances will surface water be permitted to discharge to the public foul sewerage network and no new flow will be permitted to discharge to the combined network. We would want the document to clearly state that a surface water drainage solution will need to be identified and implemented prior to the construction of hard standing areas. The solution would need to be agreed with all stakeholders.

Engagement with developers

Anglian Water offers a pre planning service which includes a capacity check to determine the impact of sewerage from a proposed development. We will also work with the developer or land owner during this process to develop foul and surface water (where applicable) drainage solutions which will not cause a detriment to our existing or future customer. We would encourage the prospective developer to contact us at the earliest convenience to discuss drainage proposals to serve the development. Details regarding this service can be found at http://www.anglianwater.co.uk/developers/pre- planning-service-.aspx

Anglian Water are keep to engage with District Council on Local Plan consultations and on individual planning applications. Summary: 303: Will require process enhancement to treat FW. Significant off-site sewergae required to connect into ALDNSC. Septicity control will be required.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: 5002_Suffolk_Coastal_allocation_-_sites_consultation_sheet_(RSP)_-_Jan-15(1).pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6331 - 3389 - Bawdsey - None 6331 Support Woodbridge Housing Market Area Bawdsey

Respondent: PJ & SA Mann [3389] Agent: N/A

Full Text: I am writing to you as a local employer and landowner, lifelong resident of Bawdsey and owner of the proposed development site at School Lane, Bawdsey.

Having been involved in the village consultation over the last six month, I have come to realise that the opinions of a limited number of Bawdsey residents are not, in my view, shared by most of the community. Most comments and opinions have been positive and encouraging a much needed younger generation to the area.

My wife and I do not want to see another development of a few expensive houses, bought as second homes. This has no benefit to the village and community. The School Lane development being a mix of affordable starter and family homes will hopefully enable young families to purchase property in the area, something that has not been possible for many years.

I hope that these and other Bawdsey residents more positive comments will be given some consideration once the application is made. Summary: My wife and I do not want to see another development of a few expensive houses, bought as second homes. This has no benefit to the village and community. The School Lane development being a mix of affordable starter and family homes will hopefully enable young families to purchase property in the area, something that has not been possible for many years.

I hope that these and other Bawdsey residents more positive comments will be given some consideration once the application is made.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6346 - 3396 - Bawdsey - None 6346 Support Woodbridge Housing Market Area Bawdsey

Respondent: James & Rebecca Barrington-Phillips [3396] Agent: N/A

Full Text: We are writing to you regarding the proposed residential development at School Lane, Bawdsey which we fully support.

We have been full time residents of Bawdsey for 20 years, having bought our first family home in Bawdsey when property there was still affordable to first time buyers. We have 3 children who have all been to Bawdsey School and we actively support many of the local groups and clubs. We would like other young families to have the opportunity to live in Bawdsey.

We would like to see a younger, vibrant community in the village and feel that by building a mixture of affordable housing/starter homes, this could happen. In the current situation any young, local people wishing to live in Bawdsey are unable to do so due to the high cost of housing, with a development of affordable housing this would give them the opportunity to live in the village.

We also feel that the development would help to sustain and improve the local economy and the future of Bawdsey School.

We are pleased to see that if the development goes ahead a car parking area will be created for parents dropping off at the school.

We appreciate and agree that many residents feel that Bawdsey is a special place and that the new buildings would spoil this but having seen the proposed plans we feel that the architects have understood this and the new houses would not look out of place within the existing mature trees and hedgerow.

We hope that our views are given some consideration. Summary: We would like to see a younger, vibrant community in the village and feel that by building a mixture of affordable housing/starter homes, this could happen. In the current situation any young, local people wishing to live in Bawdsey are unable to do so due to the high cost of housing, with a development of affordable housing this would give them the opportunity to live in the village.

We also feel that the development would help to sustain and improve the local economy and the future of Bawdsey School.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6354 - 3402 - Bawdsey - None 6354 Support Woodbridge Housing Market Area Bawdsey

Respondent: Chris Mann [3402] Agent: N/A

Full Text: Proposed Building Development. School Lane. Bawdsey

I am writing to you to register my support of the above building development project. I am a Bawdsey resident and landowner, I have a young family and I also run my agricultural and haulage business from the village.

I am pleased to see that the proposed new dwellings will be a mixture of starter homes, affordable housing and family homes, giving younger families an opportunity to live in the village, this has been impossible for many years. As an employer, at the present time any potential employees I may have are unable to live in the area due to the prohibitively high cost of housing.

It is my view that the introduction of lower cost housing to Bawdsey would be of great benefit to the village, bringing much needed younger residents to help sustain the school, community and local businesses. Summary: 303:I am pleased to see that the proposal will be a mixture of starter homes, affordable housing and family homes, giving younger families an opportunity to live in the village, this has been impossible for many years. As an employer, at the present time any potential employees I may have are unable to live in the area due to the prohibitively high cost of housing.

It is my view that the introduction of lower cost housing to Bawdsey would be of great benefit to the village, bringing much needed younger residents to help sustain the school, community and local businesses.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6474 - 3449 - Bawdsey - None 6474 Object Woodbridge Housing Market Area Bawdsey

Respondent: Elizabeth Mark [3449] Agent: N/A

Full Text: Dear Sir or Madam,

I enclose my response to the huge 3 part future planning ideas which you set out.

A lot of errors were found including the wrong school for over 11's- it is Farlingaye that is our school. Also we have no public transport- bus company left up the bus stop sign and their notices.

I have highlighted on Q30 and 31 the great problems we have here with getting access for transport, to health centre, hospitals, trains ect. This must be a factor in the housing needs and also a village I am sorry to say is "dying" due to few children; most population is over 60 and over 60 holiday houses. When some of us retire from activities in the village there will be no-one to take over as those who do come here come from towns and don't mix in many, many activities, and a whole lot of the area has closed up/blackened windows as they are not in use as permanent residences from September through to April/May.

In some places in Cornwall and Wales the councils have stopped people buying 2nd homes-when will Suffolk Coastal do the same.

I married 42 years ago and come to live here then and every house was occupied and 19 worked on farms and others at REF Bawdsey. My husband was born here and his family have lived in around Bawdsey since 1744 (tree research).

Hope you will read this and not put it on the burning pile and ignore residents views. This is my personal views not parish council (which I am on at moment).

Your faithfully Elizabeth Mark

SMALL DOCUMENT WITH BLUE COVER Q1. We at Bawdsey are not a Local Service Centre- only got a school, no shop, no pub, no proper public transport. Latter everyone has to rely on neighbours to go to Doctors and shop (Alderton)

Q2. We have enough housing (big ones) no terrace type for affordable housing for youngsters to stay on village after leaving school. The last new housing out of 12-3 are used as holiday homes- we have over 60 of these- its rained the village and made it too expensive for young people to buy. Q3. Don't want any. Q4. No comment Q5. As Answers on Q1, Q2 Q6. As the limit is now Q7. No Q8. No Q9. No Q10. Should be protected Q11. None Q12. Not our area Q13. -ditto- Q14. -ditto- Q15. -ditto- Q16. -ditto- Q17. -ditto- Q18. Need to consider impact on local communities especially villages on the Deben- a lot of traffic heading to Bawdset Quay in summer- in fact can be very dangerous on a narrow roads with "huge" farm machinery. So tourism needs monitoring. Q19. Not our area Q20. -ditto- Q21. -ditto- Q22. -ditto- Q23. -ditto- Q24. -ditto- Q25. The new policy needs to be considered extremely carefully. It could be very "explosive". Q26. Some of the old quilter buildings in the village. Q27. Does need more consideration. Q28.This is the question that affects Bawdsey village if the Anglia 1 windfarm gats go ahead- ruin our area for wildlife, peoples peace, views ect Q29. yes if windfarm gets go ahead. Q30. Q31. Yes, there should have been more on communications-particularly Broad-band, mobile phones- reception awful, one part of village near hall mobile phone can't be used at all.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6474 - 3449 - Bawdsey - None 6474 Object Woodbridge Housing Market Area Bawdsey

Transport and Health- problem with people getting to Alderton surgery a) no transport at all- we general public help people out to get up and down (Alderton). b) some people having to use framfield at Woodbridge- they will not allow people to make next appointment when there- insist on sending letter- which can take 4/5 days to reach here. There are problems getting transport to there (in fact I had to forego a lunch to get a lady up to Framfield from here-otherwise her feet (diabetic) would not be seen to for 4 to 6 weeks) awful c) Hospital letters can take ages. Someone had a phone call (automated) if they were attending appointment previously made- no letter turned up and had to go without one and explain. d) with these specific centres all over UK- people find difficult to get transport and have to take long journeys such as Cambridge, London ect. Too ill to go on their own and needed company to go to London- appointment in peak time cost (£175 per person return) Left Woodbridge at 1pm when getting to the hospital around midday having had to go on tube when handicapped to find out that appointment had been cancelled- rang 8am. On the train then. What a situation - to put people through all this. So health needs going in along with transport. The local minibus cannot take youngsters to college, work or anywhere. Also don't run on Sundays & Bank Holidays when some have to work. As a bad back sufferer I used the transport once and never again- springs are dreadful- ended up having physio. So if some of us have to give up driving can't rely on this service at all. Youngsters not having transport- means they leave the village- its sad!!

One young man has no car at the moment- who never knows when he has to work or come home is paying £15 from here to Woodbridge + another £15 to come back by taxi (£30 per day). He wants to stay here!!

Lastly, no more holiday homes please. Summary: We have enough housing (big ones) no terrace type for affordable housing for youngsters to stay on village after leaving school. The last new housing out of 12-3 are used as holiday homes- we have over 60 of these- its rained the village and made it too expensive for young people to buy.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: AH Bawdsey.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6507 - 3336 - Bawdsey - None 6507 Object Woodbridge Housing Market Area Bawdsey

Respondent: Bawdsey Parish Council (Mrs Jenny Webb) [3336] Agent: N/A

Full Text: CONSULTATION ON SITE ALLOCATIONS AND AREA SPECIFIC POLICIES

Bawdsey Parish Council met on 4th February 2015 to discuss these policies. Twelve members of the public were present and all were against further housing development in Bawdsey. Given that SCDC are no longer requesting (through the SHLAA and the Consultation Document) that Bawdsey has significant new housing development, the Parish Council wish to make the following general points. These are then followed by the answers to the specific questions. * Given that no significant new housing is needed in Bawdsey, the Parish Council no longer sees any requirement to increase the "Physical Limits Boundary" (Village Envelope). Therefore, Site 303 and indeed all the area in the triangle between The Street, East Lane and School Lane, outside the existing Boundary, should be excluded from the revised Physical Limits Boundary. * To show the exceptional nature of the Cavell Close Development, it too should remain outside the Physical Limits Boundary. Therefore the Physical Limits Boundary should revert to being the solid Blue Line on the attached plan. * The Parish Council would like to see a few new houses being built in the period of the Review but believes these could be accommodated within the existing Physical Limits Boundary. In particular, within the site of the old Garage (marked in brown on the attached plan). * SCDC should again consider ways to prevent any new housing being bought as second homes. The view of the meeting was that no more second homes are needed in Bawdsey. * SCDC, when considering issues such as employment, secondary schooling, shopping and access to health care in relation to Bawdsey, should bear in mind the importance of the lack of any transport links other than private car. * Parishioners would welcome any proposals to improve flooding and erosion risks.

Bawdsey Parish Council's response to questions in Consultation Documents:

1. Adopted approach is acceptable 2. Target housing allocation of 0 is acceptable. In practice, BPC would like to see 2 - 3 new dwellings in this time period. 3. The Old Garage, an existing brownfield site within the envelope would meet the requirement. (Marked in brown on attached plan) 4. No other sites are required. 5. Starter homes are most required but there needs to be a mechanism to prevent these selling as second homes. 6. The proposed Sites 401 and 303 are not required, as there is a zero housing requirement. Therefore, these sites should remain outside the Physical Limits Boundary and not have any housing designation. That is, they should remain as Open Countryside. 7. In its letter of 15-Oct-2014, BPC proposed increasing the Physical Limits Boundary to meet the need for more housing. Since the requirement for more housing has now disappeared, BPC no longer sees the need to increase the Boundary. Therefore, BPC now proposes that the Physical Limits Boundary reverts to that shown in solid Blue on the attached plan. 8. Of the 3 maps on the website. Map 3 is not required as the new sites are not needed. Map 2 is closest to what the BPC would like to see. We would prefer site 7368 (Cavell Close) to remain outside the envelope as a reminder of its exceptional status. Otherwise Map 2 is our preferred Physical Limits Boundary. The attached plan shows our actual preference. 9. The attached plan shows our preferred Physical Limits Boundary. It is your Bawdsey Map 2 but without Site 7368 (Cavell Close) included. 10. Not applicable. 11. The area adjacent to Site 303, alongside The Street must be protected. With the proposed changes above, it would remain as Open Countryside, which should be sufficient protection. 12. Questions 12 to 15 - No comments 16. Yes 17. Underused site, at rear of Old Garage (Marked in brown on the attached Plan) 18. No tourism sites within the Village Physical Limits Boundary. 19. Questions 19 to 24 N/A 25. SCDC to consider favourably proposals to be made in future by Bawdsey Coastal Partnership 26. Yes, all buildings within the Village Limits built by the Quilter Estate in 19th/20th Century should have some protection. 27. N/A to Bawdsey 28. NO 29. N/A to Bawdsey 30. Questions 30 and 31 - The lack of transport infrastructure. Summary: Given that no significant new housing is needed in Bawdsey, the Parish Council no longer sees any requirement to increase the "Physical Limits Boundary" (Village Envelope). Therefore, Site 303 and indeed all the area in the triangle between, The Street, East Lane and School Lane, outside the existing Boundary, should be excluded from the revised Physical Limits Boundary. The Parish Council would like to see a few new houses being built in the period of the Review but believes these could be accommodated within the existing Physical Limits Boundary. In particular, within the site of the old Garage.

Change to Plan

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6507 - 3336 - Bawdsey - None 6507 Object Woodbridge Housing Market Area Bawdsey

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: Bawdsey_PC_Response_Feb_15.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5856 - 3238 - - None 5856 Comment Woodbridge Housing Market Area Blaxhall

Respondent: Dr Eve Rossor [3238] Agent: N/A

Full Text: Thankyou for producing such a carefully thought through plan.

We comment only on Blaxhall in this response.

Blaxhall is now mis-labelled as an LSC as it no longer has a bus service, and only the pub as a significant focus in the small dispersed settlement that it is.

We agree that there is no justification in building significant numbers of houses in Blaxhall, noting that occasional infilling is happening. In particular, the allotment area in the centre of the village must be preserved to maintain the nature of the village.

The boundary includes the pub car park. The pub (The Ship) attracts visitors from afar, and needs to have a guaranteed car park. We would suggest either that this is put outside the envelope, or a specific instruction made for no building on it, which would enhance the viability of the village's main resource. Summary: Blaxhall is now mis-labelled as an LSC as it no longer has a bus service, and only the pub as a significant focus in the small dispersed settlement that it is.

We agree that there is no justification in building significant numbers of houses in Blaxhall, noting that occasional infilling is happening. In particular, the allotment area in the centre of the village must be preserved to maintain the nature of the village.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6318 - 3055 - Blaxhall - None 6318 Support Woodbridge Housing Market Area Blaxhall

Respondent: Evolution Town Planning (Mr Steven Bainbridge) Agent: N/A [3055]

Full Text: Suffolk Coastal District Council Issues and Options Consultation on Site Allocations and Area Specific Policies Local Plan Document Representations in Respect of Blaxhall and Sites off Station Road and off Mill Common Road

Reference: E280.C1.Rep02

1.0 Executive Summary

1.1 New housing development in Blaxhall, developed over the timeframe of the new Local Plan would deliver a range of new housing to meet local needs, support local infrastructure and provide site specific benefits. For example the average age of the local population is increasing, including bungalows in a new development would allow older people move to more appropriate homes and to remain living locally. Low levels of housing building make it difficult for local young people to buy homes, so new small homes or affordable homes can address this need. 1.2 Development of our one of both of our client's sites would provide for a proportionate number of new homes in Blaxhall giving additional choice of housing for those who wish to live there. 1.3 Blaxhall has around 126 homes. In the plan period to 2027 and to 2031 (as a result of the Core Strategy review later this year ), an increase of around 10% in the number of homes would normally be sustainable. The Parish Council is concerned about the impact of new housing and opposes a housing allocation. We suggest that any allocation should be between 3 and 12 homes, with homes designed to meet local housing needs and to be in character with the village. We propose two possible housing sites , and one or both could be developed with 3 to 12 homes in total with housing on the sites phased over the Local Plan period if required. 1.4 The development of these sites could provide local benefits other than homes. For example the site in Station Road could provide a pedestrian link between the village and the village hall and the playing fields which are detached from the main built up area.

2.0 Introduction 2.1 These representations describe two suitable housing sites adjacent to the settlement boundary and built up area of Blaxhall. The identification of these sites results from a village-wide walk over and assessment of the development potential of land around Blaxhall, and feedback received at a Parish Council meeting in January 2015. 2.2 Evolution Town Planning (ETP) are experienced in promoting small rural sites either through development plan representations or planning applications. We also have site assessment from working in Council planning departments. As a practice we have 30 years of combined professional experience in this type of work. 2.3 ETP have inspected various potential sites and the surrounding area. We have reviewed national planning policy and the District Councils Core Strategy and its requirements for local service centres . We have considered the Parish Plan for Blaxhall in terms of the needs and aspirations of the Parish Council. 2.4 The inset plan below and the plan in Appendix 1 identifies the two proposed sites and sets them in the context of the village of Blaxhall and its surroundings. (See attached document). 2.5 The sites edged in red are our suggested housing allocation sites, the land coloured blue outside these areas is in our client's ownership and could be used to support development for example to provide landscaping, drainage or other infrastructure. The dashed line shows the existing settlement boundary (physical limits boundary) for Blaxhall. The land highlighted green is registered common land which is shown here because of its importance to the village. The sites in brown are earlier potential allocation sites which have since been discounted by the District Council as unsuitable for allocation. The two sites could both be developed or one may be preferred over the other. 2.6 The whole of the land edged red at Site A may not be required to provide housing for Blaxhall, however it is available to provide other development related benefits if required such as a pedestrian link to the village hall and playing fields. 2.7 The plan shows that our client has a significant land holding adjacent to Blaxhall and abutting the settlement boundary. Rather than putting all the land forward for housing allocations we have focused on proposed areas which we consider to be the most appropriate for housing. The blue land could provide other forms of development such as drainage infrastructure or landscaping as part of any housing proposal. 2.8 Due to the potential afforded by the size of our client's land holding, development on these sites can be flexible in terms of the design to respond to local requirements of density, character, house type and affordability. For example, providing housing to meet local needs including bungalows, family homes, and affordable homes as required or providing for local facilities and improvements. 2.9 We consider that the maximum number of new homes that would appropriate in the plan period on new housing allocations would be 12. A number lower than that may be preferred. We consider that in total that sites A and B should provide between 3 and 12 new homes of a types and design that meets local needs and respects local character. 2.10 This report continues by assessing Blaxhall in the development hierarchy and the Development Plan it then goes on to assess the sites that have already been put forward in the village. It considers the proposed allocations against Core Strategy requirements then considers the individual characteristics and merits of the sites. 2.11 The requisite site submission proforma is in Appendix 2. (See attached document).

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6318 - 3055 - Blaxhall - None 6318 Support Woodbridge Housing Market Area Blaxhall

3.0 Description of the Sites and Surroundings

Blaxhall 3.1 The majority of the housing is focused around School Road. Further dwellings are located on Rectory Road, Church Road and Station Road to the west of the main settlement. 3.2 The allotments, common land and deep roadside verges surrounding them provide for an undeveloped element to the northern part of the village and are key to its character. 3.3 Blaxhall is recorded in the 2011 Census as having a population of 192 people and 126 dwellings across the Parish with a population skewed towards older age groups and a high proportion of home ownership. 3.4 The District Councils Issues and Options document only records one recent completion of a new home and there are no extant housing permissions in Blaxhall. 3.5 The village of Blaxhall is characterised by a wide mix of development. There are traditional detached and terraced cottages, along with modern homes and bungalows. Homes are either set back from the road behind generous frontages and verges (mainly to the north), or are set close to the roads (mainly to the south). The existing housing is relatively closely developed providing few opportunities for infill development. 3.6 There is generous green space in the built up area of the village with allotments and grassed areas. These areas are important to the villages character. New allocations should preserve the character of the village, and so the green spaces within the built up area should not be developed. 3.7 Blaxhall is described in the parish plan as: "Blaxhall's population of some 230 people has lost its shops and post office but retained a public house, a C of E Church, a small village hall and a recently modernised and expanded Youth Hostel. Blaxhall also has an international Language School, an international motorcycle scramble circuit and is within 1 mile of the internationally renowned Snape Maltings concert hall. The 123 homes in Blaxhall are widely dispersed around two main residential groupings, Mill Common and Stone Common, situated about 1 miles apart. " 3.8 The Blaxhall Parish Plan signposts its needs by highlighting issues which the community considered were 'poor and required action'. These are:

3.9 Other issues referred to as requiring improvement include road safety, litter and public transport. 3.10 Recent Parish Council discussions have considered the desirability of protecting for the village the brown land labelled 995 and 643 on the above plan. This land has previously been put forward for housing development and has been rejected by the District and Parish Councils. The land is however well related to the built up area of the village.

Site A 3.11 Site A is 0.5ha in size and is shown on map E280 SA1 located to the west of Blaxhall and adjoins land recently the subject of planning application DC/14/3247/OUT for a detached dwelling. 3.12 The site is accessed off Station Road and encompasses land between the edge of Blaxhall and the village hall and playing field. 3.13 There is sufficient road frontage to provide for a safe and suitable access (NPPF para 32) which would meet relevant standards (DfT Manual for Streets: Safe Stopping Distances Table 7.1 (p91)). 3.14 Site A is currently Grade 4 agricultural land and is unconstrained because there are no planning or environmental constraints affecting it for example historic designations or wildlife sites. 3.15 To the west of Site A is the village hall and playing fields and agricultural land. To the north and south is also agricultural land and to the east is the built up area of the village.

Site B 3.16 Site B again is 0.5ha in size and is shown on map E280 SA1 located to the east of Blaxhall, and abutting the settlement boundary. 3.17 Site B is currently Grade 4 agricultural land and is unconstrained because there are no planning or environmental constraints affecting it . 3.18 To the west and north of Site B is residential development and to the east and south if agricultural land. 3.19 The site is accessed off Mill Common Road. There is sufficient road frontage to provide for a safe and suitable access 3 which would meet relevant standards (DfT Manual for Streets: Safe Stopping Distances Table 7.1 (p91)).

4.0 Planning Policy 4.1 Blaxhall is categorised in the Suffolk Coastal Core Strategy as a 'Local Service Centre'. This means it has a range of local facilitie s and will be expected to accommodate new housing development that is consistent with the scale and character of Blaxhall. 4.2 The Suffolk Coastal Core Strategy which pre-dates the national planning guidance in the Planning Practice Guidance (PPG) sets out the distribution of new development that will be planned for across the whole District. It states

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6318 - 3055 - Blaxhall - None 6318 Support Woodbridge Housing Market Area Blaxhall

that the Key and Local Services Centres will be expected to accommodate 17% of the total of new dwellings. Blaxhall is expected to play its role in delivering sustainable development and rural housing growth. 4.3 The purpose of making provision for small scale development in villages like Blaxhall is to ensure that local services can be sustained economically and that people wishing to live in the area have the opportunity to do so5. These are both key issues raised in the Blaxhall Parish Plan from 2004. 4.4 The nature of the village means there are few opportunities for windfall development. Reliance on infill development in the local service centres may be misplaced. In all the time Suffolk Coastal District Council (SCDC) has been without a 5 year housing supply the Issues and Options document only recently records 1 completion and no extant permissions in Blaxhall. 4.5 Therefore if the village is left with no al location there may be few if any opportunities during the plan period for sustainable rural housing growth leaving Blaxhall to stagnate and the issues raised by the community to go unaddressed. 4.6 The NPPF recognises the need to support rural communities with sustainable levels of housing growth which in turn promote the retention and development of community facilities. 4.7 The Site Allocations Issues and Options document sets out an approach based on the Core Strategy which is now at odds with the PPG because the District Council is not planning for the sustainable expansion of Blaxhall through the current plan period to 2027, let alone the extended period to 2031 arising from the Core Strategy review later in 2015. The PPG states: "all settlements can play a role in delivering sustainable development in rural areas and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided unless their use can be supported by robust evidence." 4.8 New housing development in Blaxhall will provide for a sustainable increase in population which should help the local community deal with the issues they have identified. 4.9 There will need to be flexibility in the Site Allocations to cover the Core Strategy review which will extend the plan period to 2031. 4.10 This submission proposes sites for consideration for housing development that is in scale and kind with Blaxhall as part of that District -wide approach. 4.11 The Core Strategy envisages proportionate development at Blaxhall and to be sustainable it will need to relate well to the existing settlement boundary so the focus will therefore be on the unconstrained and deliverable sites which have that relationship. We consider that a sustainable allocation would be between 3 and 12 homes. 4.12 The sites identified by the District Council as 643, 995 and 685 have already been submitted to the Council by third parties and have been discounted by the District Council as unsuitable for housing development.

5 Suffolk Coastal Core Strategy

5.0 The Sites Constraints and Opportunities 5.1 The inset plan above (and in Appendix 1 - see attached document) indicates the two separate parcels of land that are the subject of this submission. 5.2 Sites A and B are considered suitable for accommodating development at a low density to reflect local character. 5.3 These sites are not mutually exclusive. The District Council may wish to proceed with both or one of them in combination in order to achieve an appropriately sized allocation for Blaxhall. We consider that up to 12 homes could be provided in total in the village using one or both the sites. 5.4 The wider land holding around site A could provide for landscaping and/or open space requirements as necessary.

Site A 5.5 Site A is located to the south of Station Road. It is 0.5ha in size which means it could provide a maximum of around 12 dwellings but a lower number at a lower density could be more appropriate for Blaxhall. 5.6 Site A offers the opportunity to link the main settlement to the village hall and playing fields and children's play area. At a recent Parish Council meeting it was noted all attendees drove the approximate 300m from Blaxhall to the village hall and none walked. 5.7 The position of Site A introduces the opportunity to improve pedestrian links between the village and the village hall and playing field with a new footpath in conjunction with development of the eastern portion of Site A closest to the village. The potential for the provision of a pedestrian footway would improve safety for residents moving between the main settlement and the village hall and playing field. 5.8 Development of a part of this site could be similar in design and layout to that fronting School Road and Rectory Road nearby i.e. detached and terraced cottages set back from the road. 5.9 Local examples include (see attached document). 5.10 The site has no ecology constraints being arable field and is unlikely to feature species or habitats of interest. However sensitive landscaping could provide for a net increase in biodiversity interest with the provision of new trees and hedgerows. 5.11 There are no landscape designations constraining the site. In visual terms development of this parcel of land could provide a functional linkage between the village and the village hall and playing field.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6318 - 3055 - Blaxhall - None 6318 Support Woodbridge Housing Market Area Blaxhall

5.12 The extent of land ownership in this location would provide for ample landscaping to the south of the proposed site. 5.13 In summary Site A is available and is unconstrained and could provide for the future rural housing needs of Blaxhall including 1 and 2 bed homes and/or bungalows, built to reflect local character.

Site B 5.14 Site B is located south of Mill Common Road. It is 0.5ha in size so could accommodate a maximum of around 12 dwellings but again a lower number at a lower density could be more appropriate for that part of the village. 5.15 Development in this location would relate well to the existing settlement boundary. With good design it would provide for an attractive new entrance into the village with interesting traditionally des igned dwellings fronting the road and traditional village features. Well landscaped verges could mirror the existing wide verges on the common land opposite. 5.16 The site has no ecology constraints being arable field. The site is within the Special Landscape Area designation. To mitigate any adverse impact the site is large enough to provide a well landscaped edge on its east and south sides. 5.17 As part of any development the provision of village gateway signs should be considered. This is because while the 30mph zone begins some 220m east of the edge of the settlement boundary there is little to inform drivers of this until reaching the village itself. This is an issue highlighted as important in the Parish Plan. 5.18 Development in this location could be similar in design and layout to nearby development being a mixture of detached houses and bungalows with substantial front gardens and properties set back from the main road and accessed off a close or lane. 5.19 Local examples include (see attached document). 5.20 The extent of land ownership on this site also provides sufficient land for landscaping that reflects the nearby common land and heath habitats. 5.21 In summary Site B is available and is unconstrained and could provide for the future housing needs of Blaxhall either on its own or in combination with Site A. 5.22 The two sites have been assessed in terms of their suitability (performance against the District Council's criteria) for housing development and are considered to be suitable, available and deliverable. 5.23 The table below sets out the opportunities and constraints for the two sites. It uses criteria from the Council's 'call for sites' proforma and SHLAA assessment sheets.

SCDC criterion Site A Site B Area 0.56ha 0.54ha Status Greenfield Greenfield % of site for housing Up to 100 Up to 100 Density Low Low Indicative capacity Max. 12 Max. 12 Likely delivery timescale 0-5 years 0-5 years Access or highways No (within the 30mph No (within the 30mph issues zone) zone) AQMA No No Area of archaeological No No importance Agricultural land grade Grade 4 Grade 4 Conservation area No No Contaminated No No Existing use Agricultural Agricultural Flood zone 1 1 Listed buildings No No Open space No No TPO No No Wildlife site or adjacent No No to Other constraints No SLA Suitable Yes Yes Available Yes Yes Achievable Yes Yes Summary Deliverable and Deliverable and developable. developable.

5.24 Both sites A and B have development potential for housing. One or both could be developed. We consider that the maximum number of homes appropriate for the village in the plan period is a 10% increase or 12 homes. The number proposed could be less and spread over both sites. 5.25 Housing should be developed at a density to accord with the existing character, and in a range of types, such as family homes, bungalows, or starter homes to meet local needs. The District Councils requirement to provide a third of homes as affordable would address requirements for low cost housing.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6318 - 3055 - Blaxhall - None 6318 Support Woodbridge Housing Market Area Blaxhall

6.0 Answers to Suffolk Coastal District Council Consultation Questions

6.1 The following section provides answers to relevant questions in the Issues and Options consultation document. Q1. Do you have any thoughts on the approach the Council has followed? Is there an alternative approach that you think should be considered for the more detailed distribution of housing in the Market Towns and Key and Local Service Centres set out in the Core Strategy and why? 6.2 Page 14 of the Issues and Options consultation document states that 'Approach 1' was "rejected when the broad scale and distribution of housing was adopted through the Core Strategy". It also states that 'Approach 2' is "the one which has been used" in the Core Strategy and the Issues and Options documents "reflects this approach". 6.3 The Core Strategy was adopted in July 2013 and post -dated the National Planning Policy Framework (the Framework). However subsequent National Planning Practice Guidance (the PPG) has been issued which 'Approach 2' does not conform to. 6.4 Specifically the PPG states: "It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability, and the role of housing in supporting the broader sustainability of villages and smaller settlements. This is clearly set out in the National Planning Policy Framework, in the core planning principles, the section on supporting a prosperous rural economy and the section on housing. A thriving rural community in a living, working countryside depends, in part, on retaining local services and community facilities such as schools, local shops, cultural venues, public houses and places of worship. Rural housing is essential to ensure viable use of these local facilities. Assessing housing need and allocating sites should be considered at a strategic level and through the Local Plan and/or neighbourhood plan process. However all settlements can play a role in delivering sustainable development in rural areas and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided unless their use can be supported by robust evidence." 6.5 The Councils 'Approach 2' leads to many Key and Local Service Centre villages having a residual housing requirement of zero. This is the case in Blaxhall. 6.6 For villages to sustain themselves for the lifetime of the plan period to 2027 and to 2031 after the Core Strategy review it is important for some land to be allocated in the plan. 6.7 Allocation of land for development on Sites A and B would allow for future development to come forward during the plan period, as the PPG expects, to ensure the village grows in a planned way and to ensure the future viability of village facilities to 2027 and 2031. Q2. Does the suggested amount of new housing to be provided in your village/town sound about right? If not, why not and what is an appropriate amount? 6.8 As set out above in order to be in conformity with the PPG it would be necessary for Blaxhall to be allocated an amount of housing to allow for planned housing development within the plan period to 2027 and to 2031 after the Core Strategy review rather than be left with a blanket zero due in part to recent and as yet undecided planning application. 6.9 The Issues and Options document at its paragraph 3.5 states: "It is essential that the Council provides over and above the minimum amount of land needed to meet the target as this will provide flexibility and choice for future residents, developers and other stakeholders. Having a variety of sites also promotes a flexible approach which will help to overcome any site specific issues that may arise over the plan period. Over allocating land for development also enables the Council to clearly demonstrate that sufficient land is available and can come forward throughout the entirety of the plan period." 6.10 It is not clear which plan period is referred to; 2027 or 2031 (as a result of the Core Strategy review later this year). A residual allocation of zero for Blaxhall will not 'provide flexibility and choice for future resident s' of that village. 6.11 In the absence of robust evidence Blaxhall should be provided with a residual allocation that allows for future expansion of the village because its existing settlement boundary is drawn tightly and will not allow for organic growth within the current settlement boundary. Q4. Do you know of any other sites not identified through the SHLAA process which you think should be considered as potentially suitable housing sites to allocate? If yes, please provide details. 6.12 These representations provide details of two sites for Blaxhall not previously considered. The requisite proforma and plans are in Appendices 1 and 2. Q5. Thinking about your own community, the people who live there, the people who would want to live there but maybe can't because there is nowhere suitable - what type and mix of housing do you think is most needed to meet your community's needs? Do you have any evidence which would support your comments and which could help support this Local Plan document as it progresses? An example might be an up to date parish plan. 6.13 It is understood from the District Council housing team that there is a consistent need for 1 and 2 bed affordable housing across the District including Blaxhall. 6.14 Affordable housing is an issue picked up in the 2004 Parish Plan which pre-dates the policy imperatives of the NPPF, PPG and Core Strategy by a decade. 6.15 The NPPF requires the planning system to boost significantly the supply of housing and in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. 6.16 As set out above the PPG refers to paragraphs 17, 28 and 54 of the NPPF in stating that "It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability, and the role of housing in supporting the broader sustainability of villages and smaller settlements. This is clearly set out in the National Planning Policy Framework, in the core planning principles, the section on

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6318 - 3055 - Blaxhall - None 6318 Support Woodbridge Housing Market Area Blaxhall

supporting a prosperous rural economy and the section on housing". 6.17 Government therefore expects local plans to provide for the sustainable expansion of villages, to provide affordable housing, which usually requires market housing to be developed as well, and not to prevent this by not allocating land through plan making. Q6. Do you think allocated sites should be included within any updated physical limits boundary or should remain outside of the physical limits boundary but denoted by a specific housing allocation designation? (Once allocated sites are built out, the opportunity would exist for the physical limits boundary to be redrawn next time they come up for review) 6.18 In order to provide for flexibility at this stage allocated sites should not be included in updated physical limits now as this will constrain the design process. As the District Council recognises there is an opportunity through detailed and careful design to provide high quality development, this process should not be constrained at the plan making stage.

7.0 Conclusion 7.1 These two sites proposed in these representations can provide Blaxhall with the opportunity to expand its supply of housing sustainably, and in a planned way over the plan period in a manner that will deliver the types and design of housing appropriate to the area. 7.2 Allocation of land in Blaxhall is important because the current settlement boundary is drawn tightly, and there are few if any, clear opportunities for windfall infill development over the plan period. 7.3 If the village is left with no allocation there will be few opportunities during the plan period for sustainable rural housing growth, leaving Blaxhall without housing to address the issues raised by the community. New housing can provide a range of house types such as bungalows to meet the needs of the elderly, family homes or homes for young people. Without new homes the population in rural areas ages and all sections of the population face increasing difficulties in finding appropriate housing. 7.4 Our client's sites are unconstrained because there are no planning or environmental constraints over them. Housing on Sites A and B could increase local housing supply and choice, provide homes for people wishing to stay in Blaxhall who cannot afford to do so and to support local facilities. The development of the site could provide benefits alongside housing being footpaths, and new landscaping. 7.5 They sites are immediately available and deliverable and development can be phased to release development on a time scale to meet local needs and the Government's express intention for all settlements to play a role delivering sustainable development in rural areas. Summary: Site A is located to the south of Station Road. It is 0.5ha in size. It could provide a maximum of around 12 dwellings but a lower number at a lower density could be more appropriate. The position of Site A introduces the opportunity to improve pedestrian links between the village, the village hall and playing field with a new footpath in conjunction with development of the eastern portion of Site A. The potential for the provision of a pedestrian footway would improve safety for residents moving between the main settlement and the village hall and playing field.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments: E280 C1 Rep02.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6319 - 3055 - Blaxhall - None 6319 Support Woodbridge Housing Market Area Blaxhall

Respondent: Evolution Town Planning (Mr Steven Bainbridge) Agent: N/A [3055]

Full Text: Suffolk Coastal District Council Issues and Options Consultation on Site Allocations and Area Specific Policies Local Plan Document Representations in Respect of Blaxhall and Sites off Station Road and off Mill Common Road

Reference: E280.C1.Rep02

1.0 Executive Summary

1.1 New housing development in Blaxhall, developed over the timeframe of the new Local Plan would deliver a range of new housing to meet local needs, support local infrastructure and provide site specific benefits. For example the average age of the local population is increasing, including bungalows in a new development would allow older people move to more appropriate homes and to remain living locally. Low levels of housing building make it difficult for local young people to buy homes, so new small homes or affordable homes can address this need. 1.2 Development of our one of both of our client's sites would provide for a proportionate number of new homes in Blaxhall giving additional choice of housing for those who wish to live there. 1.3 Blaxhall has around 126 homes. In the plan period to 2027 and to 2031 (as a result of the Core Strategy review later this year ), an increase of around 10% in the number of homes would normally be sustainable. The Parish Council is concerned about the impact of new housing and opposes a housing allocation. We suggest that any allocation should be between 3 and 12 homes, with homes designed to meet local housing needs and to be in character with the village. We propose two possible housing sites , and one or both could be developed with 3 to 12 homes in total with housing on the sites phased over the Local Plan period if required. 1.4 The development of these sites could provide local benefits other than homes. For example the site in Station Road could provide a pedestrian link between the village and the village hall and the playing fields which are detached from the main built up area.

2.0 Introduction 2.1 These representations describe two suitable housing sites adjacent to the settlement boundary and built up area of Blaxhall. The identification of these sites results from a village-wide walk over and assessment of the development potential of land around Blaxhall, and feedback received at a Parish Council meeting in January 2015. 2.2 Evolution Town Planning (ETP) are experienced in promoting small rural sites either through development plan representations or planning applications. We also have site assessment from working in Council planning departments. As a practice we have 30 years of combined professional experience in this type of work. 2.3 ETP have inspected various potential sites and the surrounding area. We have reviewed national planning policy and the District Councils Core Strategy and its requirements for local service centres . We have considered the Parish Plan for Blaxhall in terms of the needs and aspirations of the Parish Council. 2.4 The inset plan below and the plan in Appendix 1 identifies the two proposed sites and sets them in the context of the village of Blaxhall and its surroundings. (See attached document). 2.5 The sites edged in red are our suggested housing allocation sites, the land coloured blue outside these areas is in our client's ownership and could be used to support development for example to provide landscaping, drainage or other infrastructure. The dashed line shows the existing settlement boundary (physical limits boundary) for Blaxhall. The land highlighted green is registered common land which is shown here because of its importance to the village. The sites in brown are earlier potential allocation sites which have since been discounted by the District Council as unsuitable for allocation. The two sites could both be developed or one may be preferred over the other. 2.6 The whole of the land edged red at Site A may not be required to provide housing for Blaxhall, however it is available to provide other development related benefits if required such as a pedestrian link to the village hall and playing fields. 2.7 The plan shows that our client has a significant land holding adjacent to Blaxhall and abutting the settlement boundary. Rather than putting all the land forward for housing allocations we have focused on proposed areas which we consider to be the most appropriate for housing. The blue land could provide other forms of development such as drainage infrastructure or landscaping as part of any housing proposal. 2.8 Due to the potential afforded by the size of our client's land holding, development on these sites can be flexible in terms of the design to respond to local requirements of density, character, house type and affordability. For example, providing housing to meet local needs including bungalows, family homes, and affordable homes as required or providing for local facilities and improvements. 2.9 We consider that the maximum number of new homes that would appropriate in the plan period on new housing allocations would be 12. A number lower than that may be preferred. We consider that in total that sites A and B should provide between 3 and 12 new homes of a types and design that meets local needs and respects local character. 2.10 This report continues by assessing Blaxhall in the development hierarchy and the Development Plan it then goes on to assess the sites that have already been put forward in the village. It considers the proposed allocations against Core Strategy requirements then considers the individual characteristics and merits of the sites. 2.11 The requisite site submission proforma is in Appendix 2. (See attached document).

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6319 - 3055 - Blaxhall - None 6319 Support Woodbridge Housing Market Area Blaxhall

3.0 Description of the Sites and Surroundings

Blaxhall 3.1 The majority of the housing is focused around School Road. Further dwellings are located on Rectory Road, Church Road and Station Road to the west of the main settlement. 3.2 The allotments, common land and deep roadside verges surrounding them provide for an undeveloped element to the northern part of the village and are key to its character. 3.3 Blaxhall is recorded in the 2011 Census as having a population of 192 people and 126 dwellings across the Parish with a population skewed towards older age groups and a high proportion of home ownership. 3.4 The District Councils Issues and Options document only records one recent completion of a new home and there are no extant housing permissions in Blaxhall. 3.5 The village of Blaxhall is characterised by a wide mix of development. There are traditional detached and terraced cottages, along with modern homes and bungalows. Homes are either set back from the road behind generous frontages and verges (mainly to the north), or are set close to the roads (mainly to the south). The existing housing is relatively closely developed providing few opportunities for infill development. 3.6 There is generous green space in the built up area of the village with allotments and grassed areas. These areas are important to the villages character. New allocations should preserve the character of the village, and so the green spaces within the built up area should not be developed. 3.7 Blaxhall is described in the parish plan as: "Blaxhall's population of some 230 people has lost its shops and post office but retained a public house, a C of E Church, a small village hall and a recently modernised and expanded Youth Hostel. Blaxhall also has an international Language School, an international motorcycle scramble circuit and is within 1 mile of the internationally renowned Snape Maltings concert hall. The 123 homes in Blaxhall are widely dispersed around two main residential groupings, Mill Common and Stone Common, situated about 1 miles apart. " 3.8 The Blaxhall Parish Plan signposts its needs by highlighting issues which the community considered were 'poor and required action'. These are:

3.9 Other issues referred to as requiring improvement include road safety, litter and public transport. 3.10 Recent Parish Council discussions have considered the desirability of protecting for the village the brown land labelled 995 and 643 on the above plan. This land has previously been put forward for housing development and has been rejected by the District and Parish Councils. The land is however well related to the built up area of the village.

Site A 3.11 Site A is 0.5ha in size and is shown on map E280 SA1 located to the west of Blaxhall and adjoins land recently the subject of planning application DC/14/3247/OUT for a detached dwelling. 3.12 The site is accessed off Station Road and encompasses land between the edge of Blaxhall and the village hall and playing field. 3.13 There is sufficient road frontage to provide for a safe and suitable access (NPPF para 32) which would meet relevant standards (DfT Manual for Streets: Safe Stopping Distances Table 7.1 (p91)). 3.14 Site A is currently Grade 4 agricultural land and is unconstrained because there are no planning or environmental constraints affecting it for example historic designations or wildlife sites. 3.15 To the west of Site A is the village hall and playing fields and agricultural land. To the north and south is also agricultural land and to the east is the built up area of the village.

Site B 3.16 Site B again is 0.5ha in size and is shown on map E280 SA1 located to the east of Blaxhall, and abutting the settlement boundary. 3.17 Site B is currently Grade 4 agricultural land and is unconstrained because there are no planning or environmental constraints affecting it . 3.18 To the west and north of Site B is residential development and to the east and south if agricultural land. 3.19 The site is accessed off Mill Common Road. There is sufficient road frontage to provide for a safe and suitable access 3 which would meet relevant standards (DfT Manual for Streets: Safe Stopping Distances Table 7.1 (p91)).

4.0 Planning Policy 4.1 Blaxhall is categorised in the Suffolk Coastal Core Strategy as a 'Local Service Centre'. This means it has a range of local facilitie s and will be expected to accommodate new housing development that is consistent with the scale and character of Blaxhall. 4.2 The Suffolk Coastal Core Strategy which pre-dates the national planning guidance in the Planning Practice Guidance (PPG) sets out the distribution of new development that will be planned for across the whole District. It states

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6319 - 3055 - Blaxhall - None 6319 Support Woodbridge Housing Market Area Blaxhall

that the Key and Local Services Centres will be expected to accommodate 17% of the total of new dwellings. Blaxhall is expected to play its role in delivering sustainable development and rural housing growth. 4.3 The purpose of making provision for small scale development in villages like Blaxhall is to ensure that local services can be sustained economically and that people wishing to live in the area have the opportunity to do so5. These are both key issues raised in the Blaxhall Parish Plan from 2004. 4.4 The nature of the village means there are few opportunities for windfall development. Reliance on infill development in the local service centres may be misplaced. In all the time Suffolk Coastal District Council (SCDC) has been without a 5 year housing supply the Issues and Options document only recently records 1 completion and no extant permissions in Blaxhall. 4.5 Therefore if the village is left with no al location there may be few if any opportunities during the plan period for sustainable rural housing growth leaving Blaxhall to stagnate and the issues raised by the community to go unaddressed. 4.6 The NPPF recognises the need to support rural communities with sustainable levels of housing growth which in turn promote the retention and development of community facilities. 4.7 The Site Allocations Issues and Options document sets out an approach based on the Core Strategy which is now at odds with the PPG because the District Council is not planning for the sustainable expansion of Blaxhall through the current plan period to 2027, let alone the extended period to 2031 arising from the Core Strategy review later in 2015. The PPG states: "all settlements can play a role in delivering sustainable development in rural areas and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided unless their use can be supported by robust evidence." 4.8 New housing development in Blaxhall will provide for a sustainable increase in population which should help the local community deal with the issues they have identified. 4.9 There will need to be flexibility in the Site Allocations to cover the Core Strategy review which will extend the plan period to 2031. 4.10 This submission proposes sites for consideration for housing development that is in scale and kind with Blaxhall as part of that District -wide approach. 4.11 The Core Strategy envisages proportionate development at Blaxhall and to be sustainable it will need to relate well to the existing settlement boundary so the focus will therefore be on the unconstrained and deliverable sites which have that relationship. We consider that a sustainable allocation would be between 3 and 12 homes. 4.12 The sites identified by the District Council as 643, 995 and 685 have already been submitted to the Council by third parties and have been discounted by the District Council as unsuitable for housing development.

5 Suffolk Coastal Core Strategy

5.0 The Sites Constraints and Opportunities 5.1 The inset plan above (and in Appendix 1 - see attached document) indicates the two separate parcels of land that are the subject of this submission. 5.2 Sites A and B are considered suitable for accommodating development at a low density to reflect local character. 5.3 These sites are not mutually exclusive. The District Council may wish to proceed with both or one of them in combination in order to achieve an appropriately sized allocation for Blaxhall. We consider that up to 12 homes could be provided in total in the village using one or both the sites. 5.4 The wider land holding around site A could provide for landscaping and/or open space requirements as necessary.

Site A 5.5 Site A is located to the south of Station Road. It is 0.5ha in size which means it could provide a maximum of around 12 dwellings but a lower number at a lower density could be more appropriate for Blaxhall. 5.6 Site A offers the opportunity to link the main settlement to the village hall and playing fields and children's play area. At a recent Parish Council meeting it was noted all attendees drove the approximate 300m from Blaxhall to the village hall and none walked. 5.7 The position of Site A introduces the opportunity to improve pedestrian links between the village and the village hall and playing field with a new footpath in conjunction with development of the eastern portion of Site A closest to the village. The potential for the provision of a pedestrian footway would improve safety for residents moving between the main settlement and the village hall and playing field. 5.8 Development of a part of this site could be similar in design and layout to that fronting School Road and Rectory Road nearby i.e. detached and terraced cottages set back from the road. 5.9 Local examples include (see attached document). 5.10 The site has no ecology constraints being arable field and is unlikely to feature species or habitats of interest. However sensitive landscaping could provide for a net increase in biodiversity interest with the provision of new trees and hedgerows. 5.11 There are no landscape designations constraining the site. In visual terms development of this parcel of land could provide a functional linkage between the village and the village hall and playing field.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6319 - 3055 - Blaxhall - None 6319 Support Woodbridge Housing Market Area Blaxhall

5.12 The extent of land ownership in this location would provide for ample landscaping to the south of the proposed site. 5.13 In summary Site A is available and is unconstrained and could provide for the future rural housing needs of Blaxhall including 1 and 2 bed homes and/or bungalows, built to reflect local character.

Site B 5.14 Site B is located south of Mill Common Road. It is 0.5ha in size so could accommodate a maximum of around 12 dwellings but again a lower number at a lower density could be more appropriate for that part of the village. 5.15 Development in this location would relate well to the existing settlement boundary. With good design it would provide for an attractive new entrance into the village with interesting traditionally des igned dwellings fronting the road and traditional village features. Well landscaped verges could mirror the existing wide verges on the common land opposite. 5.16 The site has no ecology constraints being arable field. The site is within the Special Landscape Area designation. To mitigate any adverse impact the site is large enough to provide a well landscaped edge on its east and south sides. 5.17 As part of any development the provision of village gateway signs should be considered. This is because while the 30mph zone begins some 220m east of the edge of the settlement boundary there is little to inform drivers of this until reaching the village itself. This is an issue highlighted as important in the Parish Plan. 5.18 Development in this location could be similar in design and layout to nearby development being a mixture of detached houses and bungalows with substantial front gardens and properties set back from the main road and accessed off a close or lane. 5.19 Local examples include (see attached document). 5.20 The extent of land ownership on this site also provides sufficient land for landscaping that reflects the nearby common land and heath habitats. 5.21 In summary Site B is available and is unconstrained and could provide for the future housing needs of Blaxhall either on its own or in combination with Site A. 5.22 The two sites have been assessed in terms of their suitability (performance against the District Council's criteria) for housing development and are considered to be suitable, available and deliverable. 5.23 The table below sets out the opportunities and constraints for the two sites. It uses criteria from the Council's 'call for sites' proforma and SHLAA assessment sheets.

SCDC criterion Site A Site B Area 0.56ha 0.54ha Status Greenfield Greenfield % of site for housing Up to 100 Up to 100 Density Low Low Indicative capacity Max. 12 Max. 12 Likely delivery timescale 0-5 years 0-5 years Access or highways No (within the 30mph No (within the 30mph issues zone) zone) AQMA No No Area of archaeological No No importance Agricultural land grade Grade 4 Grade 4 Conservation area No No Contaminated No No Existing use Agricultural Agricultural Flood zone 1 1 Listed buildings No No Open space No No TPO No No Wildlife site or adjacent No No to Other constraints No SLA Suitable Yes Yes Available Yes Yes Achievable Yes Yes Summary Deliverable and Deliverable and developable. developable.

5.24 Both sites A and B have development potential for housing. One or both could be developed. We consider that the maximum number of homes appropriate for the village in the plan period is a 10% increase or 12 homes. The number proposed could be less and spread over both sites. 5.25 Housing should be developed at a density to accord with the existing character, and in a range of types, such as family homes, bungalows, or starter homes to meet local needs. The District Councils requirement to provide a third of homes as affordable would address requirements for low cost housing.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6319 - 3055 - Blaxhall - None 6319 Support Woodbridge Housing Market Area Blaxhall

6.0 Answers to Suffolk Coastal District Council Consultation Questions

6.1 The following section provides answers to relevant questions in the Issues and Options consultation document. Q1. Do you have any thoughts on the approach the Council has followed? Is there an alternative approach that you think should be considered for the more detailed distribution of housing in the Market Towns and Key and Local Service Centres set out in the Core Strategy and why? 6.2 Page 14 of the Issues and Options consultation document states that 'Approach 1' was "rejected when the broad scale and distribution of housing was adopted through the Core Strategy". It also states that 'Approach 2' is "the one which has been used" in the Core Strategy and the Issues and Options documents "reflects this approach". 6.3 The Core Strategy was adopted in July 2013 and post -dated the National Planning Policy Framework (the Framework). However subsequent National Planning Practice Guidance (the PPG) has been issued which 'Approach 2' does not conform to. 6.4 Specifically the PPG states: "It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability, and the role of housing in supporting the broader sustainability of villages and smaller settlements. This is clearly set out in the National Planning Policy Framework, in the core planning principles, the section on supporting a prosperous rural economy and the section on housing. A thriving rural community in a living, working countryside depends, in part, on retaining local services and community facilities such as schools, local shops, cultural venues, public houses and places of worship. Rural housing is essential to ensure viable use of these local facilities. Assessing housing need and allocating sites should be considered at a strategic level and through the Local Plan and/or neighbourhood plan process. However all settlements can play a role in delivering sustainable development in rural areas and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided unless their use can be supported by robust evidence." 6.5 The Councils 'Approach 2' leads to many Key and Local Service Centre villages having a residual housing requirement of zero. This is the case in Blaxhall. 6.6 For villages to sustain themselves for the lifetime of the plan period to 2027 and to 2031 after the Core Strategy review it is important for some land to be allocated in the plan. 6.7 Allocation of land for development on Sites A and B would allow for future development to come forward during the plan period, as the PPG expects, to ensure the village grows in a planned way and to ensure the future viability of village facilities to 2027 and 2031. Q2. Does the suggested amount of new housing to be provided in your village/town sound about right? If not, why not and what is an appropriate amount? 6.8 As set out above in order to be in conformity with the PPG it would be necessary for Blaxhall to be allocated an amount of housing to allow for planned housing development within the plan period to 2027 and to 2031 after the Core Strategy review rather than be left with a blanket zero due in part to recent and as yet undecided planning application. 6.9 The Issues and Options document at its paragraph 3.5 states: "It is essential that the Council provides over and above the minimum amount of land needed to meet the target as this will provide flexibility and choice for future residents, developers and other stakeholders. Having a variety of sites also promotes a flexible approach which will help to overcome any site specific issues that may arise over the plan period. Over allocating land for development also enables the Council to clearly demonstrate that sufficient land is available and can come forward throughout the entirety of the plan period." 6.10 It is not clear which plan period is referred to; 2027 or 2031 (as a result of the Core Strategy review later this year). A residual allocation of zero for Blaxhall will not 'provide flexibility and choice for future resident s' of that village. 6.11 In the absence of robust evidence Blaxhall should be provided with a residual allocation that allows for future expansion of the village because its existing settlement boundary is drawn tightly and will not allow for organic growth within the current settlement boundary. Q4. Do you know of any other sites not identified through the SHLAA process which you think should be considered as potentially suitable housing sites to allocate? If yes, please provide details. 6.12 These representations provide details of two sites for Blaxhall not previously considered. The requisite proforma and plans are in Appendices 1 and 2. Q5. Thinking about your own community, the people who live there, the people who would want to live there but maybe can't because there is nowhere suitable - what type and mix of housing do you think is most needed to meet your community's needs? Do you have any evidence which would support your comments and which could help support this Local Plan document as it progresses? An example might be an up to date parish plan. 6.13 It is understood from the District Council housing team that there is a consistent need for 1 and 2 bed affordable housing across the District including Blaxhall. 6.14 Affordable housing is an issue picked up in the 2004 Parish Plan which pre-dates the policy imperatives of the NPPF, PPG and Core Strategy by a decade. 6.15 The NPPF requires the planning system to boost significantly the supply of housing and in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. 6.16 As set out above the PPG refers to paragraphs 17, 28 and 54 of the NPPF in stating that "It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability, and the role of housing in supporting the broader sustainability of villages and smaller settlements. This is clearly set out in the National Planning Policy Framework, in the core planning principles, the section on

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6319 - 3055 - Blaxhall - None 6319 Support Woodbridge Housing Market Area Blaxhall

supporting a prosperous rural economy and the section on housing". 6.17 Government therefore expects local plans to provide for the sustainable expansion of villages, to provide affordable housing, which usually requires market housing to be developed as well, and not to prevent this by not allocating land through plan making. Q6. Do you think allocated sites should be included within any updated physical limits boundary or should remain outside of the physical limits boundary but denoted by a specific housing allocation designation? (Once allocated sites are built out, the opportunity would exist for the physical limits boundary to be redrawn next time they come up for review) 6.18 In order to provide for flexibility at this stage allocated sites should not be included in updated physical limits now as this will constrain the design process. As the District Council recognises there is an opportunity through detailed and careful design to provide high quality development, this process should not be constrained at the plan making stage.

7.0 Conclusion 7.1 These two sites proposed in these representations can provide Blaxhall with the opportunity to expand its supply of housing sustainably, and in a planned way over the plan period in a manner that will deliver the types and design of housing appropriate to the area. 7.2 Allocation of land in Blaxhall is important because the current settlement boundary is drawn tightly, and there are few if any, clear opportunities for windfall infill development over the plan period. 7.3 If the village is left with no allocation there will be few opportunities during the plan period for sustainable rural housing growth, leaving Blaxhall without housing to address the issues raised by the community. New housing can provide a range of house types such as bungalows to meet the needs of the elderly, family homes or homes for young people. Without new homes the population in rural areas ages and all sections of the population face increasing difficulties in finding appropriate housing. 7.4 Our client's sites are unconstrained because there are no planning or environmental constraints over them. Housing on Sites A and B could increase local housing supply and choice, provide homes for people wishing to stay in Blaxhall who cannot afford to do so and to support local facilities. The development of the site could provide benefits alongside housing being footpaths, and new landscaping. 7.5 They sites are immediately available and deliverable and development can be phased to release development on a time scale to meet local needs and the Government's express intention for all settlements to play a role delivering sustainable development in rural areas. Summary: Site B is located south of Mill Common Road. It is 0.5ha in size so could accommodate a maximum of around 12 dwellings but again a lower number at a lower density could be more appropriate for that part of the village. Development in this location would relate well to the existing settlement boundary. With good design it would provide for an attractive new entrance into the village with interesting traditionally des igned dwellings fronting the road and traditional village features. Well landscaped verges could mirror the existing wide verges on the common land opposite.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments: E280 C1 Rep02.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5713 - 3055 - - None 5713 Support Woodbridge Housing Market Area Bredfield

Respondent: Evolution Town Planning (Mr Steven Bainbridge) Agent: N/A [3055]

Full Text: 1.0 Executive Summary 1.1 This report presents a new site in Bredfield for consideration in the Site Allocations local plan consultation process. 1.2 The site is well related to the existing settlement boundary and this relationship will be improved with the proposed changes to the settlement boundary by increasing the proportion of the site which adjoins it. 1.3 In comparison with other sites near to the centre of the village this site would have the least impact on the residential amenity of neighbours. There are only about 5 dwellings within 100m of the site. 1.4 Other sites in Bredfield are either more dominant in terms of visual impact to neighbouring properties or are located to the furthest edges of the settlement boundary and away from village facilities. 1.5 The site is large enough that it could provide for the housing needs for Bredfield for the lifetime of the local plan. If the whole site is not required for development then opportunities may exist for complementing the pubic footpath and providing amenity space in the heart of the village.

2.0 Introduction 2.1 These representations introduce a potential housing site in Bredfield and result from a village-wide walk over and feedback received at a Parish Council meeting in January 2015. 2.2 Evolution Town Planning (ETP) are experienced in promoting small rural sites either through development plan representations or planning applications but also site assessment from working in Council planning departments. As a practice we have 30 years of combined professional experience in this type of work. 2.3 Our client owns land abutting Bredfield which we have assessed for its development potential. We are submitting this site to the District Council's Site Allocations Issues and Options consultation for consideration as a local plan allocation. 2.4 ETP have inspected various potential sites and walked the village to get a first-hand understanding of Bredfield and its surroundings. We have reviewed the Core Strategy and its requirements for local service centres and the Parish Plan (2006 and the 2008 update) in terms of the needs and aspirations of the community. 2.5 The District Council is undertaking public consultation on sites submitted to it previously and to identify new sites not previously included in earlier stages of the plan process. This submission is for consideration further to those previously submitted for development at Bredfield. 2.6 The inset plan below and in Appendix 1 identifies the land in question and sets it in the context of the village of Bredfield and its surroundings. The site edged in red is our suggested allocation site. If all three parts are not required then the western and central parcels have better access and should be preferred for housing. 2.7 This plans shows that our client has a significant land holding in Bredfield which relates well to the existing settlement boundary (the dashed line please see attached document). Access for both vehicles and pedestrians is excellent onto Woodbridge Road. 2.8 Due to the potential afforded by the size of our client's land holding, development on this site can be flexible in terms of density, character, layout and house type. 2.9 Our client is willing to respond to what the community needs whether that be housing for older people wishing to downsize whilst remaining in Bredfield or for first time buyers unable to afford the large detached dwellings which dominate the village's housing stock . 2.10 This report continues by assessing Bredfield in the development hierarchy and the Development Plan. It considers the proposed allocations and Parish Plan then considers the individual characteristics and merits of the site. 2.11 The requisite site submission proforma is in Appendix 2. This sets out the site areas of each of the parcels as being 0.5ha for the western parcel, 0.4ha for the central parcel and 1ha for the eastern parcel.

3.0 Description of the Site and Surroundings 3.1 The site is located east of Woodbridge Road. The western portion of the site is a former poplar plantation. The central and eastern portions of the site are currently not in active agricultural use and laid to pasture. 3.2 The site is bounded to the north by residential properties and to the south by Byng Brook. To the west beyond Woodbridge Road are residential properties and to the east, Ufford Road and agricultural land beyond. 3.3 On our site visits the site appeared to be of low ecological value, any ecological interest would be with the boundary vegetation which would be retained and strengthened as part of development proposals. There are no ecological designations on the site meaning there no constraints to development from ecology. 3.4 The Byng Brook runs to the south of the site but this should not be a constraint to development. It can provide outfall opportunities in managing site surface water on our site. 3.5 Woodbridge Road is a 30mph zone. The existing site access onto Woodbridge Road affords good visibility for 80m in both directions and the bends in the road act to control vehicle speeds. An access from the inside bend to the north of the road frontage would provide visibility of some 100m+ in both directions. 3.6 A pavement linking the site to the northern and southern halves of Bredfield passes the roadside edge of the site. 3.7 The site is some 200m from the nearest bus stops providing regular services Monday to Saturday to Woodbridge and Ipswich (see bus timetables in Appendix 3) starting from 7.28 in the morning and currently ending at 4.55 in the afternoon. 3.8 Bredfield has a number of local facilities including a pub, village hall, church, chapel, shop, playing pitches for football and cricket, two hard tennis courts, bowling green, children's play area and a small employment area off Scotts Lane. 3.9 The site is well located in relation to local services in a sustainable settlement.

4.0 Site Constraints and Opportunities

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5713 - 3055 - Bredfield - None 5713 Support Woodbridge Housing Market Area Bredfield

4.1 The principle opportunity of this site is its extent and location abutting the settlement boundary. Because of the extent of land under our clients control, and because the site is well placed in the village and in relation to facilities and services, it would be appropriate to develop a range of house types to reflect local needs. 4.2 There are very few dwellings overlooking the site so residential amenity impacts arising from its development would be minimal in comparison to other sites in Bredfield. 4.3 The site is located centrally in the village and in terms of landscape impact it is in our opinion the best placed site being promoted in the village. 4.4 There are no nearby significant noise sources and the land is unlikely to be contaminated because the sites appear never to have hosted buildings according to historical map regression. 4.5 The site is unconstrained as can be seen in the site submission Proforma because there are no planning or environmental designations affecting it such as listed buildings or wildlife sites. 4.6 At a combined total of 1. 9ha the three parcels of land could provide for the future housing needs of Bredfield which the District Council indicate is a minimum of 5 to 10 dwellings for the plan period to 2027 and then to 2031 when the Core Strategy is reviewed later this year . 4.7 The site bounds a public footpath and there may be opportunities to enhance the right of way or provide amenity space to complement it.

5.0 Proposed Use and Assessment of Development Potential 5.1 Bredfield is defined as a Local Service Centre in the Core Strategy which means it has a range of local facilities and will be expected to accommodate new housing development that is consistent with its scale and character. 5.2 The NPPF recognises the need to support rural communities with sustainable levels of housing growth which in turn promote the retention and development of community facilities. 5.3 The Suffolk Coastal Core Strategy (which pre-dates the PPG) sets out the distribution of new development that will be planned for across the whole District. 5.4 The Core Strategy states that "new housing development in the local service centres has the advantage of creating affordable housing as well as aiding the viability of such local facilities as shops and post offices" . 5.5 It goes on to say that in order to establish "a 15 year land supply [...] allocations will be necessary. Such allocations will have the prime purpose of achieving housing to meet local needs, an objective supported by many communities in the district. They will be restricted to those Key and Local Service Centres where: local housing need has been demonstrated; and there is community support." 5.6 The purpose of making provision for a proportionate scale of development in villages like Bredfield is to ensure that local services can be sustained economically and that people wishing to live in the area have the opportunity to do so. These are both key issues raised in the Bredfield Parish Plan. 5.7 The Parish Plan pre-dates the Core Strategy, National Planning Policy Framework and National Planning Practice Guidance and as such does not reflect the Government's housing growth agenda and the express desire to deliver a wide choice of high quality homes and to boost significantly the supply of housing. 5.8 Nonetheless the Parish Plan makes the following positive statements towards new development (our emphasis in bold): * the market is such that plots within the physical limits boundary have been used for large "executive-style" houses; small cottages rarely come on the market. * accommodate more housing. * be welcome * majority of respondents (69%) stated that it was not. Villagers evidently do not object to the construction of small houses, perhaps in groups of less than five dwellings, but it must be contained within the present development boundary identified in the Local Plan. This obviously does pose something of a problem for any potential development. Finding the required space to carry out any planned development will be difficult to achieve with the limited area available. 5.9 The Parish Plan represents measured local support for a proportionate scale of development in Bredfield at a point in time before the economic downturn and the Government's housing growth agenda. 5.10 The site we are proposing as a potential allocation is well placed in the village being well related to the settlement boundary and village facilities and would have little amenity impact on neighbouring properties. 5.11 Reflecting the requirements of the NPPF we have considered whether the sites are deliverable and developable. 5.12 This site is unconstrained and immediately available. It is well related to the settlement boundary of Bredfield, which is a local service centre, and is considered suitable. Being unconstrained it is also considered achievable within 5 years. 5.13 Our client owns sufficient land that there is flexibility on the housing density and landscaping necessary to reflect local character. The site could provide 1 and 2 bed dwellings as well as bungalows for older people wishing to downsize and remain in the village. There is sufficient space to match development densities of adjacent properties. 5.14 It is important to note that, as recognised by the Parish Plan, opportunities for infill development within the settlement boundary are unclear and the existing and proposed settlement boundary is drawn tightly around the existing built form of the village. 5.15 As the Core Strategy recognises in such circumstances; 'an allocation will be necessary'.

6.0 Answers to Consultation Questions

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5713 - 3055 - Bredfield - None 5713 Support Woodbridge Housing Market Area Bredfield

6.1 The following section provides answers to relevant questions in the Issues and Options consultation document. Q1. Do you have any thoughts on the approach the Council has followed? Is there an alternative approach that you think should be considered for the more detailed distribution of housing in the Market Towns and Key and Local Service Centres set out in the Core Strategy and why? 6.2 Page 14 of the Issues and Options consultation document states that 'Approach 1' was "rejected when the broad scale and distribution of housing was adopted through the Core Strategy". It also states that 'Approach 2' is "the one which has been used" in the Core Strategy and the Issues and Options documents "reflects this approach". 6.3 The Core Strategy was adopted in July 2013 and post-dated the National Planning Policy Framework (the Framework). However subsequent National Planning Practice Guidance (the PPG) has been issued which 'Approach 2' does not conform to. 6.4 Specifically the PPG states: "It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability, and the role of housing in supporting the broader sustainability of villages and smaller settlements. This is clearly set out in the National Planning Policy Framework, in the core planning principles, the section on supporting a prosperous rural economy and the section on housing. A thriving rural community in a living, working countryside depends, in part, on retaining local services and community facilities such as schools, local shops, cultural venues, public houses and places of worship. Rural housing is essential to ensure viable use of these local facilities. Assessing housing need and allocating sites should be considered at a strategic level and through the Local Plan and/or neighbourhood plan process. However all settlements can play a role in delivering sustainable development in rural areas and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided unless their use can be supported by robust evidence." 6.5 Approach 2 leads to many Key and Local Service Centres having a residual housing requirement of zero. This is currently not the case for Bredfield. 6.6 For villages to sustain themselves for the lifetime of the plan period to 2027 it is important for some land to be allocated in the plan. 6.7 Allocation of land for development in Bredfield would allow for future development to come forward during the plan period, as the PPG expects, to ensure the village grows in a clearly planned way and to ensure the future viability of village facilities to 2027. Q2. Does the suggested amount of new housing to be provided in your village/town sound about right? If not, why not and what is an appropriate amount? 6.8 As set out above in order to be in conformity with the PPG it would be necessary for Bredfield to be allocated an amount of housing to allow for planned housing development within the plan period to 2027. 6.9 Bredfield should be provided with an allocation that allows for future expansion of the village because as the Parish Plan recognized in 2006 its existing settlement boundary is drawn tightly and will not allow for organic growth in the future. 6.10 For the sake of clarity it would be useful if all housing figures in the Site Allocations local plan document were caveated as minimum figures reflecting national planning policy and guidance. This would perhaps help communities where some perceive the figures as maximums (which is incorrect). Q4. Do you know of any other sites not identified through the SHLAA process which you think should be considered as potentially suitable housing sites to allocate? If yes, please provide details. 6.11 These representations provide details of a site in Bredfield not previously considered. The requisite proforma and plan are in Appendices 1 and 2.

Q5. Thinking about your own community, the people who live there, the people who would want to live there but maybe can't because there is nowhere suitable - what type and mix of housing do you think is most needed to meet your community's needs? Do you have any evidence which would support your comments and which could help support this Local Plan document as it progresses? An example might be an up to date parish plan. 6.12 It is understood from the District Council housing team that there is a consistent need for 1 and 2 bed affordable housing across the District including Bredfield. 6.13 Affordable housing is an issue picked up in the Parish Plan as is housing for elderly people. 6.14 The Parish Plan recorded a majority of respondents specifying the types of housing they would prefer to see: 6.15 The above graph taken from the Parish Plan indicates only a minority of respondents wished for there to be no further development. (See attached document) 6.16 The pattern apparent from the Parish Plan survey is common in rural areas and is something our client is willing to work with the community to deliver on this site.

Q6. Do you think allocated sites should be included within any updated physical limits boundary or should remain outside of the physical limits boundary but denoted by a specific housing allocation designation? (Once allocated sites are built out, the opportunity would exist for the physical limits boundary to be redrawn next time they come up for review) 6.17 In order to provide for flexibility at this stage allocated sites should not be included in updated physical limits. As the District Council recognises an opportunity to reflect the final built form and layout of development will exist in future reviews of the plan.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5713 - 3055 - Bredfield - None 5713 Support Woodbridge Housing Market Area Bredfield

7.0 Conclusion 7.1 We are pleased to submit this site to the District Council for allocation to provide Bredfield with the opportunity to expand its supply of rural housing sustainably and in a planned way over the plan period with minimal impact on neighbouring properties. 7.2 Allocation of land in Bredfield is important because the current settlement boundary is drawn tightly and there are few if any clear opportunities for windfall infill development and very few developments have come forward in recent years inside the existing settlement boundary despite there being no 5 year housing supply. 7.3 This site is in our opinion the best placed to offer the housing needs for the village for the plan period. 7.4 The submitted site has no planning or environmental designations on it and it is immediately available because it is currently vacant. 7.5 The is considered deliverable for these reasons and if necessary development can be phased and released to meet local needs over the relevant stages of the local plan period. Summary: The site is well related to the existing settlement boundary. In comparison with other sites near to the centre of the village this site would have the least impact on the residential amenity of neighbours. There are only about 5 dwellings within 100m of the site. Other sites in Bredfield are either more dominant in terms of visual impact to neighbouring properties or are located to the furthest edges of the settlement boundary and away from village facilities. The site is large enough that it could provide for the housing needs for Bredfield for the lifetime of the local plan.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments: E358 C1 Rep01a_.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6183 - 483 - Bredfield - None 6183 Comment Woodbridge Housing Market Area Bredfield

Respondent: Anglian Water (Sue Bull) [483] Agent: N/A

Full Text: Thank you for the opportunity to comment on the Issues & Options Consultation document (December 2014).

Neighbourhood Plans Whilst Anglian Water (AW) has no comment to make on the neighbourhood area designation stage of a Neighbourhood Plan we are pleased to be consulted on the plans once they progress to draft plan stage. We are currently considering the Leiston Neighbourhood Plan and will make comment within the consultation period.

Felixstowe Area Action Plan Anglian Water are submitting representation on this consultation.

Site Allocations

Please find attached RAG spreadsheet summarising Anglian Water's comment on each site. It is important to note that this assessment does not take account of the cumulative impact of all the sites on the capacity of the Water Recycling Centres; the sites are assessed individually.

Asset Encroachment

Please note Sites 12ucl,13ucl,350,350b,408a,583a,672a,776i and 776L and WE04 are within the 400m consultation zone of the Water Recycling Centre (WRC) (formally referred to as Sewage or Wastewater Treatment Works). Initial assessment has indicated that there is an odour risk. Further discussion with Anglian Water is needed. Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage.

If a landowner or potential developer wishes to pursue an enquiry for development it is recommended they contact AW at the earliest opportunity to discuss the level of risk and the requirement for an odour risk assessment to be carried out.

Anglian Water does not want to thwart development or apply a blanket embargo on all development within 400 metres of our WRC, however we must balance this with protecting our new and existing customers from the risk of nuisance/loss of amenity whilst allowing us to provide the essential sewage treatment service to our customers and for this reason we take a risk based approach.

Similarly, development should be located a minimum of 15 metres from Pumping Stations to avoid the risk of nuisance/loss of amenity . With development proposals close to a foul pumping station,(site 693), it may be the layout of the site can be adjusted so as not to encroach on the 15 metre protection zone. The landowner/developer is advised to contact AW at the earliest opportunity to discuss.

Where there are sewers crossing the site, the site layout should be designed to take these into account; this existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The sewers should be located in highways or public open space. If it is not possible to accommodate the existing sewers within the design then diversion may be possible under section 185 of the Water Industry Act 1991 or entering into a build over/near agreement may be considered.

Details of Anglian Water encroachment policy can be viewed at: http://www.anglianwater.co.uk/developers/encroachment.aspx

Sewerage Network

The foul (or used water) flows from future growth will have an impact on the existing foul sewerage network. As outlined within the attached RAG sheet, upgrades to the network is likely to be required for a number of developments . The foul infrastructure requirements will be dependant on the location, size and phasing of the development.

We would want to see policy to ensure necessary infrastructure to serve allocations is planned and implemented before development proceeds (and dwellings occupied). To ensure this is carried through to a tactical level, we would at planning consent stage request the use of appropriate conditions to ensure infrastructure is in place before development is connected to the public sewerage network.

Surface Water and Flood Risk

Appropriate management of flood risk and the consideration of climate change is critical for long term resilience.

Whilst fluvial flooding is a significant constraint to the location of development, other forms of flooding such as surface water should be a consideration.

All developments should seek to reduce flood risk and incorporate Sustainable Drainage Systems (SuDS). We would

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6183 - 483 - Bredfield - None 6183 Comment Woodbridge Housing Market Area Bredfield

wish to see in policy that all developments should adhere to the surface water management hierarchy outlined in Part H of Building Regulations with disposal to a surface water sewer seen as a last resort. Under no circumstances will surface water be permitted to discharge to the public foul sewerage network and no new flow will be permitted to discharge to the combined network. We would want the document to clearly state that a surface water drainage solution will need to be identified and implemented prior to the construction of hard standing areas. The solution would need to be agreed with all stakeholders.

Engagement with developers

Anglian Water offers a pre planning service which includes a capacity check to determine the impact of sewerage from a proposed development. We will also work with the developer or land owner during this process to develop foul and surface water (where applicable) drainage solutions which will not cause a detriment to our existing or future customer. We would encourage the prospective developer to contact us at the earliest convenience to discuss drainage proposals to serve the development. Details regarding this service can be found at http://www.anglianwater.co.uk/developers/pre- planning-service-.aspx

Anglian Water are keep to engage with Suffolk Coastal District Council on Local Plan consultations and on individual planning applications. Summary: 780c: May required process enhancement to treat FW

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: 5002_Suffolk_Coastal_allocation_-_sites_consultation_sheet_(RSP)_-_Jan-15(1).pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5715 - 3055 - Butley - None 5715 Support Woodbridge Housing Market Area Butley

Respondent: Evolution Town Planning (Mr Steven Bainbridge) Agent: N/A [3055]

Full Text: 1.0 Executive Summary 1.1 We understand that Butley Parish Council is keen that the District Council reverse their decision to allocate no development in the village between now and the end of the plan period and allocate a site to meet local housing needs. 1.2 Having attended a recent Parish Council meeting to discuss this site, Butley Parish Council reconfirmed their strong wish for the site to be developed and for the site to provide a proportion of affordable housing for the village. This included an understanding and acceptance of the need for a proportion of market housing to make development viable. 1.3 The current settlement boundary is drawn tightly around Butley and there are few if any opportunities for windfall infill development. The Parish Council stated that there have been no new dwellings in Butley since the 1980s and certainly none in recent years. 1.4 This site is previously developed having been the site of the former middle school and it is well related to the existing settlement boundary. This relationship will improve with the suggested settlement boundary. 1.5 Development of this site has the support of the Parish Council in principle and a landowner willing to work with the Parish Council on a development that meets both party's needs. 1.6 The site has scored well in the District Council's site assessments and we consider that the site is deliverable and can be phased and released to meet both the local needs and those of our client.

2.0 Introduction 2.1 Evolution Town Planning LLP (ETP) have been instructed by the land owner to make representations to Suffolk Coastal District Council (SCDC) in respect of land at Butley (SCDC site ref. 596) for housing via an allocation in in the new local plan. 2.2 The site is shown inset below and in Appendix 1. (See attached document) 2.3 These representations are submitted to the Issues and Options consultation and follow on from representations made in July 2013 (our ref. E232.C1.Rep01) and should be read in conjunction with them. 2.4 Evolution Town Planning (ETP) are experienced in promoting small rural sites either through development plan representations or planning applications but also site assessment from working in Council planning departments. As a practice we have 30 years of combined professional experience in this type of work. 2.5 ETP are familiar with Butley and its surroundings and have met with the Parish Council during this consultation stage. 2.6 We have reviewed the Core Strategy and its requirements for local service centres and understand from the Parish Council the needs and aspirations of the community.

3.0 Description of the Site and Surroundings 3.1 The village of Butley is a local service centre and is divided between two areas of settlement boundary. 3.2 The settlement to the north is characterised by older red brick and flint cottages immediately fronting The Street (B1084) . 3.3 The settlement area to the south is characterised by the semi -detached dwellings fronting Short Walk/Church Road which are on larger individual plots. 3.4 This site is located to the southeast of Butley, adjoining the settlement boundary, and is accessed via an existing access off Short Walk and Church Road. 3.5 The access is wide and the site owner has control over the visibility splays, and there is good visibility in either direction. 3.6 The access exits into a 30mph zone so it meets the NPPF requirements of being safe and suitable. 3.7 Immediately opposite the site entrance is a pedestrian footway which links the site to the rest of Butley and which is shown in the photograph below. 3.8 The site is currently vacant but was formerly the site of the Butley Middle School. The former school is shown on the inset image below: (See attached document) 3.9 This is important because the Site Sustainability Assessment which the District Council undertook for this site wrongly assessed the site as "not having been previously developed", being "greenfield" and "currently in agricultural use". 3.10 The aerial image below, which dates from around 2007 shows the site as it was then - the red edged area is the current extent of the hard standing and playground remaining from the former school. 3.11 The site is located in the AONB but this is not a barrier to allocation for housing. 3.12 There are no planning or environmental designations preventing development in principle and it is outside of the Environment Agency flood zones 2 and 3, so is not at risk of flooding. 3.13 Butley is linked to , Woodbridge and Ipswich via the no. 71/72 bus route (with the small number of services shown on the timetable in Appendix 2) and the Coastal Accessible Transport Service operating a Dial -aride service to nearby villages and towns. 3.14 The site is less than a 400m / 5 minute walk from the site to the bus stops at the Butley Oyster Public House via the pedestrian foot path opposite the site entrance. 3.15 The site's northern, western and southern boundaries benefit from an established hedge and tree boundary which can be enhanced to improve the sites ecology and to minimise any visual impact of development. 3.16 To the north and west of the site are modern two storey detached and semidetached homes. To the south and west is agricultural land. In views from the west and south any development will be seen in the context of existing modern housing development. 3.17 The site is vacant and immediately available for development with a landowner who is willing to develop it and a supportive Parish Council willing to engage positively in the development of this site.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5715 - 3055 - Butley - None 5715 Support Woodbridge Housing Market Area Butley

4.0 Site Constraints and Opportunities 4.1 Allocation of this site would help to bring forward a proposal for the re -use of the former Middle School site. This is an aspiration of both the landowner and the Parish Council. 4.2 The site has a good access with good visibility and provides good visibility onto Church Road. 4.3 There are no planning or environmental designations on the site which prevent development in principle. 4.4 The District Council proposes extending the settlement boundary to encompass our client's house. This will improve the already good relationship this site has with the settlement boundary for Butley. 4.5 The existing settlement boundary for Butley is tightly defined around the existing settlement providing little, if any, opportunity for infill housing development in the future. 4.6 The site has been previously developed having been the site of the former Butley Middle School. However as shown in the aerial photos above it is now mostly domestic garden. Development of this site would not involve the loss of agricultural land. 4.7 The size and orientation of the site provides sufficient land for development to meet both the needs of the village and that of the landowner. 4.8 The affordable housing which the Parish Council wishes to see could be provided to the east of the site and related to the properties fronting Church Road whilst the market properties could be sited to the west of the site. 4.9 The village pub has recently closed and while waiting for it to reopen the community have arranged a 'pop up pub' in the village hall and note that increased patronage of these village initiatives through a small increase in the population of the village is what is needed.

5.0 Proposed Use and Assessment of Development Potential 5.1 Reflecting the requirements of the NPPF we have considered whether the site is deliverable and developable. 5.2 The suggested allocation site is unconstrained and immediately available and is well related to the suggested settlement boundary. This was recognised in the Council's SHLAA assessment of the site which found it suitable for development. 5.3 The site is proposed for residential development. It is approximately 0.9ha and whilst this means it could provide for a total of around 15 dwellings based on average housing densities, it is likely that a figure of 12 might better reflect local development density. 5.4 The site is large enough to provide flexibility on the housing density and landscaping necessary to reflect community needs and landscape character in the AONB. 5.5 The site is well placed in the village being well related to the settlement boundary and village facilities. It is notable that opportunities for infill development within the settlement boundary are very limited and the existing and proposed settlement boundary is drawn tightly around the existing built form of the village. 5.6 As the Core Strategy recognizes in such circumstances; 'an allocation will be necessary' to deliver a proportionate housing supply in Butley for the plan period. 5.7 The development would relate well to the suggested extension to the settlement boundary shown in Butley Map 2. Our client's land ownership is set out on the enclosed plans. 5.8 Butley is a local service centre with a tightly drawn settlement boundary where the Core Strategy states that "allocations will be necessary". 5.9 Delivery of the site is considered achievable within 5 years. But could be phased across the local plan stages to meet the needs of the village and the Parish Council who are supportive of an allocation. 5.10 Having attended a recent Parish Council meeting we can confirm that the Parish Council are supportive of an allocation on our client's site and were disappointed that despite a suggested allocation of 10 dwellings for their village the Issues and Options consultation document gave a residual requirement of zero. 5.11 The Parish Council told us that new housing development in Butley would help deliver a range of new housing to meet local needs, support local infrastructure and provide site specific benefits. 5.12 They explained that an earlier attempt to develop the site for affordable housing had failed because it was not viable and they understood that a proportion of market housing could make the development viable and bring forward the affordable housing they would like to see on this site.

6.0 Answers to Consultation Questions 6.1 The following section provides answers to relevant questions in the Issues and Options consultation document. Q1. Do you have any thoughts on the approach the Council has followed? Is there an alternative approach that you think should be considered for the more detailed distribution of housing in the Market Towns and Key and Local Service Centres set out in the Core Strategy and why? 6.2 Page 14 of the Issues and Options consultation document states that 'Approach 1' was "rejected when the broad scale and distribution of housing was adopted through the Core Strategy". It also states that 'Approach 2' is "the one which has been used" in the Core Strategy and the Issues and Options documents "reflects this approach". 6.3 The Core Strategy was adopted in July 2013 and post -dated the National Planning Policy Framework (the Framework). However subsequent National Planning Practice Guidance (the PPG) has been issued which 'Approach 2' does not conform to. 6.4 Specifically the PPG states: 6.5 "It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability, and the role of housing in supporting the broader sustainability of villages and smaller settlements. This is clearly set out in the National Planning Policy Framework, in the core planning principles, the section on supporting a prosperous rural economy and the section on housing. 6.6 A thriving rural community in a living, working countryside depends, in part, on retaining local services and

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5715 - 3055 - Butley - None 5715 Support Woodbridge Housing Market Area Butley

community facilities such as schools, local shops, cultural venues, public houses and places of worship. Rural housing is essential to ensure viable use of these local facilities. 6.7 Assessing housing need and allocating sites should be considered at a strategic level and through the Local Plan and/or neighbourhood plan process. However all settlements can play a role in delivering sustainable development in rural areas and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided unless their use can be supported by robust evidence." 6.8 Approach 2 leads to many Key and Local Service Centres having a residual housing requirement of zero. This is the case in Butley despite, we understand, clear local support. 6.9 The National Planning Policy Framework recognises the need to support rural communities with sustainable levels of housing growth which in turn promote the retention and development of community facilities. 6.10 For villages to sustain themselves for the lifetime of the plan period to 2027 and to 2031 after the Core Strategy review it is important for some land to be allocated in the plan. 6.11 Butley is a defined as a Local Service Centre in the Core Strategy which means it has a range of local facilities and will be expected to accommodate new housing development that is consistent with the scale and character. 6.12 It goes on to say that in order to establish "a 15 year land supply [...] allocations will be necessary. Such allocations will have the prime purpose of achieving housing to meet local needs, an objective supported by many communities in the district. They will be restricted to those Key and Local ervice Centres where: local housing need has been demonstrated; and there is community support." 6.13 The Issues and Options consultation document includes a suggested allocation of 10 dwellings. After accounting for zero completions the residual requirement has been reduced to zero dwellings with no explanation. This is despite, we understand, clear support from the Parish Council. 6.14 The purpose of making provision for small scale development in Butley is to ensure that local services can be sustained economically and that people wishing to live in the area have the opportunity to do so. These are both key issues supported by the Parish Counci l.

Q2. Does the suggested amount of new housing to be provided in your village/town sound about right? If not, why not and what is an appropriate amount? 6.15 As set out above in order to be in conformity with the PPG it would be necessary for Butley to be allocated an amount of housing to allow for planned housing development within the plan period to 2027 and to 2031 after the Core Strategy review rather than be left with a blanket zero contrary to local support for an allocation. 6.16 The Issues and Options document at its paragraph 3.5 states: "It is essential that the Council provides over and above the minimum amount of land needed to meet the target as this will provide flexibility and choice for future residents, developers and other stakeholders. Having a variety of sites also promotes a flexible approach which will help to overcome any site specific issues that may arise over the plan period. Over allocating land for development also enables the Council to clearly demonstrate that sufficient land is available and can come forward throughout the entirety of the plan period." 6.17 It is not clear which plan period is referred to; 2027 or 2031 (as a result of the Core Strategy review later this year). A residual allocation of zero for Butley will not 'provide flexibility and choice for future residents' of that village. 6.18 In the absence of robust evidence to the contrary Butley should be provided with a residual allocation that allows for future expansion of the village because its existing settlement boundary is drawn tightly and will not allow for organic growth.

Q5. Thinking about your own community, the people who live there, the people who would want to live there but maybe can't because there is nowhere suitable - what type and mix of housing do you think is most needed to meet your community's needs? Do you have any evidence which would support your comments and which could help support this Local Plan document as it progresses? An example might be an up to date parish plan. 6.19 It is understood from the District Council housing team that there is a consistent need for 1 and 2 bed affordable housing across the District including Butley. Affordable housing is an issue which the Parish Council have told us is important to them. 6.20 Discussions with the Parish Council have shown they understand the need to provide a mix of affordable and market homes on the site in order to make it viable. 6.21 As set out above the PPG refers to paragraphs 17, 28 and 54 of the NPPF in stating that "It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability, and the role of housing in supporting the broader sustainability of villages and smaller settlements. This is clearly set out in the National Planning Policy Framework, in the core planning principles, the section on supporting a prosperous rural economy and the section on housing". 6.22 Government therefore expects local plans to provide for the sustainable expansion of villages and not to prevent this by not allocating land through plan making.

Q6. Do you think allocated sites should be included within any updated physical limits boundary or should remain outside of the physical limits boundary but denoted by a specific housing allocation designation? (Once allocated sites are built out, the opportunity would exist for the physical limits boundary to be redrawn next time they come up for review) 6.23 In order to provide for flexibility at this stage allocated sites should not be included in updated physical limits now as this will constrain the design process. As the District Council recognises there is an opportunity through detailed and careful design to reflect the final built form and layout of development will exist in future reviews of the plan. 7.0 Conclusion

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5715 - 3055 - Butley - None 5715 Support Woodbridge Housing Market Area Butley

7.1 We are pleased to continue to promote this site to the District Council for allocation to provide Butley with the opportunity to expand its supply of rural housing sustainably and in a planned way over the plan period. 7.2 Allocation of land in Butley is important because the current settlement boundary is drawn tightly but there are no other sites available and few if any opportunities for windfall infill development. 7.3 If Butley is left with no allocation there may well be no realistic opportunities during the plan period for sustainable rural housing growth in the village. This is not what the community wants. 7.4 The village pub has recently closed and its reopening is not secure. The community have arranged a 'pop up pub' in the village hall and note that increased patronage of these village initiatives through a small increase in the population of the village is what is needed. 7.5 An allocation on Site 596 would increase local housing supply and choice, provide homes for people wishing to stay in Butley who cannot afford to do so and to support local facilities. This is what the Parish Council have also said they want to see from this process. 7.6 The site is immediately available and deliverable and has the support of the Parish Council for its development. 7.7 This can be phased to release development on a time scale to meet local needs and to reflect the stages of the Local Plan. Summary: Allocation of this site would help to bring forward a proposal for the re-use of the former Middle School. The site has good access with good visibility and provides good visibility onto Church Road. There are no planning or environmental designations on the site which prevent development in principle. The District Council proposes extending the settlement boundary. This will improve the good relationship this site has with the settlement boundary. The existing settlement boundary is tightly defined around the existing settlement providing little opportunity for infill housing development. Development of this site would not involve the loss of agricultural land.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments: E232 C1 Rep02.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6184 - 483 - Butley - None 6184 Comment Woodbridge Housing Market Area Butley

Respondent: Anglian Water (Sue Bull) [483] Agent: N/A

Full Text: Thank you for the opportunity to comment on the Issues & Options Consultation document (December 2014).

Neighbourhood Plans Whilst Anglian Water (AW) has no comment to make on the neighbourhood area designation stage of a Neighbourhood Plan we are pleased to be consulted on the plans once they progress to draft plan stage. We are currently considering the Leiston Neighbourhood Plan and will make comment within the consultation period.

Felixstowe Area Action Plan Anglian Water are submitting representation on this consultation.

Site Allocations

Please find attached RAG spreadsheet summarising Anglian Water's comment on each site. It is important to note that this assessment does not take account of the cumulative impact of all the sites on the capacity of the Water Recycling Centres; the sites are assessed individually.

Asset Encroachment

Please note Sites 12ucl,13ucl,350,350b,408a,583a,672a,776i and 776L and WE04 are within the 400m consultation zone of the Water Recycling Centre (WRC) (formally referred to as Sewage or Wastewater Treatment Works). Initial assessment has indicated that there is an odour risk. Further discussion with Anglian Water is needed. Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage.

If a landowner or potential developer wishes to pursue an enquiry for development it is recommended they contact AW at the earliest opportunity to discuss the level of risk and the requirement for an odour risk assessment to be carried out.

Anglian Water does not want to thwart development or apply a blanket embargo on all development within 400 metres of our WRC, however we must balance this with protecting our new and existing customers from the risk of nuisance/loss of amenity whilst allowing us to provide the essential sewage treatment service to our customers and for this reason we take a risk based approach.

Similarly, development should be located a minimum of 15 metres from Pumping Stations to avoid the risk of nuisance/loss of amenity . With development proposals close to a foul pumping station,(site 693), it may be the layout of the site can be adjusted so as not to encroach on the 15 metre protection zone. The landowner/developer is advised to contact AW at the earliest opportunity to discuss.

Where there are sewers crossing the site, the site layout should be designed to take these into account; this existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The sewers should be located in highways or public open space. If it is not possible to accommodate the existing sewers within the design then diversion may be possible under section 185 of the Water Industry Act 1991 or entering into a build over/near agreement may be considered.

Details of Anglian Water encroachment policy can be viewed at: http://www.anglianwater.co.uk/developers/encroachment.aspx

Sewerage Network

The foul (or used water) flows from future growth will have an impact on the existing foul sewerage network. As outlined within the attached RAG sheet, upgrades to the network is likely to be required for a number of developments . The foul infrastructure requirements will be dependant on the location, size and phasing of the development.

We would want to see policy to ensure necessary infrastructure to serve allocations is planned and implemented before development proceeds (and dwellings occupied). To ensure this is carried through to a tactical level, we would at planning consent stage request the use of appropriate conditions to ensure infrastructure is in place before development is connected to the public sewerage network.

Surface Water and Flood Risk

Appropriate management of flood risk and the consideration of climate change is critical for long term resilience.

Whilst fluvial flooding is a significant constraint to the location of development, other forms of flooding such as surface water should be a consideration.

All developments should seek to reduce flood risk and incorporate Sustainable Drainage Systems (SuDS). We would

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6184 - 483 - Butley - None 6184 Comment Woodbridge Housing Market Area Butley

wish to see in policy that all developments should adhere to the surface water management hierarchy outlined in Part H of Building Regulations with disposal to a surface water sewer seen as a last resort. Under no circumstances will surface water be permitted to discharge to the public foul sewerage network and no new flow will be permitted to discharge to the combined network. We would want the document to clearly state that a surface water drainage solution will need to be identified and implemented prior to the construction of hard standing areas. The solution would need to be agreed with all stakeholders.

Engagement with developers

Anglian Water offers a pre planning service which includes a capacity check to determine the impact of sewerage from a proposed development. We will also work with the developer or land owner during this process to develop foul and surface water (where applicable) drainage solutions which will not cause a detriment to our existing or future customer. We would encourage the prospective developer to contact us at the earliest convenience to discuss drainage proposals to serve the development. Details regarding this service can be found at http://www.anglianwater.co.uk/developers/pre- planning-service-.aspx

Anglian Water are keep to engage with Suffolk Coastal District Council on Local Plan consultations and on individual planning applications. Summary: 596: Significant off-site sewerage required to connect into nearest network - may not be viable

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: 5002_Suffolk_Coastal_allocation_-_sites_consultation_sheet_(RSP)_-_Jan-15(1).pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6387 - 2655 - - None 6387 Comment Woodbridge Housing Market Area Campsea Ashe

Respondent: Member of Parliament (MP) (Rt. Hon Therese Agent: N/A Coffey MP) [2655]

Full Text: Thank you for the opportunity to comment on the site allocations and area specific policies for the local plan. I think it is a welcome step to encourage all the public to participate in this early stage of the process. I only usually intervene on strategic issues and policies on planning.

While I have detailed my comments on some individual areas below, I have three particular issues to discuss - i) the imbalance of housing allocations around the area with the vast amount of development inserted east of the A12, the side of Suffolk that has the AONB and nearly all the SSSls; iii) the absence of nominated sites in and Leiston; iii) building on main roads and the absence of infrastructure, particularly roads, for major and cumulative developments with the risk of significant congestion and longer journey times as well as community facilities.

Allocation of housing across the district

The vast majority of the proposed housing lies east of the A12 and to the south of the district. This continues to move the centre of gravity south east which runs the risk of excluding significant parts of our area of new housing for local people and also the lack of infrastructure (either new or upgraded). There appears to be a surprising disparity between settlements on where is deemed appropriate for further development and where is not. For example, no further housing is recommended for while , lower down the settlement hierarchy, has been recommended for more housing despite having just had an application for 26 new homes approved (higher than the Local Plan allocation of 5-15). Separately, has been recommended for further housing after a significant amount already built and under construction. I do not object specifically to that but will make the point later about infrastructure. There is little difference between Wickham Market, Saxmundham and Framlingham apart from the railway station. It has been suggested that Wickham Market has already had some housing so need not have any more and Framlingham has been allocated a small amount. That is in contrast to Leiston which has been allocated up to 500 houses, though with no additional infrastructure. The experience elsewhere does not bear that out. While it makes sense to allow for housing in villages and parishes as well as market towns but in a sensible proportion that does not dwarf existing villages. Therefore, I suggest that villages that have already had housing approved in the last two years should not have further sites specifically designated but allow for windfall, within the existing village envelope and not on main roads (like the A12 in Yoxford or A1120 in or the High Road in the Trimleys or the A144). It also should be on the same side of the main road as the local facilities - which would rule out nominated sites specifically in Yoxford and Woodbridge. We should not repeat the mistakes of the past. Another guiding principle should be that new housing is as close as possible to existing facilities. There is development planned on the opposite side of the main road to key facilities in some areas, which would significantly shift the centre of gravity and mean people having to cross busy roads to get to the centre. Shifting the centre of gravity of further development away from shops and facilities in towns, as may be the case in Saxmundham, is a retrograde step for enhancing the sense of community. The council must counter the risk of our small market towns becoming car-based, seeking shopping, leisure and sporting activities away from the town.

I strongly support the protection of green gaps, acting as strategic barriers between settlements.

There is an absence of nominated sites in Leiston and Framlingham. It has been suggested that this is due to emerging town plans but they should not have been absented from this consultation.

Finally, the absence of infrastructure. There is already huge pressure on various parts of the A12 and there is no indication of what infrastructure additions or upgrades are being proposed to accommodate such significant increases. In more specific terms,

i) Martlesham area with 2000 houses, adding to the increasing retail presence on the Martlesham Heath industrial estate. The latter is already leading to significant increases in traffic, coupled with further housing already under construction in Martlesham. Significant improvements need to be made to the A12 at several junctions. ii) Woods Lane roundabout and the A1152. There are already at least 15,000 traffic movements per day at the Melton railway crossing (sourced from Network Rail three years ago). Without substantial improvements to roads here, the additional housing suggested in Melton, and will bring even greater traffic movement pressure on the round about, the railway crossing and the traffic lights on the junction of the A1152/B1438. iii) Given the council's full support for the 4 villages bypass, it is surprising that no housing has been considered for this area as bypasses usually lead to significant increases in housing. Meanwhile, up to 500 houses are being proposed for Leisten but with no road improvements and no support for the potential D2 route being suggested in conjunction with C. iv) In Saxmundham, a substantial number of new housing has already been built. While there has been minor modification of the traffic lights in the centre of the town, there has been no improvements planned to help traffic in and through the town. v) Woodbridge site at the football ground -addressing the congestion and the replacement of sporting facilities within the town area. vi) Local community infrastructure will need significant improvement - pace Rendlesham, Saxmundham, Leisten, the Trimleys and the new development at Martlesham. On local sites, I have commented by exception and no comment is not a sign of endorsement.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6387 - 2655 - Campsea Ashe - None 6387 Comment Woodbridge Housing Market Area Campsea Ashe

Woodbridge Housing Area

Campsea Ashe Site 557 is a very unusual place to add more housing especially if there is going to be work on the track for Sizewell C. I agree with 745 and 990 being unsuitable SHLAA sites. They are far too large and inappropriate. Eyke Agree that 991 and OPP7 are unsuitable sites. 991 looks to double size of village whereas Opp7 suggests substantial new housing along A-road which is unsuitable. Agree that 825 is unsuitable - losing a significant amount of green field opposite school. Orford Agree that 494/484 & 976 is unsuitable. Surprised some sites proposed with sea levels. Tunstall Disagree that 786, 597 and 730 would all be suitable as a whole as seems to double the size of the village which is unnecessary over-development. Wickham Market Would support 7761 and 776i as it is a significant market town. Woodbridge Agree that sites 937 and 453 are unsuitable due to being west of the A12. 839,750,750a, 974 unsuitable due to pressure on roundabout.

Framlingham Housing Area

Bramfield Agree that 493 is unsuitable as it is too far away from the centre. Peasenhall Agree with 832 being unsuitable as outside the envelope and inappropriate. Wenhaston The village has already had a significant amount of development therefore I don't see the need for any further sites to be added. Strongly oppose any greenfield sites. Yoxford Strongly oppose accepted SHLAA sites 642b and 794. They are both opposite or adjacent to existing housing but involves crossing a main road to get to existing village facilities.

Saxmundham Housing Area

Aldeburgh Agree with unsuitable SHLAA sites in first map. Should continue to look for windfall sites. Strongly agree that 768 shouldn't be brought forward. Agree that 411b and 411c should not be brought forward. They would dwarf the village and would constitute overdevelopment. Disagree with 4UCB being brought forward as junction already very difficult and wouldn't cope. Agree that 378 and 967 are unsuitable as are considerably out of the village. Strongly disagree with 794 as it is too close to the main road and a strategic error. Agree that 713 is unsuitable as is too far away from the village centre. Agree that 506 which would dwarf the village, 579 which would significantly reduce the gap to and 971 which would bring an unwarranted urban feel to that side of the village are unsuitable. 625 would put particular pressure on A12 which would require substantial highway change if it were to go ahead. Saxmundham Strongly agree that the non-hatched sites are unsuitable. Of the sites that have been endorsed 1006 and 1009, there is a risk of this development being too far away from the high street shift the centre of gravity. If this was to go ahead then there should be consideration for a relief road from the North entrance to the B1119. Snape Agree that 758 is unsuitable as too far out of the centre of the village. Agree with unsuitability of sites. Strongly oppose any development on 327 and 935.

Felixstowe Housing Area/Area Action Plan

Waldrlngfield Support 961 being a SHLAA unsuitable site. We need to protect this as a local gap. Most sites are too big and too far away from village centre. Kirton It is my understanding the Road site has been backed in a local consultation session run by the Parish Council. Concerned about over development if all the other sites were approved. Agree that 920 and 889 are completely unsuitable. Trimley St Mary Concern that the current road network could cope with significant development on 383F. Agree with unsuitability of 383,c,d,e & 451e as too far away from centre. Summary: Campsea Ashe Site 557 is a very unusual place to add more housing especially if there is going to be work on the track for Sizewell C. I agree with 745 and 990 being unsuitable SHLAA sites. They are far too large and inappropriate.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6206 - 3371 - - None 6206 Comment Woodbridge Housing Market Area Charsfield

Respondent: Charsfield Parish Council (Miss Sally Loader) [3371] Agent: N/A

Full Text: Please find Charsfield Parish Councils comments below regards the site allocations and area specific policies document.

We accept the recommendations as per the details set out. The only acceptable SHLA site being no 520 which has outline planning permission already. We do not accept any of the others agreeing with the reasons in the document. The suggested physical boundaries are acceptable. Summary: Please find Charsfield Parish Councils comments below regards the site allocations and area specific policies document.

We accept the recommendations as per the details set out. The only acceptable SHLA site being no 520 which has outline planning permission already. We do not accept any of the others agreeing with the reasons in the document. The suggested physical boundaries are acceptable.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6190 - 483 - - None 6190 Comment Woodbridge Housing Market Area Chillesford

Respondent: Anglian Water (Sue Bull) [483] Agent: N/A

Full Text: Thank you for the opportunity to comment on the Issues & Options Consultation document (December 2014).

Neighbourhood Plans Whilst Anglian Water (AW) has no comment to make on the neighbourhood area designation stage of a Neighbourhood Plan we are pleased to be consulted on the plans once they progress to draft plan stage. We are currently considering the Leiston Neighbourhood Plan and will make comment within the consultation period.

Felixstowe Area Action Plan Anglian Water are submitting representation on this consultation.

Site Allocations

Please find attached RAG spreadsheet summarising Anglian Water's comment on each site. It is important to note that this assessment does not take account of the cumulative impact of all the sites on the capacity of the Water Recycling Centres; the sites are assessed individually.

Asset Encroachment

Please note Sites 12ucl,13ucl,350,350b,408a,583a,672a,776i and 776L and WE04 are within the 400m consultation zone of the Water Recycling Centre (WRC) (formally referred to as Sewage or Wastewater Treatment Works). Initial assessment has indicated that there is an odour risk. Further discussion with Anglian Water is needed. Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage.

If a landowner or potential developer wishes to pursue an enquiry for development it is recommended they contact AW at the earliest opportunity to discuss the level of risk and the requirement for an odour risk assessment to be carried out.

Anglian Water does not want to thwart development or apply a blanket embargo on all development within 400 metres of our WRC, however we must balance this with protecting our new and existing customers from the risk of nuisance/loss of amenity whilst allowing us to provide the essential sewage treatment service to our customers and for this reason we take a risk based approach.

Similarly, development should be located a minimum of 15 metres from Pumping Stations to avoid the risk of nuisance/loss of amenity . With development proposals close to a foul pumping station,(site 693), it may be the layout of the site can be adjusted so as not to encroach on the 15 metre protection zone. The landowner/developer is advised to contact AW at the earliest opportunity to discuss.

Where there are sewers crossing the site, the site layout should be designed to take these into account; this existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The sewers should be located in highways or public open space. If it is not possible to accommodate the existing sewers within the design then diversion may be possible under section 185 of the Water Industry Act 1991 or entering into a build over/near agreement may be considered.

Details of Anglian Water encroachment policy can be viewed at: http://www.anglianwater.co.uk/developers/encroachment.aspx

Sewerage Network

The foul (or used water) flows from future growth will have an impact on the existing foul sewerage network. As outlined within the attached RAG sheet, upgrades to the network is likely to be required for a number of developments . The foul infrastructure requirements will be dependant on the location, size and phasing of the development.

We would want to see policy to ensure necessary infrastructure to serve allocations is planned and implemented before development proceeds (and dwellings occupied). To ensure this is carried through to a tactical level, we would at planning consent stage request the use of appropriate conditions to ensure infrastructure is in place before development is connected to the public sewerage network.

Surface Water and Flood Risk

Appropriate management of flood risk and the consideration of climate change is critical for long term resilience.

Whilst fluvial flooding is a significant constraint to the location of development, other forms of flooding such as surface water should be a consideration.

All developments should seek to reduce flood risk and incorporate Sustainable Drainage Systems (SuDS). We would

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6190 - 483 - Chillesford - None 6190 Comment Woodbridge Housing Market Area Chillesford

wish to see in policy that all developments should adhere to the surface water management hierarchy outlined in Part H of Building Regulations with disposal to a surface water sewer seen as a last resort. Under no circumstances will surface water be permitted to discharge to the public foul sewerage network and no new flow will be permitted to discharge to the combined network. We would want the document to clearly state that a surface water drainage solution will need to be identified and implemented prior to the construction of hard standing areas. The solution would need to be agreed with all stakeholders.

Engagement with developers

Anglian Water offers a pre planning service which includes a capacity check to determine the impact of sewerage from a proposed development. We will also work with the developer or land owner during this process to develop foul and surface water (where applicable) drainage solutions which will not cause a detriment to our existing or future customer. We would encourage the prospective developer to contact us at the earliest convenience to discuss drainage proposals to serve the development. Details regarding this service can be found at http://www.anglianwater.co.uk/developers/pre- planning-service-.aspx

Anglian Water are keep to engage with Suffolk Coastal District Council on Local Plan consultations and on individual planning applications. Summary: 773a: Small treatment plant, enhanced process may be required to treat FW. Significant off-site sewerage required to connect into nearest network - may not be viable

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: 5002_Suffolk_Coastal_allocation_-_sites_consultation_sheet_(RSP)_-_Jan-15(1).pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6304 - 3381 - Chillesford - None 6304 Comment Woodbridge Housing Market Area Chillesford

Respondent: Chillesford Parish Council (Mr Peter McGinity) Agent: N/A [3381]

Full Text: I am writing in response to the formal consultation on the issues and options consultation document. I apologise that these comments are slightly late.

The views of the Parish meeting in Chillesford remain broadly the same as their views on the informal consultation which I emailed to you on 8 October 2014.

The village supports the slight alteration to the village envelope to take in Hertford Place. It also agrees that the only potential development site is that adjacent to New House (773a) which the village proposes should be reserved for affordable housing. This would also ensure that the houses will be in permanent occupation and not used as second homes or holiday lets.

We also pointed out that there are now 3 new homes in the village with the completion of the new homes at Meadow View in the centre of the village. Also the Chillesford Lodge site (993) is now under construction following planning approval and listed building consent so it is misleading to note it as unsuitable for development.

The Parish meeting would like to see a children's play area in the village and are actively considering potential sites for such a facility. Summary: The village supports the slight alteration to the village envelope to take in Hertford Place. It also agrees that the only potential development site is that adjacent to New House (773a) which the village proposes should be reserved for affordable housing.

We also pointed out that there are now 3 new homes in the village with the completion of the new homes at Meadow View in the centre of the village.

The Parish meeting would like to see a children's play area in the village and are actively considering potential sites for such a facility.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6388 - 2655 - Eyke - None 6388 Comment Woodbridge Housing Market Area Eyke

Respondent: Member of Parliament (MP) (Rt. Hon Therese Agent: N/A Coffey MP) [2655]

Full Text: Thank you for the opportunity to comment on the site allocations and area specific policies for the local plan. I think it is a welcome step to encourage all the public to participate in this early stage of the process. I only usually intervene on strategic issues and policies on planning.

While I have detailed my comments on some individual areas below, I have three particular issues to discuss - i) the imbalance of housing allocations around the area with the vast amount of development inserted east of the A12, the side of Suffolk that has the AONB and nearly all the SSSls; iii) the absence of nominated sites in Framlingham and Leiston; iii) building on main roads and the absence of infrastructure, particularly roads, for major and cumulative developments with the risk of significant congestion and longer journey times as well as community facilities.

Allocation of housing across the district

The vast majority of the proposed housing lies east of the A12 and to the south of the district. This continues to move the centre of gravity south east which runs the risk of excluding significant parts of our area of new housing for local people and also the lack of infrastructure (either new or upgraded). There appears to be a surprising disparity between settlements on where is deemed appropriate for further development and where is not. For example, no further housing is recommended for Wickham Market while Wenhaston, lower down the settlement hierarchy, has been recommended for more housing despite having just had an application for 26 new homes approved (higher than the Local Plan allocation of 5-15). Separately, Saxmundham has been recommended for further housing after a significant amount already built and under construction. I do not object specifically to that but will make the point later about infrastructure. There is little difference between Wickham Market, Saxmundham and Framlingham apart from the railway station. It has been suggested that Wickham Market has already had some housing so need not have any more and Framlingham has been allocated a small amount. That is in contrast to Leiston which has been allocated up to 500 houses, though with no additional infrastructure. The experience elsewhere does not bear that out. While it makes sense to allow for housing in villages and parishes as well as market towns but in a sensible proportion that does not dwarf existing villages. Therefore, I suggest that villages that have already had housing approved in the last two years should not have further sites specifically designated but allow for windfall, within the existing village envelope and not on main roads (like the A12 in Yoxford or A1120 in Peasenhall or the High Road in the Trimleys or the A144). It also should be on the same side of the main road as the local facilities - which would rule out nominated sites specifically in Yoxford and Woodbridge. We should not repeat the mistakes of the past. Another guiding principle should be that new housing is as close as possible to existing facilities. There is development planned on the opposite side of the main road to key facilities in some areas, which would significantly shift the centre of gravity and mean people having to cross busy roads to get to the centre. Shifting the centre of gravity of further development away from shops and facilities in towns, as may be the case in Saxmundham, is a retrograde step for enhancing the sense of community. The council must counter the risk of our small market towns becoming car-based, seeking shopping, leisure and sporting activities away from the town.

I strongly support the protection of green gaps, acting as strategic barriers between settlements.

There is an absence of nominated sites in Leiston and Framlingham. It has been suggested that this is due to emerging town plans but they should not have been absented from this consultation.

Finally, the absence of infrastructure. There is already huge pressure on various parts of the A12 and there is no indication of what infrastructure additions or upgrades are being proposed to accommodate such significant increases. In more specific terms,

i) Martlesham area with 2000 houses, adding to the increasing retail presence on the Martlesham Heath industrial estate. The latter is already leading to significant increases in traffic, coupled with further housing already under construction in Martlesham. Significant improvements need to be made to the A12 at several junctions. ii) Woods Lane roundabout and the A1152. There are already at least 15,000 traffic movements per day at the Melton railway crossing (sourced from Network Rail three years ago). Without substantial improvements to roads here, the additional housing suggested in Melton, Eyke and Rendlesham will bring even greater traffic movement pressure on the round about, the railway crossing and the traffic lights on the junction of the A1152/B1438. iii) Given the council's full support for the 4 villages bypass, it is surprising that no housing has been considered for this area as bypasses usually lead to significant increases in housing. Meanwhile, up to 500 houses are being proposed for Leisten but with no road improvements and no support for the potential D2 route being suggested in conjunction with Sizewell C. iv) In Saxmundham, a substantial number of new housing has already been built. While there has been minor modification of the traffic lights in the centre of the town, there has been no improvements planned to help traffic in and through the town. v) Woodbridge site at the football ground -addressing the congestion and the replacement of sporting facilities within the town area. vi) Local community infrastructure will need significant improvement - pace Rendlesham, Saxmundham, Leisten, the Trimleys and the new development at Martlesham. On local sites, I have commented by exception and no comment is not a sign of endorsement.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6388 - 2655 - Eyke - None 6388 Comment Woodbridge Housing Market Area Eyke

Woodbridge Housing Area

Campsea Ashe Site 557 is a very unusual place to add more housing especially if there is going to be work on the track for Sizewell C. I agree with 745 and 990 being unsuitable SHLAA sites. They are far too large and inappropriate. Eyke Agree that 991 and OPP7 are unsuitable sites. 991 looks to double size of village whereas Opp7 suggests substantial new housing along A-road which is unsuitable. Hollesley Agree that 825 is unsuitable - losing a significant amount of green field opposite school. Orford Agree that 494/484 & 976 is unsuitable. Surprised some sites proposed with sea levels. Tunstall Disagree that 786, 597 and 730 would all be suitable as a whole as seems to double the size of the village which is unnecessary over-development. Wickham Market Would support 7761 and 776i as it is a significant market town. Woodbridge Agree that sites 937 and 453 are unsuitable due to being west of the A12. 839,750,750a, 974 unsuitable due to pressure on roundabout.

Framlingham Housing Area

Bramfield Agree that 493 is unsuitable as it is too far away from the centre. Peasenhall Agree with 832 being unsuitable as outside the envelope and inappropriate. Wenhaston The village has already had a significant amount of development therefore I don't see the need for any further sites to be added. Strongly oppose any greenfield sites. Yoxford Strongly oppose accepted SHLAA sites 642b and 794. They are both opposite or adjacent to existing housing but involves crossing a main road to get to existing village facilities.

Saxmundham Housing Area

Aldeburgh Agree with unsuitable SHLAA sites in first map. Should continue to look for windfall sites. Strongly agree that 768 shouldn't be brought forward. Benhall Agree that 411b and 411c should not be brought forward. They would dwarf the village and would constitute overdevelopment. Blythburgh Disagree with 4UCB being brought forward as junction already very difficult and wouldn't cope. Darsham Agree that 378 and 967 are unsuitable as are considerably out of the village. Strongly disagree with 794 as it is too close to the main road and a strategic error. Dunwich Agree that 713 is unsuitable as is too far away from the village centre. Knodishall Agree that 506 which would dwarf the village, 579 which would significantly reduce the gap to Aldringham and 971 which would bring an unwarranted urban feel to that side of the village are unsuitable. Little Glemham 625 would put particular pressure on A12 which would require substantial highway change if it were to go ahead. Saxmundham Strongly agree that the non-hatched sites are unsuitable. Of the sites that have been endorsed 1006 and 1009, there is a risk of this development being too far away from the high street shift the centre of gravity. If this was to go ahead then there should be consideration for a relief road from the North entrance to the B1119. Snape Agree that 758 is unsuitable as too far out of the centre of the village. Westleton Agree with unsuitability of sites. Strongly oppose any development on 327 and 935.

Felixstowe Housing Area/Area Action Plan

Waldrlngfield Support 961 being a SHLAA unsuitable site. We need to protect this as a local gap. Bucklesham Most sites are too big and too far away from village centre. Kirton It is my understanding the Falkenham Road site has been backed in a local consultation session run by the Parish Council. Concerned about over development if all the other sites were approved. Trimley St Martin Agree that 920 and 889 are completely unsuitable. Trimley St Mary Concern that the current road network could cope with significant development on 383F. Agree with unsuitability of 383,c,d,e & 451e as too far away from centre. Summary: Eyke Agree that 991 and OPP7 are unsuitable sites. 991 looks to double size of village whereas Opp7 suggests substantial new housing along A-road which is unsuitable.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5480 - 3100 - - None 5480 Comment Woodbridge Housing Market Area Hacheston

Respondent: Hacheston Parish Council (Mrs Deborah Ottway) Agent: N/A [3100]

Full Text: Following the meeting of Hacheston Parish Council on Monday 5th January I can report that the council wishes to comment that the number of residual houses (10) suggested for Hacheston was too great to fit within the village envelope; however, if a suitable site for development outside of the envelope was proposed, the council would give this due consideration. Summary: Following the meeting of Hacheston Parish Council on Monday 5th January I can report that the council wishes to comment that the number of residual houses (10) suggested for Hacheston was too great to fit within the village envelope; however, if a suitable site for development outside of the envelope was proposed, the council would give this due consideration.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5524 - 3116 - Hollesley - None 5524 Support Woodbridge Housing Market Area Hollesley

Respondent: Mr Nigel Squirrell [3116] Agent: N/A

Full Text: Further to my telephone conversation with your colleague this morning, to discuss the Local Plan for the village of Hollesley, with reference to site allocation and area specific policies document currently prepared for consideration. We understand from our conversations the Local Plan are open to consider additional suitable sites in the village. We are pleased to present our Brown Field Residential Development site in part of the grounds of Glebe House Retirement Home for inclusion within the village Development plan. Please find enclosed our development proposal and preliminary site plan ref: SK 04 prepared by Wincer Kievnaar Architects detailing plot sizes and locations. We would welcome the opportunity to discuss our proposal with you in more detail at your convenience, if in the meantime you require any further information to consider our proposal further, please do not hesitate to contact me. Summary: We understand from our conversations the Local Plan are open to consider additional suitable sites in the village. We are pleased to present our Brown Field Residential Development site in part of the grounds of Glebe House Retirement Home for inclusion within the village Development plan. Please find enclosed our development proposal and preliminary site plan ref: SK 04 prepared by Wincer Kievnaar Architects detailing plot sizes and locations.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments: Development Proposal.pdf Physical Limits Map.pdf Site Plan.pdf Layout Plan_A3.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5532 - 2078 - Hollesley - None 5532 Object Woodbridge Housing Market Area Hollesley

Respondent: Mrs S J Wade [2078] Agent: N/A

Full Text: I am writing in response to your invitation for people living in the SCDC area to express their views on future planning.

My comments are in relation to my home village only - Hollesley. In 2004 I moved from Woodbridge to Hollesley as I wanted to leave the town and live in this beautiful rural area and live a good quality of life in a close, village community. In the intervening 10 years I have seen Hollesley rapidly grow in terms of number of dwellings and consequent number of people, vehicles on our local roads etc. I'm of the opinion that it's now time to stop 'developing' us.

The 'Issues and Options Consultation' flyer I am in possession of asks for views on how their community 'might grow and develop up to 2027'. The premise of this is that everyone wants their community to 'grow and develop'. People have very different tastes when it comes to lifestyle. Many people like to live in towns and cities with all the attendant facilities on offer - shops, good public transport, theatres, the hustle and bustle of urban/suburban life. Other people like a simple, quieter life in a simple rural environment. Why the 'one size fits all' approach?

The definitions of a village and a town are vague - when does a village turn into a town? I don't know. I do know that, in my view, the Hollesley community needs to concentrate on cohesion and consolidation - not more growth. We have our school, shop, public house, church and a number of community groups - Hollesley is fine as it is.

I am sure that, in the great scheme of things, this letter will not have any impact at all on SCDC planning policy - the great political wheel will trundle on.

The council invited my views and I've given them. Summary: My comments are in relation to my home village only - Hollesley. In 2004 I moved from Woodbridge to Hollesley as I wanted to leave the town and live in this beautiful rural area and live a good quality of life in a close, village community. In the intervening 10 years I have seen Hollesley rapidly grow in terms of number of dwellings and consequent number of people, vehicles on our local roads etc. I'm of the opinion that it's now time to stop 'developing' us. The Hollesley community needs to concentrate on cohesion and consolidation - not more growth.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5959 - 3317 - Hollesley - None 5959 Object Woodbridge Housing Market Area Hollesley

Respondent: Hollesley Parish Council (Sally Loader) [3317] Agent: N/A

Full Text: Hollesley Parish Council response:- * no further developement required as hollesley has met its requirement * wants to leave physical limits boundary as it is * No public transport in the area Summary: Hollesley Parish Council response:- * no further developement required as hollesley has met its requirement * wants to leave physical limits boundary as it is * No public transport in the area

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6185 - 483 - Hollesley - None 6185 Comment Woodbridge Housing Market Area Hollesley

Respondent: Anglian Water (Sue Bull) [483] Agent: N/A

Full Text: Thank you for the opportunity to comment on the Issues & Options Consultation document (December 2014).

Neighbourhood Plans Whilst Anglian Water (AW) has no comment to make on the neighbourhood area designation stage of a Neighbourhood Plan we are pleased to be consulted on the plans once they progress to draft plan stage. We are currently considering the Leiston Neighbourhood Plan and will make comment within the consultation period.

Felixstowe Area Action Plan Anglian Water are submitting representation on this consultation.

Site Allocations

Please find attached RAG spreadsheet summarising Anglian Water's comment on each site. It is important to note that this assessment does not take account of the cumulative impact of all the sites on the capacity of the Water Recycling Centres; the sites are assessed individually.

Asset Encroachment

Please note Sites 12ucl,13ucl,350,350b,408a,583a,672a,776i and 776L and WE04 are within the 400m consultation zone of the Water Recycling Centre (WRC) (formally referred to as Sewage or Wastewater Treatment Works). Initial assessment has indicated that there is an odour risk. Further discussion with Anglian Water is needed. Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage.

If a landowner or potential developer wishes to pursue an enquiry for development it is recommended they contact AW at the earliest opportunity to discuss the level of risk and the requirement for an odour risk assessment to be carried out.

Anglian Water does not want to thwart development or apply a blanket embargo on all development within 400 metres of our WRC, however we must balance this with protecting our new and existing customers from the risk of nuisance/loss of amenity whilst allowing us to provide the essential sewage treatment service to our customers and for this reason we take a risk based approach.

Similarly, development should be located a minimum of 15 metres from Pumping Stations to avoid the risk of nuisance/loss of amenity . With development proposals close to a foul pumping station,(site 693), it may be the layout of the site can be adjusted so as not to encroach on the 15 metre protection zone. The landowner/developer is advised to contact AW at the earliest opportunity to discuss.

Where there are sewers crossing the site, the site layout should be designed to take these into account; this existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The sewers should be located in highways or public open space. If it is not possible to accommodate the existing sewers within the design then diversion may be possible under section 185 of the Water Industry Act 1991 or entering into a build over/near agreement may be considered.

Details of Anglian Water encroachment policy can be viewed at: http://www.anglianwater.co.uk/developers/encroachment.aspx

Sewerage Network

The foul (or used water) flows from future growth will have an impact on the existing foul sewerage network. As outlined within the attached RAG sheet, upgrades to the network is likely to be required for a number of developments . The foul infrastructure requirements will be dependant on the location, size and phasing of the development.

We would want to see policy to ensure necessary infrastructure to serve allocations is planned and implemented before development proceeds (and dwellings occupied). To ensure this is carried through to a tactical level, we would at planning consent stage request the use of appropriate conditions to ensure infrastructure is in place before development is connected to the public sewerage network.

Surface Water and Flood Risk

Appropriate management of flood risk and the consideration of climate change is critical for long term resilience.

Whilst fluvial flooding is a significant constraint to the location of development, other forms of flooding such as surface water should be a consideration.

All developments should seek to reduce flood risk and incorporate Sustainable Drainage Systems (SuDS). We would

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6185 - 483 - Hollesley - None 6185 Comment Woodbridge Housing Market Area Hollesley

wish to see in policy that all developments should adhere to the surface water management hierarchy outlined in Part H of Building Regulations with disposal to a surface water sewer seen as a last resort. Under no circumstances will surface water be permitted to discharge to the public foul sewerage network and no new flow will be permitted to discharge to the combined network. We would want the document to clearly state that a surface water drainage solution will need to be identified and implemented prior to the construction of hard standing areas. The solution would need to be agreed with all stakeholders.

Engagement with developers

Anglian Water offers a pre planning service which includes a capacity check to determine the impact of sewerage from a proposed development. We will also work with the developer or land owner during this process to develop foul and surface water (where applicable) drainage solutions which will not cause a detriment to our existing or future customer. We would encourage the prospective developer to contact us at the earliest convenience to discuss drainage proposals to serve the development. Details regarding this service can be found at http://www.anglianwater.co.uk/developers/pre- planning-service-.aspx

Anglian Water are keep to engage with Suffolk Coastal District Council on Local Plan consultations and on individual planning applications. Summary: 357: Significant off-site sewergae required to connect into HOLLSC. Septicity control will be required. 8UCH: Sewers Crossing Site.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: 5002_Suffolk_Coastal_allocation_-_sites_consultation_sheet_(RSP)_-_Jan-15(1).pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6389 - 2655 - Hollesley - None 6389 Comment Woodbridge Housing Market Area Hollesley

Respondent: Member of Parliament (MP) (Rt. Hon Therese Agent: N/A Coffey MP) [2655]

Full Text: Thank you for the opportunity to comment on the site allocations and area specific policies for the local plan. I think it is a welcome step to encourage all the public to participate in this early stage of the process. I only usually intervene on strategic issues and policies on planning.

While I have detailed my comments on some individual areas below, I have three particular issues to discuss - i) the imbalance of housing allocations around the area with the vast amount of development inserted east of the A12, the side of Suffolk that has the AONB and nearly all the SSSls; iii) the absence of nominated sites in Framlingham and Leiston; iii) building on main roads and the absence of infrastructure, particularly roads, for major and cumulative developments with the risk of significant congestion and longer journey times as well as community facilities.

Allocation of housing across the district

The vast majority of the proposed housing lies east of the A12 and to the south of the district. This continues to move the centre of gravity south east which runs the risk of excluding significant parts of our area of new housing for local people and also the lack of infrastructure (either new or upgraded). There appears to be a surprising disparity between settlements on where is deemed appropriate for further development and where is not. For example, no further housing is recommended for Wickham Market while Wenhaston, lower down the settlement hierarchy, has been recommended for more housing despite having just had an application for 26 new homes approved (higher than the Local Plan allocation of 5-15). Separately, Saxmundham has been recommended for further housing after a significant amount already built and under construction. I do not object specifically to that but will make the point later about infrastructure. There is little difference between Wickham Market, Saxmundham and Framlingham apart from the railway station. It has been suggested that Wickham Market has already had some housing so need not have any more and Framlingham has been allocated a small amount. That is in contrast to Leiston which has been allocated up to 500 houses, though with no additional infrastructure. The experience elsewhere does not bear that out. While it makes sense to allow for housing in villages and parishes as well as market towns but in a sensible proportion that does not dwarf existing villages. Therefore, I suggest that villages that have already had housing approved in the last two years should not have further sites specifically designated but allow for windfall, within the existing village envelope and not on main roads (like the A12 in Yoxford or A1120 in Peasenhall or the High Road in the Trimleys or the A144). It also should be on the same side of the main road as the local facilities - which would rule out nominated sites specifically in Yoxford and Woodbridge. We should not repeat the mistakes of the past. Another guiding principle should be that new housing is as close as possible to existing facilities. There is development planned on the opposite side of the main road to key facilities in some areas, which would significantly shift the centre of gravity and mean people having to cross busy roads to get to the centre. Shifting the centre of gravity of further development away from shops and facilities in towns, as may be the case in Saxmundham, is a retrograde step for enhancing the sense of community. The council must counter the risk of our small market towns becoming car-based, seeking shopping, leisure and sporting activities away from the town.

I strongly support the protection of green gaps, acting as strategic barriers between settlements.

There is an absence of nominated sites in Leiston and Framlingham. It has been suggested that this is due to emerging town plans but they should not have been absented from this consultation.

Finally, the absence of infrastructure. There is already huge pressure on various parts of the A12 and there is no indication of what infrastructure additions or upgrades are being proposed to accommodate such significant increases. In more specific terms,

i) Martlesham area with 2000 houses, adding to the increasing retail presence on the Martlesham Heath industrial estate. The latter is already leading to significant increases in traffic, coupled with further housing already under construction in Martlesham. Significant improvements need to be made to the A12 at several junctions. ii) Woods Lane roundabout and the A1152. There are already at least 15,000 traffic movements per day at the Melton railway crossing (sourced from Network Rail three years ago). Without substantial improvements to roads here, the additional housing suggested in Melton, Eyke and Rendlesham will bring even greater traffic movement pressure on the round about, the railway crossing and the traffic lights on the junction of the A1152/B1438. iii) Given the council's full support for the 4 villages bypass, it is surprising that no housing has been considered for this area as bypasses usually lead to significant increases in housing. Meanwhile, up to 500 houses are being proposed for Leisten but with no road improvements and no support for the potential D2 route being suggested in conjunction with Sizewell C. iv) In Saxmundham, a substantial number of new housing has already been built. While there has been minor modification of the traffic lights in the centre of the town, there has been no improvements planned to help traffic in and through the town. v) Woodbridge site at the football ground -addressing the congestion and the replacement of sporting facilities within the town area. vi) Local community infrastructure will need significant improvement - pace Rendlesham, Saxmundham, Leisten, the Trimleys and the new development at Martlesham. On local sites, I have commented by exception and no comment is not a sign of endorsement.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6389 - 2655 - Hollesley - None 6389 Comment Woodbridge Housing Market Area Hollesley

Woodbridge Housing Area

Campsea Ashe Site 557 is a very unusual place to add more housing especially if there is going to be work on the track for Sizewell C. I agree with 745 and 990 being unsuitable SHLAA sites. They are far too large and inappropriate. Eyke Agree that 991 and OPP7 are unsuitable sites. 991 looks to double size of village whereas Opp7 suggests substantial new housing along A-road which is unsuitable. Hollesley Agree that 825 is unsuitable - losing a significant amount of green field opposite school. Orford Agree that 494/484 & 976 is unsuitable. Surprised some sites proposed with sea levels. Tunstall Disagree that 786, 597 and 730 would all be suitable as a whole as seems to double the size of the village which is unnecessary over-development. Wickham Market Would support 7761 and 776i as it is a significant market town. Woodbridge Agree that sites 937 and 453 are unsuitable due to being west of the A12. 839,750,750a, 974 unsuitable due to pressure on roundabout.

Framlingham Housing Area

Bramfield Agree that 493 is unsuitable as it is too far away from the centre. Peasenhall Agree with 832 being unsuitable as outside the envelope and inappropriate. Wenhaston The village has already had a significant amount of development therefore I don't see the need for any further sites to be added. Strongly oppose any greenfield sites. Yoxford Strongly oppose accepted SHLAA sites 642b and 794. They are both opposite or adjacent to existing housing but involves crossing a main road to get to existing village facilities.

Saxmundham Housing Area

Aldeburgh Agree with unsuitable SHLAA sites in first map. Should continue to look for windfall sites. Strongly agree that 768 shouldn't be brought forward. Benhall Agree that 411b and 411c should not be brought forward. They would dwarf the village and would constitute overdevelopment. Blythburgh Disagree with 4UCB being brought forward as junction already very difficult and wouldn't cope. Darsham Agree that 378 and 967 are unsuitable as are considerably out of the village. Strongly disagree with 794 as it is too close to the main road and a strategic error. Dunwich Agree that 713 is unsuitable as is too far away from the village centre. Knodishall Agree that 506 which would dwarf the village, 579 which would significantly reduce the gap to Aldringham and 971 which would bring an unwarranted urban feel to that side of the village are unsuitable. Little Glemham 625 would put particular pressure on A12 which would require substantial highway change if it were to go ahead. Saxmundham Strongly agree that the non-hatched sites are unsuitable. Of the sites that have been endorsed 1006 and 1009, there is a risk of this development being too far away from the high street shift the centre of gravity. If this was to go ahead then there should be consideration for a relief road from the North entrance to the B1119. Snape Agree that 758 is unsuitable as too far out of the centre of the village. Westleton Agree with unsuitability of sites. Strongly oppose any development on 327 and 935.

Felixstowe Housing Area/Area Action Plan

Waldrlngfield Support 961 being a SHLAA unsuitable site. We need to protect this as a local gap. Bucklesham Most sites are too big and too far away from village centre. Kirton It is my understanding the Falkenham Road site has been backed in a local consultation session run by the Parish Council. Concerned about over development if all the other sites were approved. Trimley St Martin Agree that 920 and 889 are completely unsuitable. Trimley St Mary Concern that the current road network could cope with significant development on 383F. Agree with unsuitability of 383,c,d,e & 451e as too far away from centre. Summary: Hollesley Agree that 825 is unsuitable - losing a significant amount of green field opposite school.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6542 - 2581 - Hollesley - None 6542 Comment Woodbridge Housing Market Area Hollesley

Respondent: Suffolk County Council (Mr Robert Feakes) [2581] Agent: N/A

Full Text: Site Allocations Document - Issues and Options Consultation Suffolk County Council Response

1. Introduction

1.1 Thank you for consulting Suffolk County Council on the above document. This response aims to set out the issues which our two authorities will need to resolve as this document is brought forwards towards adoption, rather than seeking to resolve issues now. Comments are set out in relation to Suffolk County Council service responsibilities and policy objectives; matters on which our authorities need to cooperate.

2. Air Quality and Noise Assessment

2.1 There are a number of locations within Martlesham that are adjacent to the A12, which include 710, 479, 721, 644, 693, 517, 430. The bunding adjacent to the A12 at sites 517/430, provided initially to protect Martlesham Heath residents from mineral working noise, should be retained as it has been designed (it is high enough) to provide a good level of protection from road traffic noise for any new dwellings behind it.

2.2 Developments adjacent to the A1214 through , eg. 774a and also the A1156 Felixstowe Road would all be subject to traffic noise as these routes carry significant volumes of traffic. Also locations at Ufford adjacent to the A12 to include 586, 838a and 838b and at Woodbridge for plots 937, 900a and 703. There a number of IAs along the A12 at Martlesham Heath and Woodbridge and should additional residential receptors be built adjacent to the route, these would be extended, potentially requiring this authority to fund mitigation provision. Similarly for other locations adjacent the A12 at Darsham, , Little Glemham, Saxmundham and Yoxford.

2.3 There is an Air Quality Management Area (AQMA) in Woodbridge at the Lime Kiln Quay Road/Melton Hill junction. This should be viewed as a constraint and taken into account looking at the impacts of traffic growth through Woodbridge.

3. Archaeology

3.1 It is suggested that an informative section is considered which highlights the archaeology of the area and its management in the development process. The following is provided as an initial suggestion:

Suffolk Coastal has a rich, diverse and dense archaeological landscape with the river valleys, in particular, topographically favourable for early occupation of all periods. The distinctive character of the historic environment in the District includes upstanding coastal archaeology of all dates, prehistoric burial tumuli on the open heathlands around the eastern margins of Ipswich and on the Felixstowe peninsula, the remains of Roman small towns at Felixstowe and Wenhaston, the internationally important Anglo-Saxon burial ground at Sutton Hoo, numerous medieval historic towns and villages with both above and below ground heritage assets, for example Woodbridge and Aldeburgh, and the strategically placed, Napoleonic Martello towers. These are among over 7,300 sites of archaeological interest currently recorded in the Suffolk Historic Environment Record for Suffolk Coastal. Suffolk County Council Archaeological Service routinely advises that there should be early consultation of the Historic Environment Record and assessment of the archaeological potential of proposed sites at an appropriate stage in the design of new developments, in order that the requirements of the NPPF are met with regards to designated and non-designated heritage assets.

3.2 Suffolk County Council's archaeologists would be pleased to liaise with the District Council on wording, and provide more detailed information on archaeology on the area if required. To briefly clarify two points within the documents, heritage assets include Scheduled Monuments (paragraph 5.17) and non-designated heritage assets also include archaeological sites (paragraph 5.19).

3.3 For those sites which have not previously been commented on through the Strategic Housing Land Availability Assessment process, comments on likely archaeological assessment requirements are set out as an appendix to this letter.

4. Education (including Early Years)

4.1 In order to meet the requirements of Paragraph 72 of the National Planning Policy Framework, and to support community wellbeing (as described in paragraph 3.15 of the Core Strategy), this plan must ensure the delivery of sufficient education places to meet demand arising from housing growth. Government policy is that new provision made necessary as a result of demand arising from new housing should be funded from developer contributions; the County Council can only access funding to provide new places made necessary as a result of population growth arising from the existing housing stock.

4.2 In respect of the statutory requirement to provide 15 hours per week of early education for 3 - 4 year olds (and eligible 2 year olds), there is clearly a variation in levels of existing capacity across the District, which will impact on what additional provision is needed. For many of the parishes, the allocations indicated will not necessitate the provision of new Early Years settings, but contributions are still likely to be sought in many instances.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6542 - 2581 - Hollesley - None 6542 Comment Woodbridge Housing Market Area Hollesley

4.3 Those settlements with more significant development (Leiston, Saxmundham, Woodbridge, Aldeburgh and Framlingham) are more likely to require contributions towards additional provision. The County Council does not normally seek allocations of land for additional provision, given that provision is largely made through the private, voluntary and independent sector providers. However, should any new primary schools be required, it is expected that early education provision will be co-located with the new primary schools.

4.4 In terms of primary education, the distribution of housing is a key determining factor as regards what additional provision is needed. Our authorities also need to consider the long term resilience of the primary school system, and consider the likelihood that the forthcoming review of the Suffolk Core Strategy will result in the allocation of additional dwellings to the rural areas.

4.5 For much of the District, specifically in the rural areas, existing schools are likely to be able to absorb the low levels of growth proposed. However, this capacity cannot be considered as 'available' to absorb growth proposed in the market towns. Paragraph 38 of the NPPF emphasises the priority which should be given to locating key facilities in close proximity to housing. Assuming that children can attend schools a long distance from their homes will increase the need to travel, reduce the proportion of journeys undertaken by sustainable modes and place an ongoing cost on the public purse for home to school transport.

4.6 It appears that the level of growth proposed in Framlingham (75-150 dwellings) and Leiston (250-500 dwellings) can be accommodated in local schools on their existing sites, though developer contributions will be required in Framlingham at primary level and may be required in Leiston if development is at the larger end of the scale.

4.7 It also appears that the level of growth proposed in Saxmundham can be accommodated at local schools, albeit in a limited capacity. However, if further iterations of this document bring forward additional allocations in Saxmundham, it is unlikely that this growth could be accommodated at Saxmundham Primary School. Equally, the 'neighbouring' schools cannot accept further pupils from growth in Saxmundham (beyond that already agreed). Therefore, any further growth at Saxmundham will need to be accompanied with detailed consideration of how growth can be managed at primary school level. It may necessitate the development of a new primary school, which will necessarily be funded through Section 106 agreements.

4.8 Existing schools cannot accept growth indefinitely. If there is significant growth at Framlingham and Saxmundham, beyond that envisaged by this document, it is likely to be appropriate for the Local Plan to identify new school sites in these towns. This will help to minimise the risk of sending children to schools outside their own communities.

4.9 In regard to Woodbridge, it is important to better understand exactly where the housing is going to be. In considering current forecasts it appears that spaces would be available at Kyson and Melton in particular which, according to the SHLAA sites map, would be the local schools for the majority of the proposed housing. Significant housing growth within the catchments of St Marys and Woodbridge Primaries may prove problematic.

4.10 Development of 75-150 dwellings in Aldeburgh is expected to generate between 19 and 38 additional pupils (based on 25 pupils per 100 dwellings). Aldeburgh Primary School is consistently at capacity for the forecast period, and the school cannot be expanded on its current site. Whilst there is capacity at Leiston and Coldfair Green Primary Schools, sending pupils from Aldeburgh to these schools is undesirable and would need to be considered alongside growth in these parishes. If the District Council does intend to allocate housing at Aldeburgh, this will need to be the subject of early discussion.

4.11 Rendlesham Primary School has recently been expanded to 315 - places. Further expansion; which may be necessary to cope with 75-100 dwellings (19-25 pupils); would be challenging.

4.12 At secondary level, the allocations envisaged by this consultation document are likely to create additional demand at:

- Thomas Mills High School, - Saxmundham Free School, - Stradbroke High School - Debenham High School - High School - High School - Alde Valley School - Farlingaye High School - Kesgrave High School

4.13 The scale of development proposed is not envisaged as being problematic at secondary level, with the exception of growth within the Farlingaye catchment. It appears that allocated growth within the Farlingaye catchment could be around 345 dwellings (or be fewer), meaning up to 62 pupils aged 11-16 and 14 pupils aged 16+. Farlingaye High School is already consistently over capacity, and it is not possible to expand the school on its current site. Should Adastral Park come forward in the near future, this creates an opportunity for delivering additional secondary school capacity, to take pressure off Farlingaye. However, our authorities need to discuss contingencies for managing this

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6542 - 2581 - Hollesley - None 6542 Comment Woodbridge Housing Market Area Hollesley

growth.

5. Health and Wellbeing

5.1 The County Council is keen to discuss the extent to which this document can promote the objective of the Suffolk Health and Wellbeing Strategy. Particular issues are access to the countryside and green space via the public rights of way network, and consideration of whether allocations for supported housing are necessary.

6. Libraries

6.1 In order to ensure deliverability of the Plan, it will need to be demonstrated that provision can be made to increase library service levels through developer contributions. The County Council is currently developing a more detailed plan for how library service provision will be developed in order to meet the demands of planned growth, in order to inform discussions on CIL spending.

7. Minerals and Waste Plans

7.1 At present, the County Council has no comments as the Minerals and Waste planning authority, but our authorities will need to work to ensure consistency between Plans. Our authorities should consider how we might encourage the sustainable use of minerals in situ, in advance of development, in order to reduce the need for extraction elsewhere and to reduce the highway impacts of construction.

8. Natural Environment

8.1 The County Council is interested in the ways in which this DPD can support the objectives of Suffolk's Nature Strategy, and would be pleased to work with the District Council to consider how this DPD could promote natural environment objectives, such as developing ecological networks. This is relevant in the context of the health and wellbeing strategy (as referred to elsewhere in this response), and the availability of accessible green space is important for mitigating impacts on European designated sites.

9. Public Rights of Way

9.1 The NPPF refers to a need for the planning system to protect and promote the public rights of way network. The Suffolk Health and Wellbeing Strategy includes 'access to a healthy environment' as a key objective. The Plan should consider how it will meet those challenges.

9.2 There is an opportunity to give detailed thought as to how the Plan can encourage healthy and sustainable travel, improve access to the countryside and open space, and to improve leisure and recreation opportunities. Officers from the County Council would be pleased to support the development of the plan in respect of these opportunities.

10. Surface Water Management

10.1 The County Council would be pleased to provide surface water flood records, to help consider the deliverability of sites and whether or not any specific policy measures will be required. SuDS principles should be applied as appropriate, in accordance with national standards, to enhance recharge of underground aquifers as well as provide surface water management and environmental features.

11. Transport

11.1 The County Council has previously provided comments on potential highway impacts arising from each site individually. It is not envisaged that these allocations will require a cumulative assessment of transport impacts.

12. Waste Provision

12.1 Suffolk Coastal, outside of the Felixstowe AAP area, is served by Household Waste Recycling Centres at Leiston, Felixstowe and Foxhall.

12.2 Whilst there are no proposals under consideration at the current time to change the service provided at the Leiston site, or indeed to move it, there is a recognition that the site does suffer from congestion at peak times. It is likely that the impact of development in the local area will increase pressure on the site and the County Council will be seeking developer contributions to fund improvements in the current site or to fund a replacement, should an alternative site come forward.

12.3 The Foxhall site will require a modification and change to existing planning permissions beyond 2021, if it is to remain on site it will need a partial rebuild for certain and, possibly, modifications to the vehicular access arrangements. If this is not possible a new site will need to be found in the area and before 2020 at the latest. CIL funding may be sought to support these projects.

13. Water Management, Flood and Coastal Defences

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6542 - 2581 - Hollesley - None 6542 Comment Woodbridge Housing Market Area Hollesley

13.1 Water resources are critical in the east of Suffolk, as recognised in Anglian Water's recently updated Water Resources Management Plan. Any measures that can be incorporated in new developments to capture/reuse/recycle water should be encouraged.

13.2 The recently finalised Deben Estuary Plan (and forthcoming Alde/Ore Estuary Plan) should be considered in relation to the development of this Plan - in the same way as the Suffolk Shoreline Management Plan. These plans rely upon a willingness to embrace the principle of an integrated system - recognising the need to reconcile the continued wellbeing of the river systems, the interests of the communities and the ecological integrity of unique estuarine environments.

13.3 The concept within these estuary plans, of 'enabling development', proposed as one possible mechanism for funding local flood defences, should be encouraged where proper infrastructure can also be provided.

13.4 Where appropriate development funding should be directed towards flood and coastal defences. Without local contributions of this type, many of our existing settlements will be at risk in the future.

Appendix: Likely Archaeological Assessment Requirements

East Ipswich Plan Area

Martlesham 900a. This site was covered under advice in 2008 for 703. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham 893. This site is close to areas of prehistoric activity (County Historic Environment Record MRM 154, MRM 027). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Westerfield 939. This site is close to the medieval core of the settlement, and within the findspot of Roman, Saxon and Iron Age objects. There is high potential for the development to impact on archaeological remains of these periods. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham EMP1 694 - previous recommendation for early archaeological assessment (sites 721/694/644).

Ransomes EMP2 - This large area (15ha) lies adjacent to a series of burnt pits (County Historic Environment Record PFM 009) and cropmark features of a pre-historic/Roman trackway and associated features to the east (PFM 085). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Framlingham

Wenhaston 938a. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Wenhaston 938b. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. The development also has a frontage onto one of the historic streets of the late Saxon and medieval settlement. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Yoxford 794. No objection in principle but it would any application should include an desk-based assessment and appraisal of structures currently existing on the site. Depending on the results of desk-based assessment, the site may require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham

Aldringham 5668. Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work. Development should be sensitive to the particular historic character of the built environment.

Benhall 969. This site is in a topographically favourable location for early activity overlooking the River Fromus. No

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6542 - 2581 - Hollesley - None 6542 Comment Woodbridge Housing Market Area Hollesley

objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Blythburgh 4UCB. This site is in an area of very high archaeological potential within the historic core of Saxon and Medieval Blythburgh. The development fronts historic streets of the settlement. It has remained undeveloped in more recent periods (e.g. as shown on historic OS maps) and there is good potential for preservation of earlier archaeological remains. There could be complex remains surviving. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Blythburgh 3UCB Development on this site should be sympathetic to the historic farmstead, and development proposals should include assessments of historic buildings which are to be altered by the development so that informed decisions can be made. The site has archaeological potential, close to the existing 16th century building and within the historic core of Blythburgh. It would require a planning condition under the NPPF to secure a programme of archaeological work.

Kelsale cum Carleton 884 This site has not been systematically investigated for archaeological remains. It is in a topographically favourable valley side location, and should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Knodishall OPP5 This site lies within the historic settlement core, on the green edge, and development has the potential to impact upon early settlement remains. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Middleton 779 This site lies within the historic settlement core. A prehistoric ring ditch is recorded to the west (County Historic Environment Record MDD 004). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham 1006 This site is in an area of high archaeological potential overlooking the valley of the River Fromus. Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Saxmundham 1009 This site has been partially evaluated for archaeological remains (geophysical survey and some archaeological trial trenching). There are no grounds to object to development, but development will require a planning condition under the NPPF to secure a programme of archaeological work. This should include record of farm buildings, and further evaluation in the first instance. The results of evaluation will inform the overall archaeological investigation strategy.

Woodbridge

Aldeburgh 982 This large site is in an area of high archaeological potential, on a south facing slope overlooking the estuary and Aldeburgh marshes. Medieval archaeological remains are recorded to the north (County Historic Environment Record ADB 004), and Bronze Age to the west (ADB 002). Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Much of the site is within the area of brickworkings associated with the former Read's Brickworks. Desk- based assessment and geophysical survey in the first instance would establish the impacts of this previous landuse. There would be potential for promotion of the heritage of the area.

Hollesley 829 This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the southwest (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Hollesley 9UCH This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the northeast (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Information on buildings on the site should be submitted with any application, should they be impacted on by proposed development.

Hollesley 8UCH. This site lies within the historic core of Hollesley, opposite the church and with a street frontage that has high potential for archaeological remains relating to early settlement. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Early evaluation of the street frontage would be advisable so that archaeological investigation can be factored in to project designs. Evaluation has been carried out towards the rear of the site and did not reveal significant remains.

Orford OPP4 This site is close to a possible mound site (County Historic Environment Record ORF 023), and the site of a windmill depicted on a plan of c1600 (ORF 019). It should be subject to archaeological assessment at an appropriate

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6542 - 2581 - Hollesley - None 6542 Comment Woodbridge Housing Market Area Hollesley

stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Geophysical survey would be appropriate in the first instance.

Shottisham 812b Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work.

Shottisham 812d Exact map location not provided, but the site is within the Anglo-Saxon and Medieval core of the settlement (County Historic Environment Record STT 059), close to the church. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Tunstall 786 - This site lies within and on the edge of the historic settlement core. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Any application should also include an assessment of buildings that are to be affected by development.

Woodbridge 900a - This site lies within an area of archaeological potential, and Neolithic pits and Iron Age features were excavated to the south (County Historic Environment Record MRM 030). The site should be subject to archaeological assessment at an appropriate stage in the design of new development to establish the impacts of past land-use, and ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Summary: Hollesley 829 This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the southwest (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6543 - 2581 - Hollesley - None 6543 Comment Woodbridge Housing Market Area Hollesley

Respondent: Suffolk County Council (Mr Robert Feakes) [2581] Agent: N/A

Full Text: Site Allocations Document - Issues and Options Consultation Suffolk County Council Response

1. Introduction

1.1 Thank you for consulting Suffolk County Council on the above document. This response aims to set out the issues which our two authorities will need to resolve as this document is brought forwards towards adoption, rather than seeking to resolve issues now. Comments are set out in relation to Suffolk County Council service responsibilities and policy objectives; matters on which our authorities need to cooperate.

2. Air Quality and Noise Assessment

2.1 There are a number of locations within Martlesham that are adjacent to the A12, which include 710, 479, 721, 644, 693, 517, 430. The bunding adjacent to the A12 at sites 517/430, provided initially to protect Martlesham Heath residents from mineral working noise, should be retained as it has been designed (it is high enough) to provide a good level of protection from road traffic noise for any new dwellings behind it.

2.2 Developments adjacent to the A1214 through Kesgrave, eg. 774a and also the A1156 Felixstowe Road would all be subject to traffic noise as these routes carry significant volumes of traffic. Also locations at Ufford adjacent to the A12 to include 586, 838a and 838b and at Woodbridge for plots 937, 900a and 703. There a number of IAs along the A12 at Martlesham Heath and Woodbridge and should additional residential receptors be built adjacent to the route, these would be extended, potentially requiring this authority to fund mitigation provision. Similarly for other locations adjacent the A12 at Darsham, Kelsale, Little Glemham, Saxmundham and Yoxford.

2.3 There is an Air Quality Management Area (AQMA) in Woodbridge at the Lime Kiln Quay Road/Melton Hill junction. This should be viewed as a constraint and taken into account looking at the impacts of traffic growth through Woodbridge.

3. Archaeology

3.1 It is suggested that an informative section is considered which highlights the archaeology of the area and its management in the development process. The following is provided as an initial suggestion:

Suffolk Coastal has a rich, diverse and dense archaeological landscape with the river valleys, in particular, topographically favourable for early occupation of all periods. The distinctive character of the historic environment in the District includes upstanding coastal archaeology of all dates, prehistoric burial tumuli on the open heathlands around the eastern margins of Ipswich and on the Felixstowe peninsula, the remains of Roman small towns at Felixstowe and Wenhaston, the internationally important Anglo-Saxon burial ground at Sutton Hoo, numerous medieval historic towns and villages with both above and below ground heritage assets, for example Woodbridge and Aldeburgh, and the strategically placed, Napoleonic Martello towers. These are among over 7,300 sites of archaeological interest currently recorded in the Suffolk Historic Environment Record for Suffolk Coastal. Suffolk County Council Archaeological Service routinely advises that there should be early consultation of the Historic Environment Record and assessment of the archaeological potential of proposed sites at an appropriate stage in the design of new developments, in order that the requirements of the NPPF are met with regards to designated and non-designated heritage assets.

3.2 Suffolk County Council's archaeologists would be pleased to liaise with the District Council on wording, and provide more detailed information on archaeology on the area if required. To briefly clarify two points within the documents, heritage assets include Scheduled Monuments (paragraph 5.17) and non-designated heritage assets also include archaeological sites (paragraph 5.19).

3.3 For those sites which have not previously been commented on through the Strategic Housing Land Availability Assessment process, comments on likely archaeological assessment requirements are set out as an appendix to this letter.

4. Education (including Early Years)

4.1 In order to meet the requirements of Paragraph 72 of the National Planning Policy Framework, and to support community wellbeing (as described in paragraph 3.15 of the Core Strategy), this plan must ensure the delivery of sufficient education places to meet demand arising from housing growth. Government policy is that new provision made necessary as a result of demand arising from new housing should be funded from developer contributions; the County Council can only access funding to provide new places made necessary as a result of population growth arising from the existing housing stock.

4.2 In respect of the statutory requirement to provide 15 hours per week of early education for 3 - 4 year olds (and eligible 2 year olds), there is clearly a variation in levels of existing capacity across the District, which will impact on what additional provision is needed. For many of the parishes, the allocations indicated will not necessitate the provision of new Early Years settings, but contributions are still likely to be sought in many instances.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6543 - 2581 - Hollesley - None 6543 Comment Woodbridge Housing Market Area Hollesley

4.3 Those settlements with more significant development (Leiston, Saxmundham, Woodbridge, Aldeburgh and Framlingham) are more likely to require contributions towards additional provision. The County Council does not normally seek allocations of land for additional provision, given that provision is largely made through the private, voluntary and independent sector providers. However, should any new primary schools be required, it is expected that early education provision will be co-located with the new primary schools.

4.4 In terms of primary education, the distribution of housing is a key determining factor as regards what additional provision is needed. Our authorities also need to consider the long term resilience of the primary school system, and consider the likelihood that the forthcoming review of the Suffolk Core Strategy will result in the allocation of additional dwellings to the rural areas.

4.5 For much of the District, specifically in the rural areas, existing schools are likely to be able to absorb the low levels of growth proposed. However, this capacity cannot be considered as 'available' to absorb growth proposed in the market towns. Paragraph 38 of the NPPF emphasises the priority which should be given to locating key facilities in close proximity to housing. Assuming that children can attend schools a long distance from their homes will increase the need to travel, reduce the proportion of journeys undertaken by sustainable modes and place an ongoing cost on the public purse for home to school transport.

4.6 It appears that the level of growth proposed in Framlingham (75-150 dwellings) and Leiston (250-500 dwellings) can be accommodated in local schools on their existing sites, though developer contributions will be required in Framlingham at primary level and may be required in Leiston if development is at the larger end of the scale.

4.7 It also appears that the level of growth proposed in Saxmundham can be accommodated at local schools, albeit in a limited capacity. However, if further iterations of this document bring forward additional allocations in Saxmundham, it is unlikely that this growth could be accommodated at Saxmundham Primary School. Equally, the 'neighbouring' schools cannot accept further pupils from growth in Saxmundham (beyond that already agreed). Therefore, any further growth at Saxmundham will need to be accompanied with detailed consideration of how growth can be managed at primary school level. It may necessitate the development of a new primary school, which will necessarily be funded through Section 106 agreements.

4.8 Existing schools cannot accept growth indefinitely. If there is significant growth at Framlingham and Saxmundham, beyond that envisaged by this document, it is likely to be appropriate for the Local Plan to identify new school sites in these towns. This will help to minimise the risk of sending children to schools outside their own communities.

4.9 In regard to Woodbridge, it is important to better understand exactly where the housing is going to be. In considering current forecasts it appears that spaces would be available at Kyson and Melton in particular which, according to the SHLAA sites map, would be the local schools for the majority of the proposed housing. Significant housing growth within the catchments of St Marys and Woodbridge Primaries may prove problematic.

4.10 Development of 75-150 dwellings in Aldeburgh is expected to generate between 19 and 38 additional pupils (based on 25 pupils per 100 dwellings). Aldeburgh Primary School is consistently at capacity for the forecast period, and the school cannot be expanded on its current site. Whilst there is capacity at Leiston and Coldfair Green Primary Schools, sending pupils from Aldeburgh to these schools is undesirable and would need to be considered alongside growth in these parishes. If the District Council does intend to allocate housing at Aldeburgh, this will need to be the subject of early discussion.

4.11 Rendlesham Primary School has recently been expanded to 315 - places. Further expansion; which may be necessary to cope with 75-100 dwellings (19-25 pupils); would be challenging.

4.12 At secondary level, the allocations envisaged by this consultation document are likely to create additional demand at:

- Thomas Mills High School, - Saxmundham Free School, - Stradbroke High School - Debenham High School - Halesworth High School - Bungay High School - Alde Valley School - Farlingaye High School - Kesgrave High School

4.13 The scale of development proposed is not envisaged as being problematic at secondary level, with the exception of growth within the Farlingaye catchment. It appears that allocated growth within the Farlingaye catchment could be around 345 dwellings (or be fewer), meaning up to 62 pupils aged 11-16 and 14 pupils aged 16+. Farlingaye High School is already consistently over capacity, and it is not possible to expand the school on its current site. Should Adastral Park come forward in the near future, this creates an opportunity for delivering additional secondary school capacity, to take pressure off Farlingaye. However, our authorities need to discuss contingencies for managing this

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6543 - 2581 - Hollesley - None 6543 Comment Woodbridge Housing Market Area Hollesley

growth.

5. Health and Wellbeing

5.1 The County Council is keen to discuss the extent to which this document can promote the objective of the Suffolk Health and Wellbeing Strategy. Particular issues are access to the countryside and green space via the public rights of way network, and consideration of whether allocations for supported housing are necessary.

6. Libraries

6.1 In order to ensure deliverability of the Plan, it will need to be demonstrated that provision can be made to increase library service levels through developer contributions. The County Council is currently developing a more detailed plan for how library service provision will be developed in order to meet the demands of planned growth, in order to inform discussions on CIL spending.

7. Minerals and Waste Plans

7.1 At present, the County Council has no comments as the Minerals and Waste planning authority, but our authorities will need to work to ensure consistency between Plans. Our authorities should consider how we might encourage the sustainable use of minerals in situ, in advance of development, in order to reduce the need for extraction elsewhere and to reduce the highway impacts of construction.

8. Natural Environment

8.1 The County Council is interested in the ways in which this DPD can support the objectives of Suffolk's Nature Strategy, and would be pleased to work with the District Council to consider how this DPD could promote natural environment objectives, such as developing ecological networks. This is relevant in the context of the health and wellbeing strategy (as referred to elsewhere in this response), and the availability of accessible green space is important for mitigating impacts on European designated sites.

9. Public Rights of Way

9.1 The NPPF refers to a need for the planning system to protect and promote the public rights of way network. The Suffolk Health and Wellbeing Strategy includes 'access to a healthy environment' as a key objective. The Plan should consider how it will meet those challenges.

9.2 There is an opportunity to give detailed thought as to how the Plan can encourage healthy and sustainable travel, improve access to the countryside and open space, and to improve leisure and recreation opportunities. Officers from the County Council would be pleased to support the development of the plan in respect of these opportunities.

10. Surface Water Management

10.1 The County Council would be pleased to provide surface water flood records, to help consider the deliverability of sites and whether or not any specific policy measures will be required. SuDS principles should be applied as appropriate, in accordance with national standards, to enhance recharge of underground aquifers as well as provide surface water management and environmental features.

11. Transport

11.1 The County Council has previously provided comments on potential highway impacts arising from each site individually. It is not envisaged that these allocations will require a cumulative assessment of transport impacts.

12. Waste Provision

12.1 Suffolk Coastal, outside of the Felixstowe AAP area, is served by Household Waste Recycling Centres at Leiston, Felixstowe and Foxhall.

12.2 Whilst there are no proposals under consideration at the current time to change the service provided at the Leiston site, or indeed to move it, there is a recognition that the site does suffer from congestion at peak times. It is likely that the impact of development in the local area will increase pressure on the site and the County Council will be seeking developer contributions to fund improvements in the current site or to fund a replacement, should an alternative site come forward.

12.3 The Foxhall site will require a modification and change to existing planning permissions beyond 2021, if it is to remain on site it will need a partial rebuild for certain and, possibly, modifications to the vehicular access arrangements. If this is not possible a new site will need to be found in the area and before 2020 at the latest. CIL funding may be sought to support these projects.

13. Water Management, Flood and Coastal Defences

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6543 - 2581 - Hollesley - None 6543 Comment Woodbridge Housing Market Area Hollesley

13.1 Water resources are critical in the east of Suffolk, as recognised in Anglian Water's recently updated Water Resources Management Plan. Any measures that can be incorporated in new developments to capture/reuse/recycle water should be encouraged.

13.2 The recently finalised Deben Estuary Plan (and forthcoming Alde/Ore Estuary Plan) should be considered in relation to the development of this Plan - in the same way as the Suffolk Shoreline Management Plan. These plans rely upon a willingness to embrace the principle of an integrated system - recognising the need to reconcile the continued wellbeing of the river systems, the interests of the communities and the ecological integrity of unique estuarine environments.

13.3 The concept within these estuary plans, of 'enabling development', proposed as one possible mechanism for funding local flood defences, should be encouraged where proper infrastructure can also be provided.

13.4 Where appropriate development funding should be directed towards flood and coastal defences. Without local contributions of this type, many of our existing settlements will be at risk in the future.

Appendix: Likely Archaeological Assessment Requirements

East Ipswich Plan Area

Martlesham 900a. This site was covered under advice in 2008 for 703. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham 893. This site is close to areas of prehistoric activity (County Historic Environment Record MRM 154, MRM 027). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Westerfield 939. This site is close to the medieval core of the settlement, and within the findspot of Roman, Saxon and Iron Age objects. There is high potential for the development to impact on archaeological remains of these periods. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham EMP1 694 - previous recommendation for early archaeological assessment (sites 721/694/644).

Ransomes EMP2 - This large area (15ha) lies adjacent to a series of burnt pits (County Historic Environment Record PFM 009) and cropmark features of a pre-historic/Roman trackway and associated features to the east (PFM 085). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Framlingham

Wenhaston 938a. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Wenhaston 938b. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. The development also has a frontage onto one of the historic streets of the late Saxon and medieval settlement. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Yoxford 794. No objection in principle but it would any application should include an desk-based assessment and appraisal of structures currently existing on the site. Depending on the results of desk-based assessment, the site may require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham

Aldringham 5668. Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work. Development should be sensitive to the particular historic character of the built environment.

Benhall 969. This site is in a topographically favourable location for early activity overlooking the River Fromus. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6543 - 2581 - Hollesley - None 6543 Comment Woodbridge Housing Market Area Hollesley

work.

Blythburgh 4UCB. This site is in an area of very high archaeological potential within the historic core of Saxon and Medieval Blythburgh. The development fronts historic streets of the settlement. It has remained undeveloped in more recent periods (e.g. as shown on historic OS maps) and there is good potential for preservation of earlier archaeological remains. There could be complex remains surviving. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Blythburgh 3UCB Development on this site should be sympathetic to the historic farmstead, and development proposals should include assessments of historic buildings which are to be altered by the development so that informed decisions can be made. The site has archaeological potential, close to the existing 16th century building and within the historic core of Blythburgh. It would require a planning condition under the NPPF to secure a programme of archaeological work.

Kelsale cum Carleton 884 This site has not been systematically investigated for archaeological remains. It is in a topographically favourable valley side location, and should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Knodishall OPP5 This site lies within the historic settlement core, on the green edge, and development has the potential to impact upon early settlement remains. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Middleton 779 This site lies within the historic settlement core. A prehistoric ring ditch is recorded to the west (County Historic Environment Record MDD 004). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham 1006 This site is in an area of high archaeological potential overlooking the valley of the River Fromus. Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Saxmundham 1009 This site has been partially evaluated for archaeological remains (geophysical survey and some archaeological trial trenching). There are no grounds to object to development, but development will require a planning condition under the NPPF to secure a programme of archaeological work. This should include record of farm buildings, and further evaluation in the first instance. The results of evaluation will inform the overall archaeological investigation strategy.

Woodbridge

Aldeburgh 982 This large site is in an area of high archaeological potential, on a south facing slope overlooking the estuary and Aldeburgh marshes. Medieval archaeological remains are recorded to the north (County Historic Environment Record ADB 004), and Bronze Age to the west (ADB 002). Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Much of the site is within the area of brickworkings associated with the former Read's Brickworks. Desk- based assessment and geophysical survey in the first instance would establish the impacts of this previous landuse. There would be potential for promotion of the heritage of the area.

Hollesley 829 This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the southwest (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Hollesley 9UCH This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the northeast (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Information on buildings on the site should be submitted with any application, should they be impacted on by proposed development.

Hollesley 8UCH. This site lies within the historic core of Hollesley, opposite the church and with a street frontage that has high potential for archaeological remains relating to early settlement. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Early evaluation of the street frontage would be advisable so that archaeological investigation can be factored in to project designs. Evaluation has been carried out towards the rear of the site and did not reveal significant remains.

Orford OPP4 This site is close to a possible mound site (County Historic Environment Record ORF 023), and the site of a windmill depicted on a plan of c1600 (ORF 019). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6543 - 2581 - Hollesley - None 6543 Comment Woodbridge Housing Market Area Hollesley

investigation strategies. Geophysical survey would be appropriate in the first instance.

Shottisham 812b Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work.

Shottisham 812d Exact map location not provided, but the site is within the Anglo-Saxon and Medieval core of the settlement (County Historic Environment Record STT 059), close to the church. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Tunstall 786 - This site lies within and on the edge of the historic settlement core. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Any application should also include an assessment of buildings that are to be affected by development.

Woodbridge 900a - This site lies within an area of archaeological potential, and Neolithic pits and Iron Age features were excavated to the south (County Historic Environment Record MRM 030). The site should be subject to archaeological assessment at an appropriate stage in the design of new development to establish the impacts of past land-use, and ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Summary: Hollesley 9UCH This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the northeast (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Information on buildings on the site should be submitted with any application, should they be impacted on by proposed development.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6544 - 2581 - Hollesley - None 6544 Comment Woodbridge Housing Market Area Hollesley

Respondent: Suffolk County Council (Mr Robert Feakes) [2581] Agent: N/A

Full Text: Site Allocations Document - Issues and Options Consultation Suffolk County Council Response

1. Introduction

1.1 Thank you for consulting Suffolk County Council on the above document. This response aims to set out the issues which our two authorities will need to resolve as this document is brought forwards towards adoption, rather than seeking to resolve issues now. Comments are set out in relation to Suffolk County Council service responsibilities and policy objectives; matters on which our authorities need to cooperate.

2. Air Quality and Noise Assessment

2.1 There are a number of locations within Martlesham that are adjacent to the A12, which include 710, 479, 721, 644, 693, 517, 430. The bunding adjacent to the A12 at sites 517/430, provided initially to protect Martlesham Heath residents from mineral working noise, should be retained as it has been designed (it is high enough) to provide a good level of protection from road traffic noise for any new dwellings behind it.

2.2 Developments adjacent to the A1214 through Kesgrave, eg. 774a and also the A1156 Felixstowe Road would all be subject to traffic noise as these routes carry significant volumes of traffic. Also locations at Ufford adjacent to the A12 to include 586, 838a and 838b and at Woodbridge for plots 937, 900a and 703. There a number of IAs along the A12 at Martlesham Heath and Woodbridge and should additional residential receptors be built adjacent to the route, these would be extended, potentially requiring this authority to fund mitigation provision. Similarly for other locations adjacent the A12 at Darsham, Kelsale, Little Glemham, Saxmundham and Yoxford.

2.3 There is an Air Quality Management Area (AQMA) in Woodbridge at the Lime Kiln Quay Road/Melton Hill junction. This should be viewed as a constraint and taken into account looking at the impacts of traffic growth through Woodbridge.

3. Archaeology

3.1 It is suggested that an informative section is considered which highlights the archaeology of the area and its management in the development process. The following is provided as an initial suggestion:

Suffolk Coastal has a rich, diverse and dense archaeological landscape with the river valleys, in particular, topographically favourable for early occupation of all periods. The distinctive character of the historic environment in the District includes upstanding coastal archaeology of all dates, prehistoric burial tumuli on the open heathlands around the eastern margins of Ipswich and on the Felixstowe peninsula, the remains of Roman small towns at Felixstowe and Wenhaston, the internationally important Anglo-Saxon burial ground at Sutton Hoo, numerous medieval historic towns and villages with both above and below ground heritage assets, for example Woodbridge and Aldeburgh, and the strategically placed, Napoleonic Martello towers. These are among over 7,300 sites of archaeological interest currently recorded in the Suffolk Historic Environment Record for Suffolk Coastal. Suffolk County Council Archaeological Service routinely advises that there should be early consultation of the Historic Environment Record and assessment of the archaeological potential of proposed sites at an appropriate stage in the design of new developments, in order that the requirements of the NPPF are met with regards to designated and non-designated heritage assets.

3.2 Suffolk County Council's archaeologists would be pleased to liaise with the District Council on wording, and provide more detailed information on archaeology on the area if required. To briefly clarify two points within the documents, heritage assets include Scheduled Monuments (paragraph 5.17) and non-designated heritage assets also include archaeological sites (paragraph 5.19).

3.3 For those sites which have not previously been commented on through the Strategic Housing Land Availability Assessment process, comments on likely archaeological assessment requirements are set out as an appendix to this letter.

4. Education (including Early Years)

4.1 In order to meet the requirements of Paragraph 72 of the National Planning Policy Framework, and to support community wellbeing (as described in paragraph 3.15 of the Core Strategy), this plan must ensure the delivery of sufficient education places to meet demand arising from housing growth. Government policy is that new provision made necessary as a result of demand arising from new housing should be funded from developer contributions; the County Council can only access funding to provide new places made necessary as a result of population growth arising from the existing housing stock.

4.2 In respect of the statutory requirement to provide 15 hours per week of early education for 3 - 4 year olds (and eligible 2 year olds), there is clearly a variation in levels of existing capacity across the District, which will impact on what additional provision is needed. For many of the parishes, the allocations indicated will not necessitate the provision of new Early Years settings, but contributions are still likely to be sought in many instances.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6544 - 2581 - Hollesley - None 6544 Comment Woodbridge Housing Market Area Hollesley

4.3 Those settlements with more significant development (Leiston, Saxmundham, Woodbridge, Aldeburgh and Framlingham) are more likely to require contributions towards additional provision. The County Council does not normally seek allocations of land for additional provision, given that provision is largely made through the private, voluntary and independent sector providers. However, should any new primary schools be required, it is expected that early education provision will be co-located with the new primary schools.

4.4 In terms of primary education, the distribution of housing is a key determining factor as regards what additional provision is needed. Our authorities also need to consider the long term resilience of the primary school system, and consider the likelihood that the forthcoming review of the Suffolk Core Strategy will result in the allocation of additional dwellings to the rural areas.

4.5 For much of the District, specifically in the rural areas, existing schools are likely to be able to absorb the low levels of growth proposed. However, this capacity cannot be considered as 'available' to absorb growth proposed in the market towns. Paragraph 38 of the NPPF emphasises the priority which should be given to locating key facilities in close proximity to housing. Assuming that children can attend schools a long distance from their homes will increase the need to travel, reduce the proportion of journeys undertaken by sustainable modes and place an ongoing cost on the public purse for home to school transport.

4.6 It appears that the level of growth proposed in Framlingham (75-150 dwellings) and Leiston (250-500 dwellings) can be accommodated in local schools on their existing sites, though developer contributions will be required in Framlingham at primary level and may be required in Leiston if development is at the larger end of the scale.

4.7 It also appears that the level of growth proposed in Saxmundham can be accommodated at local schools, albeit in a limited capacity. However, if further iterations of this document bring forward additional allocations in Saxmundham, it is unlikely that this growth could be accommodated at Saxmundham Primary School. Equally, the 'neighbouring' schools cannot accept further pupils from growth in Saxmundham (beyond that already agreed). Therefore, any further growth at Saxmundham will need to be accompanied with detailed consideration of how growth can be managed at primary school level. It may necessitate the development of a new primary school, which will necessarily be funded through Section 106 agreements.

4.8 Existing schools cannot accept growth indefinitely. If there is significant growth at Framlingham and Saxmundham, beyond that envisaged by this document, it is likely to be appropriate for the Local Plan to identify new school sites in these towns. This will help to minimise the risk of sending children to schools outside their own communities.

4.9 In regard to Woodbridge, it is important to better understand exactly where the housing is going to be. In considering current forecasts it appears that spaces would be available at Kyson and Melton in particular which, according to the SHLAA sites map, would be the local schools for the majority of the proposed housing. Significant housing growth within the catchments of St Marys and Woodbridge Primaries may prove problematic.

4.10 Development of 75-150 dwellings in Aldeburgh is expected to generate between 19 and 38 additional pupils (based on 25 pupils per 100 dwellings). Aldeburgh Primary School is consistently at capacity for the forecast period, and the school cannot be expanded on its current site. Whilst there is capacity at Leiston and Coldfair Green Primary Schools, sending pupils from Aldeburgh to these schools is undesirable and would need to be considered alongside growth in these parishes. If the District Council does intend to allocate housing at Aldeburgh, this will need to be the subject of early discussion.

4.11 Rendlesham Primary School has recently been expanded to 315 - places. Further expansion; which may be necessary to cope with 75-100 dwellings (19-25 pupils); would be challenging.

4.12 At secondary level, the allocations envisaged by this consultation document are likely to create additional demand at:

- Thomas Mills High School, - Saxmundham Free School, - Stradbroke High School - Debenham High School - Halesworth High School - Bungay High School - Alde Valley School - Farlingaye High School - Kesgrave High School

4.13 The scale of development proposed is not envisaged as being problematic at secondary level, with the exception of growth within the Farlingaye catchment. It appears that allocated growth within the Farlingaye catchment could be around 345 dwellings (or be fewer), meaning up to 62 pupils aged 11-16 and 14 pupils aged 16+. Farlingaye High School is already consistently over capacity, and it is not possible to expand the school on its current site. Should Adastral Park come forward in the near future, this creates an opportunity for delivering additional secondary school capacity, to take pressure off Farlingaye. However, our authorities need to discuss contingencies for managing this

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6544 - 2581 - Hollesley - None 6544 Comment Woodbridge Housing Market Area Hollesley

growth.

5. Health and Wellbeing

5.1 The County Council is keen to discuss the extent to which this document can promote the objective of the Suffolk Health and Wellbeing Strategy. Particular issues are access to the countryside and green space via the public rights of way network, and consideration of whether allocations for supported housing are necessary.

6. Libraries

6.1 In order to ensure deliverability of the Plan, it will need to be demonstrated that provision can be made to increase library service levels through developer contributions. The County Council is currently developing a more detailed plan for how library service provision will be developed in order to meet the demands of planned growth, in order to inform discussions on CIL spending.

7. Minerals and Waste Plans

7.1 At present, the County Council has no comments as the Minerals and Waste planning authority, but our authorities will need to work to ensure consistency between Plans. Our authorities should consider how we might encourage the sustainable use of minerals in situ, in advance of development, in order to reduce the need for extraction elsewhere and to reduce the highway impacts of construction.

8. Natural Environment

8.1 The County Council is interested in the ways in which this DPD can support the objectives of Suffolk's Nature Strategy, and would be pleased to work with the District Council to consider how this DPD could promote natural environment objectives, such as developing ecological networks. This is relevant in the context of the health and wellbeing strategy (as referred to elsewhere in this response), and the availability of accessible green space is important for mitigating impacts on European designated sites.

9. Public Rights of Way

9.1 The NPPF refers to a need for the planning system to protect and promote the public rights of way network. The Suffolk Health and Wellbeing Strategy includes 'access to a healthy environment' as a key objective. The Plan should consider how it will meet those challenges.

9.2 There is an opportunity to give detailed thought as to how the Plan can encourage healthy and sustainable travel, improve access to the countryside and open space, and to improve leisure and recreation opportunities. Officers from the County Council would be pleased to support the development of the plan in respect of these opportunities.

10. Surface Water Management

10.1 The County Council would be pleased to provide surface water flood records, to help consider the deliverability of sites and whether or not any specific policy measures will be required. SuDS principles should be applied as appropriate, in accordance with national standards, to enhance recharge of underground aquifers as well as provide surface water management and environmental features.

11. Transport

11.1 The County Council has previously provided comments on potential highway impacts arising from each site individually. It is not envisaged that these allocations will require a cumulative assessment of transport impacts.

12. Waste Provision

12.1 Suffolk Coastal, outside of the Felixstowe AAP area, is served by Household Waste Recycling Centres at Leiston, Felixstowe and Foxhall.

12.2 Whilst there are no proposals under consideration at the current time to change the service provided at the Leiston site, or indeed to move it, there is a recognition that the site does suffer from congestion at peak times. It is likely that the impact of development in the local area will increase pressure on the site and the County Council will be seeking developer contributions to fund improvements in the current site or to fund a replacement, should an alternative site come forward.

12.3 The Foxhall site will require a modification and change to existing planning permissions beyond 2021, if it is to remain on site it will need a partial rebuild for certain and, possibly, modifications to the vehicular access arrangements. If this is not possible a new site will need to be found in the area and before 2020 at the latest. CIL funding may be sought to support these projects.

13. Water Management, Flood and Coastal Defences

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6544 - 2581 - Hollesley - None 6544 Comment Woodbridge Housing Market Area Hollesley

13.1 Water resources are critical in the east of Suffolk, as recognised in Anglian Water's recently updated Water Resources Management Plan. Any measures that can be incorporated in new developments to capture/reuse/recycle water should be encouraged.

13.2 The recently finalised Deben Estuary Plan (and forthcoming Alde/Ore Estuary Plan) should be considered in relation to the development of this Plan - in the same way as the Suffolk Shoreline Management Plan. These plans rely upon a willingness to embrace the principle of an integrated system - recognising the need to reconcile the continued wellbeing of the river systems, the interests of the communities and the ecological integrity of unique estuarine environments.

13.3 The concept within these estuary plans, of 'enabling development', proposed as one possible mechanism for funding local flood defences, should be encouraged where proper infrastructure can also be provided.

13.4 Where appropriate development funding should be directed towards flood and coastal defences. Without local contributions of this type, many of our existing settlements will be at risk in the future.

Appendix: Likely Archaeological Assessment Requirements

East Ipswich Plan Area

Martlesham 900a. This site was covered under advice in 2008 for 703. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham 893. This site is close to areas of prehistoric activity (County Historic Environment Record MRM 154, MRM 027). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Westerfield 939. This site is close to the medieval core of the settlement, and within the findspot of Roman, Saxon and Iron Age objects. There is high potential for the development to impact on archaeological remains of these periods. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham EMP1 694 - previous recommendation for early archaeological assessment (sites 721/694/644).

Ransomes EMP2 - This large area (15ha) lies adjacent to a series of burnt pits (County Historic Environment Record PFM 009) and cropmark features of a pre-historic/Roman trackway and associated features to the east (PFM 085). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Framlingham

Wenhaston 938a. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Wenhaston 938b. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. The development also has a frontage onto one of the historic streets of the late Saxon and medieval settlement. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Yoxford 794. No objection in principle but it would any application should include an desk-based assessment and appraisal of structures currently existing on the site. Depending on the results of desk-based assessment, the site may require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham

Aldringham 5668. Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work. Development should be sensitive to the particular historic character of the built environment.

Benhall 969. This site is in a topographically favourable location for early activity overlooking the River Fromus. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6544 - 2581 - Hollesley - None 6544 Comment Woodbridge Housing Market Area Hollesley

work.

Blythburgh 4UCB. This site is in an area of very high archaeological potential within the historic core of Saxon and Medieval Blythburgh. The development fronts historic streets of the settlement. It has remained undeveloped in more recent periods (e.g. as shown on historic OS maps) and there is good potential for preservation of earlier archaeological remains. There could be complex remains surviving. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Blythburgh 3UCB Development on this site should be sympathetic to the historic farmstead, and development proposals should include assessments of historic buildings which are to be altered by the development so that informed decisions can be made. The site has archaeological potential, close to the existing 16th century building and within the historic core of Blythburgh. It would require a planning condition under the NPPF to secure a programme of archaeological work.

Kelsale cum Carleton 884 This site has not been systematically investigated for archaeological remains. It is in a topographically favourable valley side location, and should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Knodishall OPP5 This site lies within the historic settlement core, on the green edge, and development has the potential to impact upon early settlement remains. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Middleton 779 This site lies within the historic settlement core. A prehistoric ring ditch is recorded to the west (County Historic Environment Record MDD 004). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham 1006 This site is in an area of high archaeological potential overlooking the valley of the River Fromus. Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Saxmundham 1009 This site has been partially evaluated for archaeological remains (geophysical survey and some archaeological trial trenching). There are no grounds to object to development, but development will require a planning condition under the NPPF to secure a programme of archaeological work. This should include record of farm buildings, and further evaluation in the first instance. The results of evaluation will inform the overall archaeological investigation strategy.

Woodbridge

Aldeburgh 982 This large site is in an area of high archaeological potential, on a south facing slope overlooking the estuary and Aldeburgh marshes. Medieval archaeological remains are recorded to the north (County Historic Environment Record ADB 004), and Bronze Age to the west (ADB 002). Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Much of the site is within the area of brickworkings associated with the former Read's Brickworks. Desk- based assessment and geophysical survey in the first instance would establish the impacts of this previous landuse. There would be potential for promotion of the heritage of the area.

Hollesley 829 This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the southwest (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Hollesley 9UCH This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the northeast (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Information on buildings on the site should be submitted with any application, should they be impacted on by proposed development.

Hollesley 8UCH. This site lies within the historic core of Hollesley, opposite the church and with a street frontage that has high potential for archaeological remains relating to early settlement. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Early evaluation of the street frontage would be advisable so that archaeological investigation can be factored in to project designs. Evaluation has been carried out towards the rear of the site and did not reveal significant remains.

Orford OPP4 This site is close to a possible mound site (County Historic Environment Record ORF 023), and the site of a windmill depicted on a plan of c1600 (ORF 019). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6544 - 2581 - Hollesley - None 6544 Comment Woodbridge Housing Market Area Hollesley

investigation strategies. Geophysical survey would be appropriate in the first instance.

Shottisham 812b Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work.

Shottisham 812d Exact map location not provided, but the site is within the Anglo-Saxon and Medieval core of the settlement (County Historic Environment Record STT 059), close to the church. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Tunstall 786 - This site lies within and on the edge of the historic settlement core. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Any application should also include an assessment of buildings that are to be affected by development.

Woodbridge 900a - This site lies within an area of archaeological potential, and Neolithic pits and Iron Age features were excavated to the south (County Historic Environment Record MRM 030). The site should be subject to archaeological assessment at an appropriate stage in the design of new development to establish the impacts of past land-use, and ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Summary: Hollesley 8UCH. This site lies within the historic core of Hollesley, opposite the church and with a street frontage that has high potential for archaeological remains relating to early settlement. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Early evaluation of the street frontage would be advisable so that archaeological investigation can be factored in to project designs. Evaluation has been carried out towards the rear of the site and did not reveal significant remains.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6004 - 3065 - Orford - None 6004 Comment Woodbridge Housing Market Area Orford

Respondent: Historic (Mr Tom Gilbert-Wooldridge) Agent: N/A [3065]

Full Text: Suffolk Coastal Site Allocations and Area Specific Policies *

Thank you for your letter dated 12 December 2014 regarding the above consultation.

We would like to make the following comments:

Section 3: Housing

Q1: Do you have any thoughts on the approach to housing distribution that the Council has followed? The Council's approach to housing distribution, which follows a more considered approach to reflect the wide variety of settlement types and character and their needs and aspirations for future development, seems preferable to a more rigid approach of distributing housing equally between settlement types. However, it will require a careful and detailed analysis of settlements to ensure that distribution of housing is appropriate. The historic environment is a critical factor in this analysis in terms of considering the ability of settlements to accommodate new housing without undue harm to heritage assets. We hope that through the Strategic Housing Land Avaialbity Assessment (SHLAA) and Sustainability Appraisal (SA) processes that heritage impacts are properly considered when assessing sites. Our advice on assessing site specific proposals (see our SA letter of 12 December 2014) remains relevant.

Q3: Using the information in the Map Booklets, which housing sites are most appropriate?

* We have limited our assessment of sites to those settlements in Tables 2 to 6 where there is an indicative suggested housing allocation. We have used the map booklets for each housing market sub-area, and focused on those sites shown as "suitable" in the SHLAA.

Please note that due to time and resource constraints we have not been able to assess every site in great detail. Our comments on sites have been based on rapid desk-based analysis and limited site visits and we have not had the opportunity to ascertain precise impacts. We have focussed on those sites with the potential for the greatest historic environment impact. This does not mean there are no issues with any other site and we reserve the right to comment further on any site as and when proposals develop.

Please also note that we have not considered areas of archaeological interest beyond scheduled monuments in most cases, nor have we looked at historic landscape issues beyond registered historic parks & gardens. However, wider archaeological and landscape impacts are important considerations and need to be factored into site assessment. The possible cumulative impact of a number of site allocations in one location could cause significant harm to the historic landscape. Advice from conservation and archaeological staff at district and county levels should be sought, along with consultation of the Suffolk Historic Environment Record (HER) for specific heritage assets.

*

Martlesham Heath The SHLAA sites shown in Map 3 of the map booklet for Martlesham Heath (430, 517, 644 and 693) are not mentioned in the accompanying table. They appear to extend beyond the site boundary of the Adastral Park site. This is significant as the SHLAA sites include or adjoin a number of scheduled monuments to the south and east at Spratt's Plantation and Brightwell Heath. We have commented on historic environment issues in this location in relation to the Adastral Park applications. We would welcome clarification on the SHLAA sites and the intended allocations for Martlesham (notwithstanding the potential neighbourhood plan).

Westerfield Westerfield is a village centred on a cross roads with ribbon development along all four roads leading into the village, and with a number of proposed development sites. There is scope for some further infill frontage development along the roads leading into the village and site 939 would have no impact on the historic environment. The development indicated in front of Mill Farmhouse (Grade II) would result in some harm to the setting of this listed building. English Heritage is also concerned that development in depth on the east side of the road leading into the village from the south (sites 564 and 622) would harm the setting of the Grade I listed Church of St Mary Magdalene and the adjacent Grade II listed former Rectory. However, there may be scope for some frontage development to these sites along this road. The drainage ditch in the field containing site 622 may be of some historic interest and advice on this should be sought from the County Archaeologist on its archaeological potential.

To the north of the village there are three development sites proposed; 702a, 702b and 702c. Site 702c is modest in size and would have no impact on the historic environment. However, sites 702a and 702b both would adversely impact on the setting of an important group of listed buildings comprising the Grade II* Westerfield Hall, the Grade II Westerfield Hall Farm and the Grade II Swan's Nest. Currently this group of buildings are detached from the village and enjoy and open view out over the fields to the east. Development on site 702a would effectively bring them in to the

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6004 - 3065 - Orford - None 6004 Comment Woodbridge Housing Market Area Orford

village, while development on site 702b would be extremely harmful to their setting and block important views out from to the east.

The proximity of Westerfield to Ipswich and the Borough Council's proposed Ipswich Garden Suburb is an important consideration when looking at potential site allocations around the village. There could be considerable change to the wider setting of Westerfield and its heritage assets as a result of the garden suburb, and village allocations could have cumulative impacts. Given that the indicative allocation for Westerfield is only 10-20 dwellings, and there are a large number of 'suitable' sites in the village, we hope this amount can be accommodated without unacceptable harm to heritage assets.

*

Easton Easton is a linear village arranged along the valley floor, with the ground sloping steeply up to the northeast. Site 672a abuts the boundaries of the Easton Conservation Area and rises away from the road to encircle round behind the primary school. Development on this site would adversely impact on the setting of Verandah Cottages (Grade II listed) which lies immediately to the southeast of the site and there is also the potential for harm to the character and appearance of the conservation area through the new housing rising up the slope and being visually prominent along the skyline. Depending on the extent to which the development climbs up the hill, there is also the potential for it to impact on the setting of the moated scheduled site at Bentries Farm, which is on the higher ground above the village and has commanding views south back towards this site. The tall stacks on Verandah Cottages are currently clearly visible in these views.

Framlingham We note that the intention is for the indicative suggested housing allocation of 75-150 dwellings for Framlingham to be delivered through the emerging Neighbourhood Plan, and as such, the Map Booklet does not cover this settlement. However, it should be noted that Framlingham has a very rich historic environment, with many designated heritage assets including a conservation area centred on the historic core, multiple listed buildings and a large scheduled monument covering Framlingham Castle and its surroundings (the castle is also in the guardianship of English Heritage). We are very keen to engage in the Neighbourhood Plan as it evolves.

In terms of the SHLAA, we would welcome the opportunity to comment on Framlingham sites that might be considered 'suitable' and/or 'developable' to ensure that they are appropriate from a historic environment perspective.

Peasenhall Peasenhall is a linear village that follows the watercourse running parallel to the main road through the village. Site 400 is located adjacent to the boundaries of the conservation area, but a well-designed development that replicates the traditional relationship of cottages to the road might be acceptable. A conventional modern housing development of detached and semi-detached properties set in the middle of their plots would be harmful to the character and appearance of the conservation area. Therefore, if this site is to be pursued we would strongly recommend that a development brief is prepared to guide how development of this site should proceed.

Wenhaston Wenhaston is a village that has seen significant 20th century development; its historic centre is marked by a cluster of Grade II listed houses towards the northern end of the village, with the Grade I listed Church of St Peter sited on high ground immediately south of this cluster. A number of development sites are proposed in the village. Site 518 is away from the main part of the village and is unlikely to impact on the historic environment. Site 695 is a triangular site enclosed on two sided by 20th century housing and again will have no impact on the historic environment, though the southeastern boundary of this site is very prominent on the skyline in the approach to the village along Hall Road, and would therefore benefit from careful treatment.

Site 938b is of some concern to English Heritage. This is located immediately west of the cluster of Grade II houses that form the historic core of the settlement, and to the north of the Grade I listed church. The tower of the church is currently clearly visible across this site and development on this site would harm the setting of the Grade I church. Furthermore, Back Road and Bramfield Road that abut the site are narrow, traditional country lanes bounded by high hedgerows that would require significant change to support housing development. Such changes along Back Road in particular would again be harmful to the wider setting of the church. Site 938a is of less concern to English Heritage, though we would question whether it is suitable for development in depth and suggest that frontage development along Heath Road would be more appropriate. Site 733 is a triangular site at the northern end of the village where the land drops away, and the topography is such that a well-designed development would be unlikely to adversely impact on the setting of nearby heritage assets. Development of this site would also provide the opportunity to enhance the current rather scruffy appearance of the site's southern corner.

*

Aldeburgh Aldeburgh is an important historic settlement with a large number of heritage assets. Sites 608 and 982 are all remote from the historic core and are unlikely to adversely impact on any designated heritage assets.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6004 - 3065 - Orford - None 6004 Comment Woodbridge Housing Market Area Orford

Leiston We note that the intention is for the indicative suggested housing allocation of 250- 500 dwellings for Leiston to be delivered through the emerging Neighbourhood Plan, and as such, the Map Booklet does not cover this settlement. However, it should be noted that Leiston has a number of designated heritage assets, including a conservation area and several listed buildings, with the scheduled monument of Leiston Abbey situated to the north of the settlement (the abbey is also in the guardianship of English Heritage). We would wish to engage in the Neighbourhood Plan as it evolves.

In terms of the SHLAA, we would welcome the opportunity to comment on Leiston sites that might be considered 'suitable' and/or 'developable' to ensure that they are appropriate from a historic environment perspective.

Saxmundham Saxmundham is an important historic settlement that has seen extensive 20th century housing development, though most of this has been to the east of the High Street, on land running up to the A12. The Grade II* listed Church of St John the Baptist is located east of the High Street on Church Hill, which rises east away from the settlement. The church itself is prominent in views approaching the settlement from the south. It is noted that new housing has recently been completed on the site on the north side of Church Hill directly opposite the church and development of sites 1006 and 1009 would continue this precedent. However, development on the southern end of site 1009 would have the potential to adversely impact on the setting of the church. In particular the rising ground may place houses in the backdrop of the views of the church from the southwest. English Heritage therefore recommends that a landscaped buffer is retained at the southern end of site 1009 adjacent to Church Hill in order to protect the setting of the church.

*

Orford Orford is an important historic settlement with a large number of heritage assets, including an extensive conservation area, the Grade I listed Chruch of St Bartholomew and the Grade I listed and scheduled Orford Castle (the castle is also in the guardianship of English Heritage). Site OPP4 appears remote from the historic core and is unlikely to adversely impact on any designated heritage assets.

Woodbridge Woodbridge is an important historic settlement with a large number of heritage assets, including a several highly graded assets. Sites 635, 703, 900a and 7636 are all remote from the historic core and are unlikely to adversely impact on any designated heritage assets.

Section 4: The Economy

Q12: What do you consider to be the main issues which need to be addressed to ensure the Martlesham site remains successful into the future? The Martlesham Heath Business Campus (including Adastral Park) is a site we have commented on in recent years relating to the proposed redevelopment for employment and housing purposes. Our primary concern has been impact on a number of scheduled monuments consisting of pre-historic barrows at Spratt's Plantation, Brightwell Heath and beyond. Impact on the historic buildings and structures within the site (connected to the military use of the site) and on the wider historic landscape have also featured as concerns (for example, see our advice letters on the Adastral Park scheme from 2008 and 2009). Any redevelopment proposals for the Martlesham site will need to take the historic environment into account, with sufficient wording in any new or revised policies for this site.

Q14: Should the Ransomes Europark allocation be extended onto the land adjacent within the AONB? Extending the employment allocation into the AONB could have an impact on a number of scheduled monuments immediately to the east (and presumably affect the AONB itself). There are several pre-historic bowl barrows (burial sites) as part of the Seven Hills barrow cemetery. We strongly recommend that potential impacts on the significance and setting of these scheduled monuments is considered before any decision is made on extending the allocation.

Q18: Are there any tourist related matters that you would like to bring to our attention? We remain interested in proposals relating to Snape Maltings following our advice on various schemes over the years. We would welcome the updating of Policy AP166 providing that any revisions are compatible with the conservation of the site's heritage assets. The maltings are a sensitive historic site, with a conservation area and two listed buildings. Care will need to be taken that any updated policy still ensures the conservation and enhancement of these heritage assets, and we would be happy to comment on any emerging draft wording. We note the intention to delete Policy AP165 relating to an interpretative centre for

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6004 - 3065 - Orford - None 6004 Comment Woodbridge Housing Market Area Orford

East Lane Bawdsey connected to the military heritage of coastal defences in this location. The intention is to rely on the Core Strategy for any proposals in this location. We hope that this approach would ensure the conservation and enhancement of the various heritage assets in this location, including the Martello Towers.

We also note the perceived need (from town and parish councils) for improved visitor management in tourist hotspots such as Orford, with car parking identified as an issue. Any improvements to visitor management, including new car parks, should take into account potential impacts on the historic environment and specific heritage assets.

Q19: Given the definition of Main Town Centre uses in the NPPF, the unique character of the individual market town and the desire to see the town centres remain viable and vibrant areas into the future, do you think the town centre boundary as currently defined is the most appropriate? We do not have a strong view on the exact form of town centre boundaries, but consider that they are a useful tool to help with the vitality and viability of town centres. All of the district's town centres (including Felixstowe which is covered by the emerging Area Action Plan) have important historic environments with many heritage assets. Efforts to retain and enhance the vitality and viability of town centres should therefore conserve and enhance the historic environment. In 2013, we published a review of retail and town centre issues in historic areas, which may contain a number of relevant recommendations and case studies for this plan. The review can be downloaded from our website at: http://www.english-heritage.org.uk/professional/advice/advice-by-topic/heritage-and- growth/changingface-high-street/

Section 5: The Environment

Q26: Are there any buildings/groups of buildings that you would wish to nominate for consideration as non-listed heritage assets? We welcome the Council's commitment to producing a register of non-listed heritage assets. This should consider all heritage asset types, rather than just buildings (e.g. historic parks and gardens). While we do not have any specific nominations, we have produced advice on local listing to help with the selection and management of non-listed heritage assets, which can be found on our website at: http://www.englishheritage.org.uk/caring/listing/local/local- designations/local-list/

Beyond the issue of local listing and conservation area designation, it is unfortunate that the consultation document does not discuss the overall approach to the historic environment in this plan. Paragraph 126 of the National Planning Policy Framework states that: "local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment". The NPPF also states that local plans should include strategic policies to deliver the protection and enhancement of the historic environment (paragraph 156) and should identify land where development is inappropriate because of its environmental or historic significance (paragraph 157).

The Local Plan as a whole should be able to demonstrate that it sets out a positive strategy for the historic environment. This means that, on balance, the Local Plan has a positive effect on the historic environment and heritage assets. Different sections of the Local Plan should form part of the overall positive strategy, such as proposals for housing, regeneration, town centres or employment development. Policies throughout the Local Plan should help deliver the conservation of the historic environment with appropriate references where necessary. At the same time, a specific historic environment policy is encouraged as it helps to emphasise and implement the "positive strategy" required by the NPPF.

The Core Strategy does not have a specific historic environment policy, with certain aspects covered in other policies such as SP15 (Landscape and Townscape) and DM21 (Design Aesthetics) and policies for specific settlements. The saved policies from the old Local Plan again cover certain aspects such as conservation areas (Policy AP1) and historic parks and gardens (Policy AP4) or specific locations. There is a lack of a clear strategy relating to the historic environment at present, and we would encourage greater clarity. This should set out the Council's approach to the management of designated and non-designated heritage assets (including archaeology) and how issues such as heritage at risk will be tackled. We welcome the intention to retain and update Policies AP1 and AP4 from the old Local Plan, but this should be as part of wider review and update of the Council's approach to the historic environment.

We have attached a copy of our draft Good Practice Advice Note on the historic environment in Local Plans, which has been subject to public consultation in 2014 and should be published in its final form later this year (see: http://www.englishheritage.org.uk/publications/guidelines- and-standards/consultations/). We hope this is of assistance when drafting the next iteration of this plan. We would also be happy to discuss the Council's approach to the historic environment.

We hope that the above comments are of assistance. Please do not hesitate to contact me if you have any queries. We look forward to the next iteration of this plan. Summary: Orford is an important historic settlement with a large number of heritage assets, including an extensive conservation area, the Grade I listed Chruch of St

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6004 - 3065 - Orford - None 6004 Comment Woodbridge Housing Market Area Orford

Bartholomew and the Grade I listed and scheduled Orford Castle (the castle is also in the guardianship of English Heritage). Site OPP4 appears remote from the historic core and is unlikely to adversely impact on any designated heritage assets.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: gpa1-he-local-plans-consultation.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6390 - 2655 - Orford - None 6390 Comment Woodbridge Housing Market Area Orford

Respondent: Member of Parliament (MP) (Rt. Hon Therese Agent: N/A Coffey MP) [2655]

Full Text: Thank you for the opportunity to comment on the site allocations and area specific policies for the local plan. I think it is a welcome step to encourage all the public to participate in this early stage of the process. I only usually intervene on strategic issues and policies on planning.

While I have detailed my comments on some individual areas below, I have three particular issues to discuss - i) the imbalance of housing allocations around the area with the vast amount of development inserted east of the A12, the side of Suffolk that has the AONB and nearly all the SSSls; iii) the absence of nominated sites in Framlingham and Leiston; iii) building on main roads and the absence of infrastructure, particularly roads, for major and cumulative developments with the risk of significant congestion and longer journey times as well as community facilities.

Allocation of housing across the district

The vast majority of the proposed housing lies east of the A12 and to the south of the district. This continues to move the centre of gravity south east which runs the risk of excluding significant parts of our area of new housing for local people and also the lack of infrastructure (either new or upgraded). There appears to be a surprising disparity between settlements on where is deemed appropriate for further development and where is not. For example, no further housing is recommended for Wickham Market while Wenhaston, lower down the settlement hierarchy, has been recommended for more housing despite having just had an application for 26 new homes approved (higher than the Local Plan allocation of 5-15). Separately, Saxmundham has been recommended for further housing after a significant amount already built and under construction. I do not object specifically to that but will make the point later about infrastructure. There is little difference between Wickham Market, Saxmundham and Framlingham apart from the railway station. It has been suggested that Wickham Market has already had some housing so need not have any more and Framlingham has been allocated a small amount. That is in contrast to Leiston which has been allocated up to 500 houses, though with no additional infrastructure. The experience elsewhere does not bear that out. While it makes sense to allow for housing in villages and parishes as well as market towns but in a sensible proportion that does not dwarf existing villages. Therefore, I suggest that villages that have already had housing approved in the last two years should not have further sites specifically designated but allow for windfall, within the existing village envelope and not on main roads (like the A12 in Yoxford or A1120 in Peasenhall or the High Road in the Trimleys or the A144). It also should be on the same side of the main road as the local facilities - which would rule out nominated sites specifically in Yoxford and Woodbridge. We should not repeat the mistakes of the past. Another guiding principle should be that new housing is as close as possible to existing facilities. There is development planned on the opposite side of the main road to key facilities in some areas, which would significantly shift the centre of gravity and mean people having to cross busy roads to get to the centre. Shifting the centre of gravity of further development away from shops and facilities in towns, as may be the case in Saxmundham, is a retrograde step for enhancing the sense of community. The council must counter the risk of our small market towns becoming car-based, seeking shopping, leisure and sporting activities away from the town.

I strongly support the protection of green gaps, acting as strategic barriers between settlements.

There is an absence of nominated sites in Leiston and Framlingham. It has been suggested that this is due to emerging town plans but they should not have been absented from this consultation.

Finally, the absence of infrastructure. There is already huge pressure on various parts of the A12 and there is no indication of what infrastructure additions or upgrades are being proposed to accommodate such significant increases. In more specific terms,

i) Martlesham area with 2000 houses, adding to the increasing retail presence on the Martlesham Heath industrial estate. The latter is already leading to significant increases in traffic, coupled with further housing already under construction in Martlesham. Significant improvements need to be made to the A12 at several junctions. ii) Woods Lane roundabout and the A1152. There are already at least 15,000 traffic movements per day at the Melton railway crossing (sourced from Network Rail three years ago). Without substantial improvements to roads here, the additional housing suggested in Melton, Eyke and Rendlesham will bring even greater traffic movement pressure on the round about, the railway crossing and the traffic lights on the junction of the A1152/B1438. iii) Given the council's full support for the 4 villages bypass, it is surprising that no housing has been considered for this area as bypasses usually lead to significant increases in housing. Meanwhile, up to 500 houses are being proposed for Leisten but with no road improvements and no support for the potential D2 route being suggested in conjunction with Sizewell C. iv) In Saxmundham, a substantial number of new housing has already been built. While there has been minor modification of the traffic lights in the centre of the town, there has been no improvements planned to help traffic in and through the town. v) Woodbridge site at the football ground -addressing the congestion and the replacement of sporting facilities within the town area. vi) Local community infrastructure will need significant improvement - pace Rendlesham, Saxmundham, Leisten, the Trimleys and the new development at Martlesham. On local sites, I have commented by exception and no comment is not a sign of endorsement.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6390 - 2655 - Orford - None 6390 Comment Woodbridge Housing Market Area Orford

Woodbridge Housing Area

Campsea Ashe Site 557 is a very unusual place to add more housing especially if there is going to be work on the track for Sizewell C. I agree with 745 and 990 being unsuitable SHLAA sites. They are far too large and inappropriate. Eyke Agree that 991 and OPP7 are unsuitable sites. 991 looks to double size of village whereas Opp7 suggests substantial new housing along A-road which is unsuitable. Hollesley Agree that 825 is unsuitable - losing a significant amount of green field opposite school. Orford Agree that 494/484 & 976 is unsuitable. Surprised some sites proposed with sea levels. Tunstall Disagree that 786, 597 and 730 would all be suitable as a whole as seems to double the size of the village which is unnecessary over-development. Wickham Market Would support 7761 and 776i as it is a significant market town. Woodbridge Agree that sites 937 and 453 are unsuitable due to being west of the A12. 839,750,750a, 974 unsuitable due to pressure on roundabout.

Framlingham Housing Area

Bramfield Agree that 493 is unsuitable as it is too far away from the centre. Peasenhall Agree with 832 being unsuitable as outside the envelope and inappropriate. Wenhaston The village has already had a significant amount of development therefore I don't see the need for any further sites to be added. Strongly oppose any greenfield sites. Yoxford Strongly oppose accepted SHLAA sites 642b and 794. They are both opposite or adjacent to existing housing but involves crossing a main road to get to existing village facilities.

Saxmundham Housing Area

Aldeburgh Agree with unsuitable SHLAA sites in first map. Should continue to look for windfall sites. Strongly agree that 768 shouldn't be brought forward. Benhall Agree that 411b and 411c should not be brought forward. They would dwarf the village and would constitute overdevelopment. Blythburgh Disagree with 4UCB being brought forward as junction already very difficult and wouldn't cope. Darsham Agree that 378 and 967 are unsuitable as are considerably out of the village. Strongly disagree with 794 as it is too close to the main road and a strategic error. Dunwich Agree that 713 is unsuitable as is too far away from the village centre. Knodishall Agree that 506 which would dwarf the village, 579 which would significantly reduce the gap to Aldringham and 971 which would bring an unwarranted urban feel to that side of the village are unsuitable. Little Glemham 625 would put particular pressure on A12 which would require substantial highway change if it were to go ahead. Saxmundham Strongly agree that the non-hatched sites are unsuitable. Of the sites that have been endorsed 1006 and 1009, there is a risk of this development being too far away from the high street shift the centre of gravity. If this was to go ahead then there should be consideration for a relief road from the North entrance to the B1119. Snape Agree that 758 is unsuitable as too far out of the centre of the village. Westleton Agree with unsuitability of sites. Strongly oppose any development on 327 and 935.

Felixstowe Housing Area/Area Action Plan

Waldrlngfield Support 961 being a SHLAA unsuitable site. We need to protect this as a local gap. Bucklesham Most sites are too big and too far away from village centre. Kirton It is my understanding the Falkenham Road site has been backed in a local consultation session run by the Parish Council. Concerned about over development if all the other sites were approved. Trimley St Martin Agree that 920 and 889 are completely unsuitable. Trimley St Mary Concern that the current road network could cope with significant development on 383F. Agree with unsuitability of 383,c,d,e & 451e as too far away from centre. Summary: Orford Agree that 494/484 & 976 is unsuitable. Surprised some sites proposed with sea levels.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6545 - 2581 - Orford - None 6545 Comment Woodbridge Housing Market Area Orford

Respondent: Suffolk County Council (Mr Robert Feakes) [2581] Agent: N/A

Full Text: Site Allocations Document - Issues and Options Consultation Suffolk County Council Response

1. Introduction

1.1 Thank you for consulting Suffolk County Council on the above document. This response aims to set out the issues which our two authorities will need to resolve as this document is brought forwards towards adoption, rather than seeking to resolve issues now. Comments are set out in relation to Suffolk County Council service responsibilities and policy objectives; matters on which our authorities need to cooperate.

2. Air Quality and Noise Assessment

2.1 There are a number of locations within Martlesham that are adjacent to the A12, which include 710, 479, 721, 644, 693, 517, 430. The bunding adjacent to the A12 at sites 517/430, provided initially to protect Martlesham Heath residents from mineral working noise, should be retained as it has been designed (it is high enough) to provide a good level of protection from road traffic noise for any new dwellings behind it.

2.2 Developments adjacent to the A1214 through Kesgrave, eg. 774a and also the A1156 Felixstowe Road would all be subject to traffic noise as these routes carry significant volumes of traffic. Also locations at Ufford adjacent to the A12 to include 586, 838a and 838b and at Woodbridge for plots 937, 900a and 703. There a number of IAs along the A12 at Martlesham Heath and Woodbridge and should additional residential receptors be built adjacent to the route, these would be extended, potentially requiring this authority to fund mitigation provision. Similarly for other locations adjacent the A12 at Darsham, Kelsale, Little Glemham, Saxmundham and Yoxford.

2.3 There is an Air Quality Management Area (AQMA) in Woodbridge at the Lime Kiln Quay Road/Melton Hill junction. This should be viewed as a constraint and taken into account looking at the impacts of traffic growth through Woodbridge.

3. Archaeology

3.1 It is suggested that an informative section is considered which highlights the archaeology of the area and its management in the development process. The following is provided as an initial suggestion:

Suffolk Coastal has a rich, diverse and dense archaeological landscape with the river valleys, in particular, topographically favourable for early occupation of all periods. The distinctive character of the historic environment in the District includes upstanding coastal archaeology of all dates, prehistoric burial tumuli on the open heathlands around the eastern margins of Ipswich and on the Felixstowe peninsula, the remains of Roman small towns at Felixstowe and Wenhaston, the internationally important Anglo-Saxon burial ground at Sutton Hoo, numerous medieval historic towns and villages with both above and below ground heritage assets, for example Woodbridge and Aldeburgh, and the strategically placed, Napoleonic Martello towers. These are among over 7,300 sites of archaeological interest currently recorded in the Suffolk Historic Environment Record for Suffolk Coastal. Suffolk County Council Archaeological Service routinely advises that there should be early consultation of the Historic Environment Record and assessment of the archaeological potential of proposed sites at an appropriate stage in the design of new developments, in order that the requirements of the NPPF are met with regards to designated and non-designated heritage assets.

3.2 Suffolk County Council's archaeologists would be pleased to liaise with the District Council on wording, and provide more detailed information on archaeology on the area if required. To briefly clarify two points within the documents, heritage assets include Scheduled Monuments (paragraph 5.17) and non-designated heritage assets also include archaeological sites (paragraph 5.19).

3.3 For those sites which have not previously been commented on through the Strategic Housing Land Availability Assessment process, comments on likely archaeological assessment requirements are set out as an appendix to this letter.

4. Education (including Early Years)

4.1 In order to meet the requirements of Paragraph 72 of the National Planning Policy Framework, and to support community wellbeing (as described in paragraph 3.15 of the Core Strategy), this plan must ensure the delivery of sufficient education places to meet demand arising from housing growth. Government policy is that new provision made necessary as a result of demand arising from new housing should be funded from developer contributions; the County Council can only access funding to provide new places made necessary as a result of population growth arising from the existing housing stock.

4.2 In respect of the statutory requirement to provide 15 hours per week of early education for 3 - 4 year olds (and eligible 2 year olds), there is clearly a variation in levels of existing capacity across the District, which will impact on what additional provision is needed. For many of the parishes, the allocations indicated will not necessitate the provision of new Early Years settings, but contributions are still likely to be sought in many instances.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6545 - 2581 - Orford - None 6545 Comment Woodbridge Housing Market Area Orford

4.3 Those settlements with more significant development (Leiston, Saxmundham, Woodbridge, Aldeburgh and Framlingham) are more likely to require contributions towards additional provision. The County Council does not normally seek allocations of land for additional provision, given that provision is largely made through the private, voluntary and independent sector providers. However, should any new primary schools be required, it is expected that early education provision will be co-located with the new primary schools.

4.4 In terms of primary education, the distribution of housing is a key determining factor as regards what additional provision is needed. Our authorities also need to consider the long term resilience of the primary school system, and consider the likelihood that the forthcoming review of the Suffolk Core Strategy will result in the allocation of additional dwellings to the rural areas.

4.5 For much of the District, specifically in the rural areas, existing schools are likely to be able to absorb the low levels of growth proposed. However, this capacity cannot be considered as 'available' to absorb growth proposed in the market towns. Paragraph 38 of the NPPF emphasises the priority which should be given to locating key facilities in close proximity to housing. Assuming that children can attend schools a long distance from their homes will increase the need to travel, reduce the proportion of journeys undertaken by sustainable modes and place an ongoing cost on the public purse for home to school transport.

4.6 It appears that the level of growth proposed in Framlingham (75-150 dwellings) and Leiston (250-500 dwellings) can be accommodated in local schools on their existing sites, though developer contributions will be required in Framlingham at primary level and may be required in Leiston if development is at the larger end of the scale.

4.7 It also appears that the level of growth proposed in Saxmundham can be accommodated at local schools, albeit in a limited capacity. However, if further iterations of this document bring forward additional allocations in Saxmundham, it is unlikely that this growth could be accommodated at Saxmundham Primary School. Equally, the 'neighbouring' schools cannot accept further pupils from growth in Saxmundham (beyond that already agreed). Therefore, any further growth at Saxmundham will need to be accompanied with detailed consideration of how growth can be managed at primary school level. It may necessitate the development of a new primary school, which will necessarily be funded through Section 106 agreements.

4.8 Existing schools cannot accept growth indefinitely. If there is significant growth at Framlingham and Saxmundham, beyond that envisaged by this document, it is likely to be appropriate for the Local Plan to identify new school sites in these towns. This will help to minimise the risk of sending children to schools outside their own communities.

4.9 In regard to Woodbridge, it is important to better understand exactly where the housing is going to be. In considering current forecasts it appears that spaces would be available at Kyson and Melton in particular which, according to the SHLAA sites map, would be the local schools for the majority of the proposed housing. Significant housing growth within the catchments of St Marys and Woodbridge Primaries may prove problematic.

4.10 Development of 75-150 dwellings in Aldeburgh is expected to generate between 19 and 38 additional pupils (based on 25 pupils per 100 dwellings). Aldeburgh Primary School is consistently at capacity for the forecast period, and the school cannot be expanded on its current site. Whilst there is capacity at Leiston and Coldfair Green Primary Schools, sending pupils from Aldeburgh to these schools is undesirable and would need to be considered alongside growth in these parishes. If the District Council does intend to allocate housing at Aldeburgh, this will need to be the subject of early discussion.

4.11 Rendlesham Primary School has recently been expanded to 315 - places. Further expansion; which may be necessary to cope with 75-100 dwellings (19-25 pupils); would be challenging.

4.12 At secondary level, the allocations envisaged by this consultation document are likely to create additional demand at:

- Thomas Mills High School, - Saxmundham Free School, - Stradbroke High School - Debenham High School - Halesworth High School - Bungay High School - Alde Valley School - Farlingaye High School - Kesgrave High School

4.13 The scale of development proposed is not envisaged as being problematic at secondary level, with the exception of growth within the Farlingaye catchment. It appears that allocated growth within the Farlingaye catchment could be around 345 dwellings (or be fewer), meaning up to 62 pupils aged 11-16 and 14 pupils aged 16+. Farlingaye High School is already consistently over capacity, and it is not possible to expand the school on its current site. Should Adastral Park come forward in the near future, this creates an opportunity for delivering additional secondary school capacity, to take pressure off Farlingaye. However, our authorities need to discuss contingencies for managing this

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6545 - 2581 - Orford - None 6545 Comment Woodbridge Housing Market Area Orford

growth.

5. Health and Wellbeing

5.1 The County Council is keen to discuss the extent to which this document can promote the objective of the Suffolk Health and Wellbeing Strategy. Particular issues are access to the countryside and green space via the public rights of way network, and consideration of whether allocations for supported housing are necessary.

6. Libraries

6.1 In order to ensure deliverability of the Plan, it will need to be demonstrated that provision can be made to increase library service levels through developer contributions. The County Council is currently developing a more detailed plan for how library service provision will be developed in order to meet the demands of planned growth, in order to inform discussions on CIL spending.

7. Minerals and Waste Plans

7.1 At present, the County Council has no comments as the Minerals and Waste planning authority, but our authorities will need to work to ensure consistency between Plans. Our authorities should consider how we might encourage the sustainable use of minerals in situ, in advance of development, in order to reduce the need for extraction elsewhere and to reduce the highway impacts of construction.

8. Natural Environment

8.1 The County Council is interested in the ways in which this DPD can support the objectives of Suffolk's Nature Strategy, and would be pleased to work with the District Council to consider how this DPD could promote natural environment objectives, such as developing ecological networks. This is relevant in the context of the health and wellbeing strategy (as referred to elsewhere in this response), and the availability of accessible green space is important for mitigating impacts on European designated sites.

9. Public Rights of Way

9.1 The NPPF refers to a need for the planning system to protect and promote the public rights of way network. The Suffolk Health and Wellbeing Strategy includes 'access to a healthy environment' as a key objective. The Plan should consider how it will meet those challenges.

9.2 There is an opportunity to give detailed thought as to how the Plan can encourage healthy and sustainable travel, improve access to the countryside and open space, and to improve leisure and recreation opportunities. Officers from the County Council would be pleased to support the development of the plan in respect of these opportunities.

10. Surface Water Management

10.1 The County Council would be pleased to provide surface water flood records, to help consider the deliverability of sites and whether or not any specific policy measures will be required. SuDS principles should be applied as appropriate, in accordance with national standards, to enhance recharge of underground aquifers as well as provide surface water management and environmental features.

11. Transport

11.1 The County Council has previously provided comments on potential highway impacts arising from each site individually. It is not envisaged that these allocations will require a cumulative assessment of transport impacts.

12. Waste Provision

12.1 Suffolk Coastal, outside of the Felixstowe AAP area, is served by Household Waste Recycling Centres at Leiston, Felixstowe and Foxhall.

12.2 Whilst there are no proposals under consideration at the current time to change the service provided at the Leiston site, or indeed to move it, there is a recognition that the site does suffer from congestion at peak times. It is likely that the impact of development in the local area will increase pressure on the site and the County Council will be seeking developer contributions to fund improvements in the current site or to fund a replacement, should an alternative site come forward.

12.3 The Foxhall site will require a modification and change to existing planning permissions beyond 2021, if it is to remain on site it will need a partial rebuild for certain and, possibly, modifications to the vehicular access arrangements. If this is not possible a new site will need to be found in the area and before 2020 at the latest. CIL funding may be sought to support these projects.

13. Water Management, Flood and Coastal Defences

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6545 - 2581 - Orford - None 6545 Comment Woodbridge Housing Market Area Orford

13.1 Water resources are critical in the east of Suffolk, as recognised in Anglian Water's recently updated Water Resources Management Plan. Any measures that can be incorporated in new developments to capture/reuse/recycle water should be encouraged.

13.2 The recently finalised Deben Estuary Plan (and forthcoming Alde/Ore Estuary Plan) should be considered in relation to the development of this Plan - in the same way as the Suffolk Shoreline Management Plan. These plans rely upon a willingness to embrace the principle of an integrated system - recognising the need to reconcile the continued wellbeing of the river systems, the interests of the communities and the ecological integrity of unique estuarine environments.

13.3 The concept within these estuary plans, of 'enabling development', proposed as one possible mechanism for funding local flood defences, should be encouraged where proper infrastructure can also be provided.

13.4 Where appropriate development funding should be directed towards flood and coastal defences. Without local contributions of this type, many of our existing settlements will be at risk in the future.

Appendix: Likely Archaeological Assessment Requirements

East Ipswich Plan Area

Martlesham 900a. This site was covered under advice in 2008 for 703. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham 893. This site is close to areas of prehistoric activity (County Historic Environment Record MRM 154, MRM 027). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Westerfield 939. This site is close to the medieval core of the settlement, and within the findspot of Roman, Saxon and Iron Age objects. There is high potential for the development to impact on archaeological remains of these periods. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham EMP1 694 - previous recommendation for early archaeological assessment (sites 721/694/644).

Ransomes EMP2 - This large area (15ha) lies adjacent to a series of burnt pits (County Historic Environment Record PFM 009) and cropmark features of a pre-historic/Roman trackway and associated features to the east (PFM 085). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Framlingham

Wenhaston 938a. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Wenhaston 938b. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. The development also has a frontage onto one of the historic streets of the late Saxon and medieval settlement. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Yoxford 794. No objection in principle but it would any application should include an desk-based assessment and appraisal of structures currently existing on the site. Depending on the results of desk-based assessment, the site may require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham

Aldringham 5668. Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work. Development should be sensitive to the particular historic character of the built environment.

Benhall 969. This site is in a topographically favourable location for early activity overlooking the River Fromus. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6545 - 2581 - Orford - None 6545 Comment Woodbridge Housing Market Area Orford

work.

Blythburgh 4UCB. This site is in an area of very high archaeological potential within the historic core of Saxon and Medieval Blythburgh. The development fronts historic streets of the settlement. It has remained undeveloped in more recent periods (e.g. as shown on historic OS maps) and there is good potential for preservation of earlier archaeological remains. There could be complex remains surviving. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Blythburgh 3UCB Development on this site should be sympathetic to the historic farmstead, and development proposals should include assessments of historic buildings which are to be altered by the development so that informed decisions can be made. The site has archaeological potential, close to the existing 16th century building and within the historic core of Blythburgh. It would require a planning condition under the NPPF to secure a programme of archaeological work.

Kelsale cum Carleton 884 This site has not been systematically investigated for archaeological remains. It is in a topographically favourable valley side location, and should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Knodishall OPP5 This site lies within the historic settlement core, on the green edge, and development has the potential to impact upon early settlement remains. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Middleton 779 This site lies within the historic settlement core. A prehistoric ring ditch is recorded to the west (County Historic Environment Record MDD 004). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham 1006 This site is in an area of high archaeological potential overlooking the valley of the River Fromus. Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Saxmundham 1009 This site has been partially evaluated for archaeological remains (geophysical survey and some archaeological trial trenching). There are no grounds to object to development, but development will require a planning condition under the NPPF to secure a programme of archaeological work. This should include record of farm buildings, and further evaluation in the first instance. The results of evaluation will inform the overall archaeological investigation strategy.

Woodbridge

Aldeburgh 982 This large site is in an area of high archaeological potential, on a south facing slope overlooking the estuary and Aldeburgh marshes. Medieval archaeological remains are recorded to the north (County Historic Environment Record ADB 004), and Bronze Age to the west (ADB 002). Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Much of the site is within the area of brickworkings associated with the former Read's Brickworks. Desk- based assessment and geophysical survey in the first instance would establish the impacts of this previous landuse. There would be potential for promotion of the heritage of the area.

Hollesley 829 This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the southwest (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Hollesley 9UCH This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the northeast (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Information on buildings on the site should be submitted with any application, should they be impacted on by proposed development.

Hollesley 8UCH. This site lies within the historic core of Hollesley, opposite the church and with a street frontage that has high potential for archaeological remains relating to early settlement. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Early evaluation of the street frontage would be advisable so that archaeological investigation can be factored in to project designs. Evaluation has been carried out towards the rear of the site and did not reveal significant remains.

Orford OPP4 This site is close to a possible mound site (County Historic Environment Record ORF 023), and the site of a windmill depicted on a plan of c1600 (ORF 019). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6545 - 2581 - Orford - None 6545 Comment Woodbridge Housing Market Area Orford

investigation strategies. Geophysical survey would be appropriate in the first instance.

Shottisham 812b Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work.

Shottisham 812d Exact map location not provided, but the site is within the Anglo-Saxon and Medieval core of the settlement (County Historic Environment Record STT 059), close to the church. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Tunstall 786 - This site lies within and on the edge of the historic settlement core. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Any application should also include an assessment of buildings that are to be affected by development.

Woodbridge 900a - This site lies within an area of archaeological potential, and Neolithic pits and Iron Age features were excavated to the south (County Historic Environment Record MRM 030). The site should be subject to archaeological assessment at an appropriate stage in the design of new development to establish the impacts of past land-use, and ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Summary: Orford OPP4 This site is close to a possible mound site (County Historic Environment Record ORF 023), and the site of a windmill depicted on a plan of c1600 (ORF 019). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Geophysical survey would be appropriate in the first instance.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5613 - 3128 - Otley - None 5613 Support Woodbridge Housing Market Area Otley

Respondent: Mr Martin Price [3128] Agent: N/A

Full Text: Land Bounded by Helmingham Road and Ipswich Road, Otley

The Site

The site forms part of an agricultural field that lies at the junction of Helmingham Road and Ipswich Road, Otley. The whole field encompasses an area of approximately 3.0ha. The land the subject of this representation fronts Helmingham Road and is shown cross hatched on the attached plan. It extends to approximately 1ha in area. The defined physical limits boundary of Otley lies immediately to the south. A dwelling known as "The Bungalow" lies immediately to the north, with the White Hart public house lying approximately 45m to the north of the site's northern boundary.

Capacity

Given the edge of village location, it is suggested that a high density development would not be appropriate here and a capacity of between 15-20 dwellings would be appropriate. This equates to a density of between 15 & 20 dwellings per hectare.

Planning Considerations

* The site is well related to the physical limits boundary of the village. * It lies within the 30 mph zone. * Otley is a substantial settlement that is designated a 'key service centre' in the adopted Core Strategy . * The site lies within a reasonable walking distance of all the facilities/services that Otley has to offer. * The site is a gap within the ribbon development that stretches along Helmingham Road. * The site does not lie within any landscape designated area and its development would not result in any significant impact on the character of the wider landscape, or upon the landscaping setting of the village. * The site is not within an area identified as being of high flood risk. * Mains drainage and water connections are available in Helmingham Road close to the site. * Notwithstanding its rural location there are reasonable public transport links to Ipswich and the market towns.

The adopted Core Strategy identifies a minimum need for 7,900 new homes across the whole of the Suffolk Coastal District between 2010 and 2027. The Core Strategy advises that 1,350 (17%) of these will be provided with key and local service centres. In terms of new housing allocations, a minimum of 780 are expected to be within key and local service centres. This site provides an opportunity to contribute to that identified need within a highly sustainable settlement. It will also help to reinforce the sustainability of the settlement thereby helping to ensure the survival of existing services and facilities such as the post office, pub and school. Given the size of this site, development will include an element of affordable housing which is particularly important at a time when delivery of such housing is being restricted to larger sites in excess of 10 dwellings. The site is part of a larger field such that development here could be extended as a when future needs arise.

Conclusion

The site lies in a highly sustainable location and is well related to the existing village . It can be developed without any material adverse impact on interests of acknowledged importance. It is suitable for development, is available for development and can be delivered . It should therefore be allocated as such in the emerging Housing Allocations Document. Summary: The site forms part of an agricultural field that lies at the junction of Helmingham Road and Ipswich Road, Otley. The land fronts Helmingham Road and is shown cross hatched on the attached plan. It extends to approximately 1ha in area.he site lies in a highly sustainable location and is well related to the existing village . It can be developed without any material adverse impact on interests of acknowledged importance. It is suitable for development, is available for development and can be delivered . It should therefore be allocated as such in the emerging Housing Allocations Document.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments: Land fronting Helmingham Road Otley.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6045 - 3192 - Otley - None 6045 Object Woodbridge Housing Market Area Otley

Respondent: mr andrew graham [3192] Agent: N/A

Full Text: As your consultation site is not working I am sending you this objection to this site being allocated for housing on a number of grounds namely ,

1) This site is outside the village boundary . 2) The Hubbards site has 35 houses planned which would be a significant expansion of the village. There are some sites within the village boundary which are likely to become available which would also provide housing development opportunities. 3) Using the criteria used I wish to comment as follows :

a) 8 - This possible development would not enhance the quality of life for the residents on the East side of the site by increasing noise , light pollution and loss of amenity.Given its location I cannot see how it would enhance the quality of life for the village as a whole. b) 11- The logic used surprises me . How can a residential development conserve soil resources and quality ? Once a site is built on the soil is disturbed or concreted over soil conservation and quality preservation is not possible . Please also see my remarks below on possible contamination. c) 17- It would not conserve biodiversity , quite the opposite . There is a large bird population both nesting and transient . Recent sightings include Red Kites ,and a wide variety of smaller birds. Barn owls use the area for feeding and also there are two types of bat which feed there. There also may be a bat roost on the site . d) 19- I do not see the logic , as the frontage to the site is from the private road leading to Hubbards. The site is not visible form Helmingham road so I fail to see how this can be relevant as a criteria.

Development limitation :

This site was used as a timber fencing company , and timber yard from about 1971 to 2004. Before 2002 when the regulations changed some very toxic chemicals were used in timber preservation . It is unclear whether full scale timber treatment was carried out on site but at the very least it is likely that some preservative coating of timber was carried out even if it was only touch up . Some preservatives contained Lindane and Arsenical /coal tar compounds . There is evidence from many published studies that the leaching of preservative products and ground contamination from stored timber was commonplace . Regulations were changed and certain preservatives were banned about 2002 . However many studies from around the world including Defra show that even pressure treated timber stored in the open leaches toxic compounds such as CCAs and in some cases arsenic compounds into the soil over time when exposed to weathering . Some of the timber on site currently has been there for at least 10 years so the probability of contaminants being present in the soil on parts of the site is high . There are indications from the site ecology that there may be contamination in the soil over a good part of the site .

I would not buy a house on this site due to the risk of contamination leading to health issues particularly for children. The use of pressurised timber in raised beds is now regarded to be high risk for vegetable growing due to leaching of preservatives . If soil is disturbed by building work there would be some potential risk to other properties and residents health from contaminated soil in the form of dust.

To be fair some of the site probably was not used as timber storage and may uncontaminated.

Impact : Building on this site would not improve the landscape , would mean loss of trees mainly on the eastern side of the site and would mean a loss of biodiversity.

Environmental Conditions : development of this site would mean an increase in noise and light pollution particularly for the residential area on the eastern side of the site .

For all the above reasons I would submit that this is an unsuitable site and should not be allocated for housing development . Summary: 584: This site is outside the village boundary. The Hubbards site has 35 houses planned which would be a significant expansion of the village. There are some sites within the village boundary which are likely to become available which would also provide housing development opportunities. This site was used as a timber fencing company , and timber yard from about 1971 to 2004. It is unclear whether full scale timber treatment was carried out on site but at the very least it is likely that some preservative coating of timber was carried out even if it was only touch up

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6113 - 2865 - Otley - None 6113 Support Woodbridge Housing Market Area Otley

Respondent: Abbotts Countrywide (Mr Mark Haslam) [2865] Agent: N/A

Full Text: Otley Village Key Service Centre, Land Parcel 965, Land to the north of Otley House, Helmingham Road, Otley, Ipswich, Suffolk. IP6 9NR

On behalf of our clients, - Mr & Mrs Carter-Jonas, we write in respect of the above land parcel (965).

Our clients are currently looking at a possible scheme of development for part of the site, this being in a linear I road frontage arrangement, - the site area is edged red on the attached plan.

During the next 2 to 3 weeks, our clients will be submitting a Pre Planning Application Enquiry, which will set out the case for development.

Please could this site, both as a whole (1.25 Hectare), and in part (0.45 Hectare), continue to be included as part of your ongoing considerations for the final Development Plan Document. Summary: We write in respect of the above land parcel (965).

Our clients are currently looking at a possible scheme of development for part of the site, this being in a linear I road frontage arrangement-the site area is edged red on the attached plan.

During the next 2 to 3 weeks, our clients will be submitting a Pre Planning Application Enquiry, which will set out the case for development.

Please could this site, both as a whole (1.25 Hectare), and in part (0.45 Hectare), continue to be included as part of your ongoing considerations for the final Development Plan Document.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments: Drawing 1571-1.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6446 - 3047 - Otley - None 6446 Comment Woodbridge Housing Market Area Otley

Respondent: Otley Parish Council (Vanessa Osborne) [3047] Agent: N/A

Full Text: Site Allocations & Area Specific Policies Issues and Options document (December 2014)

Otley Parish Council has not met and discussed the Site Allocations and Area Specific LPD documents and have the following comments:

We are not aware of any further sites within the parish of Otley which should be considered as additional to those within the SHLAA and we continue to be in full agreement with the allocation of up to 35 houses on the brownfield site 318a, which already has outline planning permission and includes five small B1 units. We agree with the zero indicative suggested housing allocation as we feel that site 318a has more than fulfilled the quota of our key service centre and support strategic policy SP7 to protect local employment areas. We would be particularly keen to retain employment within this site as the current occupiers, Hubbards, who will vacate the land once sold, employ many local people.

We agree to the suggested physical limits and areas to be protected from development as shown on the map for Otley within the Map Booklet to accompany the Issues and Options Consultation and that saved policy AP28 should still apply to those areas protected. We believe there is already a conservation order placed on the garden of Moselle, within this area. We continue to request that site 318, currently deemed unsuitable for development, become marked as an area to be protected from future development under saved planning policy AP28 because it is prime agricultural land and is core to the natural and historic landscape, providing setting and backdrop to this historic church. This was logged on the council's database in 2009 as representation 934.

In line with strategic policy SP3 we fully support the importance to provide the right type, size and tenure of future housing. Otley Parish Council wishes it to be noted that the requirements for Otley would be smaller starter homes and lifetime homes, to include bungalows which is demonstrated within our Parish Plan 2009 (page 21 and pages 26 & 27) and also within a Consultation Statement 2013 from Planning Vocalism in support of the application for the redevelopment of HTG Trading (Hubbards) site 318a (pages 17 & 21).

Within section number 6 of the consultation document, Community & Wellbeing, Objective 15 - Physical and Community Infrastructure, Otley Parish Council would like to see some consideration given to the inclusion of charging units / hubs for electric cars within future developments that would be accessible to every member of the community to not only address current deficiencies but encourage and meet future needs for greener forms of transport.

We support the work of the Council to produce a list of non-designated Heritage Assets and would like to suggest our own for inclusion : Toad Hall, Church Road which has interesting and unusual architecture for the area, opposite St Mary's Church and also Garden Cottage, Church Road (adjacent Toad Hall) for its historic value as it was the village school until 1914.

We trust that our comments will be taken into consideration within the consultation and look forward to hearing from you in due course. Summary: We are not aware of any further sites within the parish of Otley which should be considered. We continue to be in agreement with the allocation of up to 35 houses on the brownfield site 318a, which has outline permission including five small B1 units. We agree with the zero indicative suggested housing allocation; we feel site 318a has more than fulfilled our quota. We support strategic policy SP7 to protect local employment areas. We would be particularly keen to retain employment within this site as the current occupiers, who will vacate the land once sold, employ many local people.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6186 - 483 - Rendlesham - None 6186 Comment Woodbridge Housing Market Area Rendlesham

Respondent: Anglian Water (Sue Bull) [483] Agent: N/A

Full Text: Thank you for the opportunity to comment on the Issues & Options Consultation document (December 2014).

Neighbourhood Plans Whilst Anglian Water (AW) has no comment to make on the neighbourhood area designation stage of a Neighbourhood Plan we are pleased to be consulted on the plans once they progress to draft plan stage. We are currently considering the Leiston Neighbourhood Plan and will make comment within the consultation period.

Felixstowe Area Action Plan Anglian Water are submitting representation on this consultation.

Site Allocations

Please find attached RAG spreadsheet summarising Anglian Water's comment on each site. It is important to note that this assessment does not take account of the cumulative impact of all the sites on the capacity of the Water Recycling Centres; the sites are assessed individually.

Asset Encroachment

Please note Sites 12ucl,13ucl,350,350b,408a,583a,672a,776i and 776L and WE04 are within the 400m consultation zone of the Water Recycling Centre (WRC) (formally referred to as Sewage or Wastewater Treatment Works). Initial assessment has indicated that there is an odour risk. Further discussion with Anglian Water is needed. Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage.

If a landowner or potential developer wishes to pursue an enquiry for development it is recommended they contact AW at the earliest opportunity to discuss the level of risk and the requirement for an odour risk assessment to be carried out.

Anglian Water does not want to thwart development or apply a blanket embargo on all development within 400 metres of our WRC, however we must balance this with protecting our new and existing customers from the risk of nuisance/loss of amenity whilst allowing us to provide the essential sewage treatment service to our customers and for this reason we take a risk based approach.

Similarly, development should be located a minimum of 15 metres from Pumping Stations to avoid the risk of nuisance/loss of amenity . With development proposals close to a foul pumping station,(site 693), it may be the layout of the site can be adjusted so as not to encroach on the 15 metre protection zone. The landowner/developer is advised to contact AW at the earliest opportunity to discuss.

Where there are sewers crossing the site, the site layout should be designed to take these into account; this existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The sewers should be located in highways or public open space. If it is not possible to accommodate the existing sewers within the design then diversion may be possible under section 185 of the Water Industry Act 1991 or entering into a build over/near agreement may be considered.

Details of Anglian Water encroachment policy can be viewed at: http://www.anglianwater.co.uk/developers/encroachment.aspx

Sewerage Network

The foul (or used water) flows from future growth will have an impact on the existing foul sewerage network. As outlined within the attached RAG sheet, upgrades to the network is likely to be required for a number of developments . The foul infrastructure requirements will be dependant on the location, size and phasing of the development.

We would want to see policy to ensure necessary infrastructure to serve allocations is planned and implemented before development proceeds (and dwellings occupied). To ensure this is carried through to a tactical level, we would at planning consent stage request the use of appropriate conditions to ensure infrastructure is in place before development is connected to the public sewerage network.

Surface Water and Flood Risk

Appropriate management of flood risk and the consideration of climate change is critical for long term resilience.

Whilst fluvial flooding is a significant constraint to the location of development, other forms of flooding such as surface water should be a consideration.

All developments should seek to reduce flood risk and incorporate Sustainable Drainage Systems (SuDS). We would

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6186 - 483 - Rendlesham - None 6186 Comment Woodbridge Housing Market Area Rendlesham

wish to see in policy that all developments should adhere to the surface water management hierarchy outlined in Part H of Building Regulations with disposal to a surface water sewer seen as a last resort. Under no circumstances will surface water be permitted to discharge to the public foul sewerage network and no new flow will be permitted to discharge to the combined network. We would want the document to clearly state that a surface water drainage solution will need to be identified and implemented prior to the construction of hard standing areas. The solution would need to be agreed with all stakeholders.

Engagement with developers

Anglian Water offers a pre planning service which includes a capacity check to determine the impact of sewerage from a proposed development. We will also work with the developer or land owner during this process to develop foul and surface water (where applicable) drainage solutions which will not cause a detriment to our existing or future customer. We would encourage the prospective developer to contact us at the earliest convenience to discuss drainage proposals to serve the development. Details regarding this service can be found at http://www.anglianwater.co.uk/developers/pre- planning-service-.aspx

Anglian Water are keep to engage with Suffolk Coastal District Council on Local Plan consultations and on individual planning applications. Summary: 350: Encroachment advisory zone for WRC - risk score 25, Sewers Crossing Site 350b: Encroachment advisory zone for WRC - risk score 0, Sewers Crossing Site 754: Some localised network enhancement may be required to receive FW

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: 5002_Suffolk_Coastal_allocation_-_sites_consultation_sheet_(RSP)_-_Jan-15(1).pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6266 - 2963 - Rendlesham - None 6266 Comment Woodbridge Housing Market Area Rendlesham

Respondent: Suffolk Coastal District Council (SCDC Agent: N/A Environmental Protection) [2963]

Full Text: LOCAL PLAN ISSUES AND OPTIONS CONSULTATION FELIXSTOWE AREA ACTION PLAN ISSUES AND OPTIONS DOCUMENT AND SITE ALLOCATIONS AND AREA SPECIFIC POLICIES ISSUES AND OPTIONS DOCUMENT

Head of Environmental Services and Port Health - Environmental Protection Comments

Thank you for your consultation regarding the above.

Further to my Memorandum dated 18th February 2015, please find comments regarding air quality matters detailed below.

Due to time constraints I have focussed on those SHLAA sites identified as 'suitable' at this time. Any other sites which come into play in the future, or any 'suitable' sites where different information comes forward, will need further input from Environmental Protection regarding air quality.

For any areas where there are a number of smaller applications (where they are under 0.25ha) the cumulative impacts on traffic flows will need to be taken into account. This also applies to any areas where there are both larger 'suitable' developments and smaller applications in proximity.

I understand that at the next stage of your process, as sites are firmed up, Planning Policy could place a formal recognition on selected individual sites to advise that anyone looking to develop them would need to produce an air quality assessment to accompany any planning application. Air quality assessments should be undertaken using current guidance produced by Environmental Protection UK (EPUK) and the Institute of Air Quality Management (IAQM). I have identified some plots at this stage which would benefit from this, mentioned in the lists below, and would be looking at this in more detail during the next round of your Consultation. I am unsure whether there is also the possibility to place other requirements on certain sites (such as need to produce a green travel plan, to provide car sharing facilities, cycle racks, bus stops etc) in order to prevent worsening of air quality within AQMAs and at any other locations which may be in danger of breaching the air quality objectives in the future should traffic flows increase? I would like to explore this further with you for the next round of Consultation.

Felixstowe Peninsula Area Action Plan

There is an AQMA declared at the Dooley Inn PH, Ferry lane, Felixstowe - close to Dock Gate 2 roundabout. This AQMA has been declared for annual mean levels of nitrogen dioxide due to emissions from and associated with the port of Felixstowe, including traffic on local roads. Any additional traffic produced in the vicinity of Dock gate 2 roundabout and Ferry Lane is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA and this should be considered when determining planning applications.

The Plan discusses a Felixstowe Logistics Park, to be developed by the Port of Felixstowe on sites within the perimeter of the Port. Any sites to be developed by the Port as part of this would need an air quality assessment to determine any impact on nitrogen dioxide levels within the declared Air Quality Management Area (AQMA) at Ferry Lane. My recommendation would be for the Port to make use of Dock Gate 1 over Dock gate 2 for access as this would keep additional traffic away from the AQMA.

Paragraph 6.9 of the Felixstowe Peninsula Area Action Plan discusses the declared AQMA at Ferry Lane, Felixstowe. It states that '... through the continued monitoring of the AQMA, the Council has the ability to ensure that Air Quality within these areas is not to the detriment of the environment or public health.' The continued monitoring of nitrogen dioxide levels within the AQMA allows us to determine what the levels are and whether they are increasing, decreasing or static, it does not in itself actually enable us to ensure that air quality is not detrimental. This is tackled by the statutory Air Quality Action Plan which has been produced for the AQMA - the aim of which is to protect Public Health only. Air quality affecting 'the environment' itself is not covered or tackled by the Local Air Quality Management process but will obviously be positively impacted upon.

Felixstowe and Trimleys * 451g - this borders the A14 and an air quality assessment would be required if this site was developed. A buffer zone alongside the A14 and Candlet Road should be considered in order to protect housing in the new development from being exposed to poor air quality. * 936 - this borders the A14 and an air quality assessment would be required if this site was developed. A buffer zone alongside the A14 and Candlet Road should be considered in order to protect housing in the new development from being exposed to poor air quality. * Sites 936, 383a, 451b, 451c, 451d, 383b, 383f, 451f and 607 within the Trimleys will need to have cumulative traffic effects considered with regard to air quality. Traffic from these sites travelling into Felixstowe using the route via High Street Trimley and not the A14 needs to be calculated and air quality impacts at the junction of High Road West and Garrison Lane will need to be determined. This junction has in recent times become more congested along the Trimley High Road West arm at peak times.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6266 - 2963 - Rendlesham - None 6266 Comment Woodbridge Housing Market Area Rendlesham

* Un-numbered 'unsuitable site', Dock Gate 1/Haven exchange roundabout. I realise that this site is marked as 'unsuitable' anyway but I need to make a specific comment here as if this site were to have housing it could introduce receptors to an area likely to be above the Objectives and become an AQMA. This would be due to the closeness to a heavily trafficked area.

Site Allocations and Area Specific Policies

Q12 asks 'What do you consider to be the main issues which need to be addressed to ensure the Martlesham site remains successful in the future?'. This area, including the A12, has changed considerably in recent times in terms of traffic with the introduction of the retail outlets Next, Pets at Home and M&S Food. Any future decisions regarding sites in this area will need to take account of current traffic flows and provide information on air quality impacts. In recognition of the latest court decision regarding the application for the BT site at Adastral Park, previous comments submitted by the Environmental Protection Team continue to apply, and it is important that any air quality assessments undertaken historically for this application are updated accordingly.

Q29 asks 'should there be further reference to AQMAs ?' Yes I do, and I am happy to work with you to determine what exactly needs to be included. Some initial thoughts are:

* Advising that the spatial planning system has an important role to play in improving air quality and reducing exposure to air pollution, both through the development of local planning policy and the determination of individual planning applications. * Possibly reference to each of the 3 AQMAs in respect of which Towns/Parishes could impact negatively on them through traffic increases. * Declaration of an AQMA does not mean there will be a complete ban on development within or close to that area. Rather it means that greater weight must be given to the consideration of air quality impacts and their mitigation from any developments. * Information regarding the production of Action Plans for each of the AQMAs which have measures included to try and reduce the pollutant of concern. * Statement to the effect that the Area Action Plans and any Neighbourhood Plans produced should be working in conjunction with the official Action Plans for each AQMA.

East of Ipswich Housing Market Sub-Area

Martlesham * 900a and 703 - there appears to be a buffer between the A12 and the housing to the north of this site. Consideration should be given to a similar buffer on this site so that new houses are not exposed to poor air quality. An air assessment would be required if this site was developed with specific reference to impacts on the Woodbridge AQMA.

* Adastral Park - previous comments submitted by the Environmental Protection Team continue to apply. It is important, however, that any air quality assessments undertaken historically for this application are updated accordingly due to the recent changes in traffic flows in this area.

Framlingham Housing Market Sub-Area

Framlingham * As Framlingham is to produce a Neighbourhood Plan there is no detail regarding specific sites here. It will be necessary as part of that plan to ensure that there are no air quality implications from cumulative traffic related to developments in Framlingham.

Saxmundham Housing Market Sub-Area There is an AQMA declared at Long Row on the A12 in . This AQMA has been declared for annual mean levels of nitrogen dioxide due to emissions from traffic on the A12. Any additional traffic produced from housing which would use this area of the A12 is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA and this should be considered when determining planning applications.

Stratford St Andrew * The suggested housing allocation is 0-10 but no SHLAA sites have been submitted or considered. Any sites for housing that would be exiting onto the A12 close to the declared AQMA (even if only for 1 or 2 houses) should consider air quality implications for the AQMA. This would not necessarily be in terms of numbers of vehicles but in terms of any traffic congestion they may cause in or near to the AQMA when entering/exiting onto the A12.

Saxmundham * 1006 and1009 - these sites are likely to use Church Street and its traffic lit junction with High Street, South Entrance and Chantry road. Traffic and congestion on Church Street and at this junction has increased in recent years due to the development of Waitrose, Tesco and other local retail outlets. These applications will need to have cumulative traffic effects considered and air quality impacts at the junction and on Church street will need to be determined.

Leiston

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6266 - 2963 - Rendlesham - None 6266 Comment Woodbridge Housing Market Area Rendlesham

* As Leiston is to produce a Neighbourhood Plan there is no detail regarding specific sites here. It will be necessary as part of that plan to ensure that there are no air quality implications from cumulative traffic related to developments in Leiston as the suggested allocation is 250-500. Any development will need to specifically include air quality impacts from cumulative effects of traffic generated by the construction of Sizewell C Power station once that application has been submitted.

Woodbridge Housing Market Sub-Area There is an AQMA declared within Woodbridge at the traffic lit junction of Lime Kiln Quay Road/Thoroughfare/St John's Street/Melton Hill. This AQMA has been declared for annual mean levels of nitrogen dioxide due to emissions from traffic using the junction. Woodbridge is the nearest shopping centre for a number of nearby Parishes (including those on the Peninsula), and the most likely route for traffic travelling from those parishes to the North and North-East into the shopping area is along the B1438 and through the declared AQMA. Any additional traffic produced by these parishes is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA in Woodbridge and this should be considered when determining planning applications.

Woodbridge * There are no 'suitable' sites for housing located within Woodbridge. There are a number of 'unsuitable sites' and smaller sites (less than0.25 ha) which could send additional traffic through the declared AQMA due to their location (459, 4169, 72361 and 5722). These will therefore have a negative impact on the AQMA and this should be considered. The same would apply for any windfall sites within Woodbridge which could put additional traffic through the AQMA.

Melton * As Melton is producing a Neighbourhood Plan there is no detail regarding specific sites here. Woodbridge is the nearest shopping centre to Melton, and the most likely route for traffic travelling from Melton into the shopping area is along the B1438 and through the declared AQMA. Any additional traffic produced by Melton parish is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA in Woodbridge and this should be considered.

Rendlesham * 350 (includes 676) and 754. Traffic accessing Woodbridge, one of the nearby shopping centres for Rendlesham, will do so along the B1438 and through the declared AQMA. Any additional traffic produced by Rendlesham parish is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA in Woodbridge and this should be considered. Summary: 350 (includes 676) and 754. Traffic accessing Woodbridge, one of the nearby shopping centres for Rendlesham, will do so along the B1438 and through the declared AQMA. Any additional traffic produced by Rendlesham parish is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA in Woodbridge and this should be considered.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5851 - 3294 - Shottisham - None 5851 Object Woodbridge Housing Market Area Shottisham

Respondent: Shottisham Parish Council (Mrs Sally Loader) Agent: N/A [3294]

Full Text: With reference to the parish survey attached, Councillors are unable to support development on either site at this time, but wish to register the results of the Housing Survey.

The council also have chosen the "suggested physical limits boundary" for Shottisham and also supports the implementation of the Deben estuary plan.

The Parish Council consider that no more than 6 houses should be allocated in this period. Summary: With reference to the parish survey attached, Councillors are unable to support development on either site at this time, but wish to register the results of the Housing Survey.

The council also have chosen the "suggested physical limits boundary" for Shottisham and also supports the implementation of the Deben estuary plan.

The Parish Council consider that no more than 6 houses should be allocated in this period.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: Housing Survey Analysis (1).pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6187 - 483 - Shottisham - None 6187 Comment Woodbridge Housing Market Area Shottisham

Respondent: Anglian Water (Sue Bull) [483] Agent: N/A

Full Text: Thank you for the opportunity to comment on the Issues & Options Consultation document (December 2014).

Neighbourhood Plans Whilst Anglian Water (AW) has no comment to make on the neighbourhood area designation stage of a Neighbourhood Plan we are pleased to be consulted on the plans once they progress to draft plan stage. We are currently considering the Leiston Neighbourhood Plan and will make comment within the consultation period.

Felixstowe Area Action Plan Anglian Water are submitting representation on this consultation.

Site Allocations

Please find attached RAG spreadsheet summarising Anglian Water's comment on each site. It is important to note that this assessment does not take account of the cumulative impact of all the sites on the capacity of the Water Recycling Centres; the sites are assessed individually.

Asset Encroachment

Please note Sites 12ucl,13ucl,350,350b,408a,583a,672a,776i and 776L and WE04 are within the 400m consultation zone of the Water Recycling Centre (WRC) (formally referred to as Sewage or Wastewater Treatment Works). Initial assessment has indicated that there is an odour risk. Further discussion with Anglian Water is needed. Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage.

If a landowner or potential developer wishes to pursue an enquiry for development it is recommended they contact AW at the earliest opportunity to discuss the level of risk and the requirement for an odour risk assessment to be carried out.

Anglian Water does not want to thwart development or apply a blanket embargo on all development within 400 metres of our WRC, however we must balance this with protecting our new and existing customers from the risk of nuisance/loss of amenity whilst allowing us to provide the essential sewage treatment service to our customers and for this reason we take a risk based approach.

Similarly, development should be located a minimum of 15 metres from Pumping Stations to avoid the risk of nuisance/loss of amenity . With development proposals close to a foul pumping station,(site 693), it may be the layout of the site can be adjusted so as not to encroach on the 15 metre protection zone. The landowner/developer is advised to contact AW at the earliest opportunity to discuss.

Where there are sewers crossing the site, the site layout should be designed to take these into account; this existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The sewers should be located in highways or public open space. If it is not possible to accommodate the existing sewers within the design then diversion may be possible under section 185 of the Water Industry Act 1991 or entering into a build over/near agreement may be considered.

Details of Anglian Water encroachment policy can be viewed at: http://www.anglianwater.co.uk/developers/encroachment.aspx

Sewerage Network

The foul (or used water) flows from future growth will have an impact on the existing foul sewerage network. As outlined within the attached RAG sheet, upgrades to the network is likely to be required for a number of developments . The foul infrastructure requirements will be dependant on the location, size and phasing of the development.

We would want to see policy to ensure necessary infrastructure to serve allocations is planned and implemented before development proceeds (and dwellings occupied). To ensure this is carried through to a tactical level, we would at planning consent stage request the use of appropriate conditions to ensure infrastructure is in place before development is connected to the public sewerage network.

Surface Water and Flood Risk

Appropriate management of flood risk and the consideration of climate change is critical for long term resilience.

Whilst fluvial flooding is a significant constraint to the location of development, other forms of flooding such as surface water should be a consideration.

All developments should seek to reduce flood risk and incorporate Sustainable Drainage Systems (SuDS). We would

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6187 - 483 - Shottisham - None 6187 Comment Woodbridge Housing Market Area Shottisham

wish to see in policy that all developments should adhere to the surface water management hierarchy outlined in Part H of Building Regulations with disposal to a surface water sewer seen as a last resort. Under no circumstances will surface water be permitted to discharge to the public foul sewerage network and no new flow will be permitted to discharge to the combined network. We would want the document to clearly state that a surface water drainage solution will need to be identified and implemented prior to the construction of hard standing areas. The solution would need to be agreed with all stakeholders.

Engagement with developers

Anglian Water offers a pre planning service which includes a capacity check to determine the impact of sewerage from a proposed development. We will also work with the developer or land owner during this process to develop foul and surface water (where applicable) drainage solutions which will not cause a detriment to our existing or future customer. We would encourage the prospective developer to contact us at the earliest convenience to discuss drainage proposals to serve the development. Details regarding this service can be found at http://www.anglianwater.co.uk/developers/pre- planning-service-.aspx

Anglian Water are keep to engage with Suffolk Coastal District Council on Local Plan consultations and on individual planning applications. Summary: 812b: Significant off-site sewergae required to connect into HOLLSC. Septicity control will be required. 812d: Significant off-site sewergae required to connect into HOLLSC. Septicity control will be required.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: 5002_Suffolk_Coastal_allocation_-_sites_consultation_sheet_(RSP)_-_Jan-15(1).pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6546 - 2581 - Shottisham - None 6546 Comment Woodbridge Housing Market Area Shottisham

Respondent: Suffolk County Council (Mr Robert Feakes) [2581] Agent: N/A

Full Text: Site Allocations Document - Issues and Options Consultation Suffolk County Council Response

1. Introduction

1.1 Thank you for consulting Suffolk County Council on the above document. This response aims to set out the issues which our two authorities will need to resolve as this document is brought forwards towards adoption, rather than seeking to resolve issues now. Comments are set out in relation to Suffolk County Council service responsibilities and policy objectives; matters on which our authorities need to cooperate.

2. Air Quality and Noise Assessment

2.1 There are a number of locations within Martlesham that are adjacent to the A12, which include 710, 479, 721, 644, 693, 517, 430. The bunding adjacent to the A12 at sites 517/430, provided initially to protect Martlesham Heath residents from mineral working noise, should be retained as it has been designed (it is high enough) to provide a good level of protection from road traffic noise for any new dwellings behind it.

2.2 Developments adjacent to the A1214 through Kesgrave, eg. 774a and also the A1156 Felixstowe Road would all be subject to traffic noise as these routes carry significant volumes of traffic. Also locations at Ufford adjacent to the A12 to include 586, 838a and 838b and at Woodbridge for plots 937, 900a and 703. There a number of IAs along the A12 at Martlesham Heath and Woodbridge and should additional residential receptors be built adjacent to the route, these would be extended, potentially requiring this authority to fund mitigation provision. Similarly for other locations adjacent the A12 at Darsham, Kelsale, Little Glemham, Saxmundham and Yoxford.

2.3 There is an Air Quality Management Area (AQMA) in Woodbridge at the Lime Kiln Quay Road/Melton Hill junction. This should be viewed as a constraint and taken into account looking at the impacts of traffic growth through Woodbridge.

3. Archaeology

3.1 It is suggested that an informative section is considered which highlights the archaeology of the area and its management in the development process. The following is provided as an initial suggestion:

Suffolk Coastal has a rich, diverse and dense archaeological landscape with the river valleys, in particular, topographically favourable for early occupation of all periods. The distinctive character of the historic environment in the District includes upstanding coastal archaeology of all dates, prehistoric burial tumuli on the open heathlands around the eastern margins of Ipswich and on the Felixstowe peninsula, the remains of Roman small towns at Felixstowe and Wenhaston, the internationally important Anglo-Saxon burial ground at Sutton Hoo, numerous medieval historic towns and villages with both above and below ground heritage assets, for example Woodbridge and Aldeburgh, and the strategically placed, Napoleonic Martello towers. These are among over 7,300 sites of archaeological interest currently recorded in the Suffolk Historic Environment Record for Suffolk Coastal. Suffolk County Council Archaeological Service routinely advises that there should be early consultation of the Historic Environment Record and assessment of the archaeological potential of proposed sites at an appropriate stage in the design of new developments, in order that the requirements of the NPPF are met with regards to designated and non-designated heritage assets.

3.2 Suffolk County Council's archaeologists would be pleased to liaise with the District Council on wording, and provide more detailed information on archaeology on the area if required. To briefly clarify two points within the documents, heritage assets include Scheduled Monuments (paragraph 5.17) and non-designated heritage assets also include archaeological sites (paragraph 5.19).

3.3 For those sites which have not previously been commented on through the Strategic Housing Land Availability Assessment process, comments on likely archaeological assessment requirements are set out as an appendix to this letter.

4. Education (including Early Years)

4.1 In order to meet the requirements of Paragraph 72 of the National Planning Policy Framework, and to support community wellbeing (as described in paragraph 3.15 of the Core Strategy), this plan must ensure the delivery of sufficient education places to meet demand arising from housing growth. Government policy is that new provision made necessary as a result of demand arising from new housing should be funded from developer contributions; the County Council can only access funding to provide new places made necessary as a result of population growth arising from the existing housing stock.

4.2 In respect of the statutory requirement to provide 15 hours per week of early education for 3 - 4 year olds (and eligible 2 year olds), there is clearly a variation in levels of existing capacity across the District, which will impact on what additional provision is needed. For many of the parishes, the allocations indicated will not necessitate the provision of new Early Years settings, but contributions are still likely to be sought in many instances.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6546 - 2581 - Shottisham - None 6546 Comment Woodbridge Housing Market Area Shottisham

4.3 Those settlements with more significant development (Leiston, Saxmundham, Woodbridge, Aldeburgh and Framlingham) are more likely to require contributions towards additional provision. The County Council does not normally seek allocations of land for additional provision, given that provision is largely made through the private, voluntary and independent sector providers. However, should any new primary schools be required, it is expected that early education provision will be co-located with the new primary schools.

4.4 In terms of primary education, the distribution of housing is a key determining factor as regards what additional provision is needed. Our authorities also need to consider the long term resilience of the primary school system, and consider the likelihood that the forthcoming review of the Suffolk Core Strategy will result in the allocation of additional dwellings to the rural areas.

4.5 For much of the District, specifically in the rural areas, existing schools are likely to be able to absorb the low levels of growth proposed. However, this capacity cannot be considered as 'available' to absorb growth proposed in the market towns. Paragraph 38 of the NPPF emphasises the priority which should be given to locating key facilities in close proximity to housing. Assuming that children can attend schools a long distance from their homes will increase the need to travel, reduce the proportion of journeys undertaken by sustainable modes and place an ongoing cost on the public purse for home to school transport.

4.6 It appears that the level of growth proposed in Framlingham (75-150 dwellings) and Leiston (250-500 dwellings) can be accommodated in local schools on their existing sites, though developer contributions will be required in Framlingham at primary level and may be required in Leiston if development is at the larger end of the scale.

4.7 It also appears that the level of growth proposed in Saxmundham can be accommodated at local schools, albeit in a limited capacity. However, if further iterations of this document bring forward additional allocations in Saxmundham, it is unlikely that this growth could be accommodated at Saxmundham Primary School. Equally, the 'neighbouring' schools cannot accept further pupils from growth in Saxmundham (beyond that already agreed). Therefore, any further growth at Saxmundham will need to be accompanied with detailed consideration of how growth can be managed at primary school level. It may necessitate the development of a new primary school, which will necessarily be funded through Section 106 agreements.

4.8 Existing schools cannot accept growth indefinitely. If there is significant growth at Framlingham and Saxmundham, beyond that envisaged by this document, it is likely to be appropriate for the Local Plan to identify new school sites in these towns. This will help to minimise the risk of sending children to schools outside their own communities.

4.9 In regard to Woodbridge, it is important to better understand exactly where the housing is going to be. In considering current forecasts it appears that spaces would be available at Kyson and Melton in particular which, according to the SHLAA sites map, would be the local schools for the majority of the proposed housing. Significant housing growth within the catchments of St Marys and Woodbridge Primaries may prove problematic.

4.10 Development of 75-150 dwellings in Aldeburgh is expected to generate between 19 and 38 additional pupils (based on 25 pupils per 100 dwellings). Aldeburgh Primary School is consistently at capacity for the forecast period, and the school cannot be expanded on its current site. Whilst there is capacity at Leiston and Coldfair Green Primary Schools, sending pupils from Aldeburgh to these schools is undesirable and would need to be considered alongside growth in these parishes. If the District Council does intend to allocate housing at Aldeburgh, this will need to be the subject of early discussion.

4.11 Rendlesham Primary School has recently been expanded to 315 - places. Further expansion; which may be necessary to cope with 75-100 dwellings (19-25 pupils); would be challenging.

4.12 At secondary level, the allocations envisaged by this consultation document are likely to create additional demand at:

- Thomas Mills High School, - Saxmundham Free School, - Stradbroke High School - Debenham High School - Halesworth High School - Bungay High School - Alde Valley School - Farlingaye High School - Kesgrave High School

4.13 The scale of development proposed is not envisaged as being problematic at secondary level, with the exception of growth within the Farlingaye catchment. It appears that allocated growth within the Farlingaye catchment could be around 345 dwellings (or be fewer), meaning up to 62 pupils aged 11-16 and 14 pupils aged 16+. Farlingaye High School is already consistently over capacity, and it is not possible to expand the school on its current site. Should Adastral Park come forward in the near future, this creates an opportunity for delivering additional secondary school capacity, to take pressure off Farlingaye. However, our authorities need to discuss contingencies for managing this

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6546 - 2581 - Shottisham - None 6546 Comment Woodbridge Housing Market Area Shottisham

growth.

5. Health and Wellbeing

5.1 The County Council is keen to discuss the extent to which this document can promote the objective of the Suffolk Health and Wellbeing Strategy. Particular issues are access to the countryside and green space via the public rights of way network, and consideration of whether allocations for supported housing are necessary.

6. Libraries

6.1 In order to ensure deliverability of the Plan, it will need to be demonstrated that provision can be made to increase library service levels through developer contributions. The County Council is currently developing a more detailed plan for how library service provision will be developed in order to meet the demands of planned growth, in order to inform discussions on CIL spending.

7. Minerals and Waste Plans

7.1 At present, the County Council has no comments as the Minerals and Waste planning authority, but our authorities will need to work to ensure consistency between Plans. Our authorities should consider how we might encourage the sustainable use of minerals in situ, in advance of development, in order to reduce the need for extraction elsewhere and to reduce the highway impacts of construction.

8. Natural Environment

8.1 The County Council is interested in the ways in which this DPD can support the objectives of Suffolk's Nature Strategy, and would be pleased to work with the District Council to consider how this DPD could promote natural environment objectives, such as developing ecological networks. This is relevant in the context of the health and wellbeing strategy (as referred to elsewhere in this response), and the availability of accessible green space is important for mitigating impacts on European designated sites.

9. Public Rights of Way

9.1 The NPPF refers to a need for the planning system to protect and promote the public rights of way network. The Suffolk Health and Wellbeing Strategy includes 'access to a healthy environment' as a key objective. The Plan should consider how it will meet those challenges.

9.2 There is an opportunity to give detailed thought as to how the Plan can encourage healthy and sustainable travel, improve access to the countryside and open space, and to improve leisure and recreation opportunities. Officers from the County Council would be pleased to support the development of the plan in respect of these opportunities.

10. Surface Water Management

10.1 The County Council would be pleased to provide surface water flood records, to help consider the deliverability of sites and whether or not any specific policy measures will be required. SuDS principles should be applied as appropriate, in accordance with national standards, to enhance recharge of underground aquifers as well as provide surface water management and environmental features.

11. Transport

11.1 The County Council has previously provided comments on potential highway impacts arising from each site individually. It is not envisaged that these allocations will require a cumulative assessment of transport impacts.

12. Waste Provision

12.1 Suffolk Coastal, outside of the Felixstowe AAP area, is served by Household Waste Recycling Centres at Leiston, Felixstowe and Foxhall.

12.2 Whilst there are no proposals under consideration at the current time to change the service provided at the Leiston site, or indeed to move it, there is a recognition that the site does suffer from congestion at peak times. It is likely that the impact of development in the local area will increase pressure on the site and the County Council will be seeking developer contributions to fund improvements in the current site or to fund a replacement, should an alternative site come forward.

12.3 The Foxhall site will require a modification and change to existing planning permissions beyond 2021, if it is to remain on site it will need a partial rebuild for certain and, possibly, modifications to the vehicular access arrangements. If this is not possible a new site will need to be found in the area and before 2020 at the latest. CIL funding may be sought to support these projects.

13. Water Management, Flood and Coastal Defences

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6546 - 2581 - Shottisham - None 6546 Comment Woodbridge Housing Market Area Shottisham

13.1 Water resources are critical in the east of Suffolk, as recognised in Anglian Water's recently updated Water Resources Management Plan. Any measures that can be incorporated in new developments to capture/reuse/recycle water should be encouraged.

13.2 The recently finalised Deben Estuary Plan (and forthcoming Alde/Ore Estuary Plan) should be considered in relation to the development of this Plan - in the same way as the Suffolk Shoreline Management Plan. These plans rely upon a willingness to embrace the principle of an integrated system - recognising the need to reconcile the continued wellbeing of the river systems, the interests of the communities and the ecological integrity of unique estuarine environments.

13.3 The concept within these estuary plans, of 'enabling development', proposed as one possible mechanism for funding local flood defences, should be encouraged where proper infrastructure can also be provided.

13.4 Where appropriate development funding should be directed towards flood and coastal defences. Without local contributions of this type, many of our existing settlements will be at risk in the future.

Appendix: Likely Archaeological Assessment Requirements

East Ipswich Plan Area

Martlesham 900a. This site was covered under advice in 2008 for 703. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham 893. This site is close to areas of prehistoric activity (County Historic Environment Record MRM 154, MRM 027). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Westerfield 939. This site is close to the medieval core of the settlement, and within the findspot of Roman, Saxon and Iron Age objects. There is high potential for the development to impact on archaeological remains of these periods. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham EMP1 694 - previous recommendation for early archaeological assessment (sites 721/694/644).

Ransomes EMP2 - This large area (15ha) lies adjacent to a series of burnt pits (County Historic Environment Record PFM 009) and cropmark features of a pre-historic/Roman trackway and associated features to the east (PFM 085). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Framlingham

Wenhaston 938a. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Wenhaston 938b. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. The development also has a frontage onto one of the historic streets of the late Saxon and medieval settlement. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Yoxford 794. No objection in principle but it would any application should include an desk-based assessment and appraisal of structures currently existing on the site. Depending on the results of desk-based assessment, the site may require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham

Aldringham 5668. Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work. Development should be sensitive to the particular historic character of the built environment.

Benhall 969. This site is in a topographically favourable location for early activity overlooking the River Fromus. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6546 - 2581 - Shottisham - None 6546 Comment Woodbridge Housing Market Area Shottisham

work.

Blythburgh 4UCB. This site is in an area of very high archaeological potential within the historic core of Saxon and Medieval Blythburgh. The development fronts historic streets of the settlement. It has remained undeveloped in more recent periods (e.g. as shown on historic OS maps) and there is good potential for preservation of earlier archaeological remains. There could be complex remains surviving. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Blythburgh 3UCB Development on this site should be sympathetic to the historic farmstead, and development proposals should include assessments of historic buildings which are to be altered by the development so that informed decisions can be made. The site has archaeological potential, close to the existing 16th century building and within the historic core of Blythburgh. It would require a planning condition under the NPPF to secure a programme of archaeological work.

Kelsale cum Carleton 884 This site has not been systematically investigated for archaeological remains. It is in a topographically favourable valley side location, and should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Knodishall OPP5 This site lies within the historic settlement core, on the green edge, and development has the potential to impact upon early settlement remains. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Middleton 779 This site lies within the historic settlement core. A prehistoric ring ditch is recorded to the west (County Historic Environment Record MDD 004). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham 1006 This site is in an area of high archaeological potential overlooking the valley of the River Fromus. Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Saxmundham 1009 This site has been partially evaluated for archaeological remains (geophysical survey and some archaeological trial trenching). There are no grounds to object to development, but development will require a planning condition under the NPPF to secure a programme of archaeological work. This should include record of farm buildings, and further evaluation in the first instance. The results of evaluation will inform the overall archaeological investigation strategy.

Woodbridge

Aldeburgh 982 This large site is in an area of high archaeological potential, on a south facing slope overlooking the estuary and Aldeburgh marshes. Medieval archaeological remains are recorded to the north (County Historic Environment Record ADB 004), and Bronze Age to the west (ADB 002). Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Much of the site is within the area of brickworkings associated with the former Read's Brickworks. Desk- based assessment and geophysical survey in the first instance would establish the impacts of this previous landuse. There would be potential for promotion of the heritage of the area.

Hollesley 829 This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the southwest (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Hollesley 9UCH This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the northeast (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Information on buildings on the site should be submitted with any application, should they be impacted on by proposed development.

Hollesley 8UCH. This site lies within the historic core of Hollesley, opposite the church and with a street frontage that has high potential for archaeological remains relating to early settlement. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Early evaluation of the street frontage would be advisable so that archaeological investigation can be factored in to project designs. Evaluation has been carried out towards the rear of the site and did not reveal significant remains.

Orford OPP4 This site is close to a possible mound site (County Historic Environment Record ORF 023), and the site of a windmill depicted on a plan of c1600 (ORF 019). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6546 - 2581 - Shottisham - None 6546 Comment Woodbridge Housing Market Area Shottisham

investigation strategies. Geophysical survey would be appropriate in the first instance.

Shottisham 812b Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work.

Shottisham 812d Exact map location not provided, but the site is within the Anglo-Saxon and Medieval core of the settlement (County Historic Environment Record STT 059), close to the church. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Tunstall 786 - This site lies within and on the edge of the historic settlement core. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Any application should also include an assessment of buildings that are to be affected by development.

Woodbridge 900a - This site lies within an area of archaeological potential, and Neolithic pits and Iron Age features were excavated to the south (County Historic Environment Record MRM 030). The site should be subject to archaeological assessment at an appropriate stage in the design of new development to establish the impacts of past land-use, and ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Summary: Shottisham 812b Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work.

Shottisham 812d Exact map location not provided, but the site is within the Anglo-Saxon and Medieval core of the settlement (County Historic Environment Record STT 059), close to the church. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5707 - 2851 - Tunstall - i 5707 Object Woodbridge Housing Market Area Tunstall

Respondent: Tunstall Parish Council (ms Sarah Corbett) [2851] Agent: N/A

Full Text: Tunstall already is over its quota with recent development at the Maltings and the forthcoming application for 33 houses on Ashe Road. As well as building on AONB areas outside the village envelope, these open spaces constitute some of the only remaining green spaces in the main village. I disagree with point 8, that it will approve quality of life as removing green spaces and building on AONB land to replace with houses does not suggest a life enhancing move to me. In particular, the land adjacent to the Red House is close to a very dangerous junction with Snape Road and attempts to make this safe (eg mini roundabout) would significantly alter the character of the village. This also applies to the four way junction at Ashe Road/orford Road/School Road/ Woodbridge Road, which is already likely to have increased traffic with the new development on Ashe Road and Sizewell C traffic. Tunstall has no school, no shop, regular flooding, and a huge amount of traffic coming through the village. I also feel that point 3 that it would reduce crime and antisocial behaviour is laughable. Apart from the fact that crime is negligible, we are not yet a village where kids hang around drinking cheap cider on street corners. However, build yet more housing in a village with no resources for them, and quite understandably, the street corners may be the only places they have to go. Short term employment is created, but this can be created by building on more suitable sites and is not dependent on building on AONB land. In short, the very few positives are outweighed by negatives beyond those written on the summary. Summary: Tunstall is expecting to have way in excess of 20 houses built in the next few years without considering these sites. There is insufficient infrastructure; the village would need new road layouts which would irreparably alter its character; negligible crime is unlikely to be reduced, nor is building on some of the few remaining green spaces likely to make people feel better about life, particularly on the Orford Road site where schedule 1 birds are frequently seen (and should not be disturbed).

Change to Plan Add comment that village has easily exceeded its quota of housing with current proposals in development. Acknowledge that crime in the village (not the forest) is not currently an issue anyway Acknowledge that village life is likely to be enhanced by open space more than by extra houses and that few open spaces in the village centre remain List the village resources (or lack thereof) Amend flooding statement to reflect the fact that the roads flood here several times a year (suggest a visit after heavy rain?)

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified No No Yes i

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5744 - 3250 - Tunstall - None 5744 Object Woodbridge Housing Market Area Tunstall

Respondent: Mrs Susan Dalziel [3250] Agent: N/A

Full Text: 597/730 access to both these sites unacceptable due to high volume traffic on both woodbridge and `orford roads. there is already a serious sewage problem on Orford Rd, any further development will increase this. The proposed planning for 33 houses on Ashe Rd. more than fulfills Tunstalls' obligation for further housing there is simply not the infrastructure to support more. Areas of open space in rural villages are to be cherished. Summary: 597/730 access to both these sites unacceptable due to high volume traffic on both woodbridge and `orford roads. there is already a serious sewage problem on Orford Rd, any further development will increase this. The proposed planning for 33 houses on Ashe Rd. more than fulfills Tunstalls' obligation for further housing there is simply not the infrastructure to support more. Areas of open space in rural villages are to be cherished.

Change to Plan No more housing.

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Yes Yes Yes None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5754 - 3055 - Tunstall - None 5754 Support Woodbridge Housing Market Area Tunstall

Respondent: Evolution Town Planning (Mr Steven Bainbridge) Agent: N/A [3055]

Full Text: 1.0 Executive Summary 1.1 Our client's site is well placed to provide housing development in Tunstall village over the plan period to 2027 and beyond to 2031. It is available for development in the short term or can be phased to meet the various phases of the local plan. It is capable of providing housing to meet local needs such as affordable housing for local people or bungalows for retirees wishing to downsize while remaining in the village. 1.2 This potential is increased if the site is considered in conjunction with two neighbouring sites. 1.3 The three sites combined would have a superior relationship to the existing settlement boundary when compared to other potential development sites in the village. Such a combined site would also have the benefit of two existing vehicular accesses. 1.4 Other sites in the village are either less well related to the settlement boundary than this group, or may have ownership issues making them unavailable as proposed. 1.5 The potential group of sites including our client's site is large enough to provide for Tunstall's future housing needs plus areas of open space linked to the existing footpath. 1.6 With two existing access onto Snape Road, development off this group of sites could enabled the 30 mph zone to be extended northwards past our client's site and thereby reducing the speed of vehicles entering Tunstall from the north. 1.7 Our client is willing to consider a joint approach with neighbouring land owners who are also promoting their land as we consider this provides the best opportunity for development allocation in Tunstall to meet future housing needs.

2.0 Introduction 2.1 Evolution Town Planning LLP have been instructed by the Estate of the late Derek Ling to make further representations to Suffolk Coastal District Council (SCDC) in respect of land at Tunstall (SCDC site ref. 983) for housing in the new local plan. 2.2 These representations are submitted to the Issues and Options consultation and follow on from representations made in July 2013 (our ref. E148.C1.Rep01) and should be read in conjunction with them. 2.3 The site is shown edged red in the inset map below and in Appendix 1. 3.0 Description of the Site and its Surroundings 3.1 The site is located to the northeast of Tunstall and is accessed via an existing vehicular access onto Snape Road (B1069) on the eastern side of the site. 3.2 The site adjoins the settlement boundary of Tunstall on its western boundary. 3.3 The site is currently unused but was previously used by the late owner to store agricultural machinery and pens for game birds with a number of structures evident on the Ordnance Survey base map. This can be seen on a Google Earth aerial photo dated December 2000: 3.4 A later Google Earth aerial photo dated December 2007 shows the site stripped and cleared of these structures: (See attached document) 3.5 The latest Google Earth aerial photo dated May 2011 shows the site as it is now; rough grassland and vegetation growth giving the site an overtly 'green' appearance: 3.6 Despite this overtly 'green' appearance the site appeared from our previous site visits to be of little ecological value. 3.7 The aerial photos show that the site is bounded to the north by agricultural land, to the west and east by residential development and to the south by other sites submitted to the Council for development allocation (site no.s 765 and 509). 3.8 The northern boundary of the site benefits from an established hedge and tree boundary which provides excellent screening to view from open countryside to the north. 3.9 The site is located outside of the AONB. A footpath exists within the site on the northern boundary but would be unaffected by development and would be retained for the future. 3.10 The parish of Tunstall has a population of 513 people and 215 households (2011 Census). Tunstall village is a local service centre in the District Council's settlement hierarchy meaning it is a sustainable village that will see housing growth in the future. 3.11 Tunstall is linked to the nearby larger Key Service Centres of Rendlesham and Snape, and the Market towns of Woodbridge and Aldeburgh, and beyond to Ipswich via the hourly no. 65 bus route (see bus timetable in Appendix 2).

4.0 Site Constraints and Opportunities 4.1 There are no known planning or environmental constraints to development of our client's site. It is not in flood zones 2 or 3 and there is no known history of surface water flooding. 4.2 The site is not within the AONB and does not host a SSSI. It is not within a conservation area and the nearest listed building is Grade 2 and approximately 100m to the south. 4.3 Site 765 is described in the Tunstall map book as unsuitable for development because it is allotments but this is incorrect. From a review of the Google Earth aerial photos the site has not hosted allotments since at least the year 2000 and earlier SHLAA documents refer to this site as former allotments. 4.4 Unlike SCDC sites 786 and 597 which are in active uses this site is not used which makes it a better choice because it is immediately available for development if allocated. 4.5 Site 509 abuts the settlement boundary on its southern side. It is described in the Tunstall map book as being poorly related to the village despite having a larger boundary with the village settlement boundary than other sites deemed to be well related. 4.6 As a group our client's site and sites 765 and 509 adjoin the settlement boundary on three sides and have two vehicular accesses onto Snape Road.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5754 - 3055 - Tunstall - None 5754 Support Woodbridge Housing Market Area Tunstall

4.7 These accesses onto the B1069 are within short distance of the 30mph zone. Development of this group of sites could provide for the extension of the 30mph zone northwards along Snape Road, helping to reduce traffic speeds as vehicles enter Tunstall from the northeast. 4.8 These sites, as a group, are better related to the village than site 786 which protrudes into the open countryside on the village's northern boundary. 4.9 Development of this group, reinforced by the landscape mitigation provided by the northern boundary of our client's site would provide for a logical and defensible allocation for the village.

5.0 Proposed Use and Assessment of Development Potential 5.1 The village of Tunstall is characterised by a mixture of development densities; mostly lower density, and typically by 3+ bedroom detached houses (2011 Census). 5.2 We are proposing our client's site for low density residential development . 5.3 This means that although a site of this size might otherwise accommodate up to 30 dwellings a lower figure of 20 is considered more appropriate to reflect the existing settlement pattern of Tunstall. 5.4 This figure of 20 dwellings could be provided across sites 509, 756 and 983 as a group. The adjacent residential development of Tunstall Green to the west provides an example of the development density that may be appropriate. 5.5 Development of our client's site on its own could deliver 6 affordable dwellings for Tunstall secured by legal agreement and to meet the needs of the village and those who wish to live in Tunstall but cannot do so. 5.6 This would include retirees wishing to down size or first time buyers who have been raised in the area but cannot afford to buy in the village.

6.0 Answers to Consultation Questions 6.1 The following section provides answers to relevant questions in the Issues and Options consultation document. Q1. Do you have any thoughts on the approach the Council has followed? Is there an alternative approach that you think should be considered for the more detailed distribution of housing in the Market Towns and Key and Local Service Centres set out in the Core Strategy and why? 6.2 Page 14 of the Issues and Options consultation document states that 'Approach 1' was "rejected when the broad scale and distribution of housing was adopted through the Core Strategy". It also states that 'Approach 2' is "the one which has been used" in the Core Strategy and the Issues and Options documents "reflects this approach". 6.3 The Core Strategy was adopted in July 2013 and post -dated the National Planning Policy Framework (the Framework). However subsequent National Planning Practice Guidance (the PPG) has been issued which 'Approach 2' does not conform to. 6.4 Specifically the PPG states: 6.5 "It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability, and the role of housing in supporting the broader sustainability of villages and smaller settlements. This is clearly set out in the National Planning Policy Framework, in the core planning principles, the section on supporting a prosperous rural economy and the section on housing. 6.6 A thriving rural community in a living, working countryside depends, in part, on retaining local services and community facilities such as schools, local shops, cultural venues, public houses and places of worship. Rural housing is essential to ensure viable use of these local facilities. 6.7 Assessing housing need and allocating sites should be considered at a strategic level and through the Local Plan and/or neighbourhood plan process. However all settlements can play a role in delivering sustainable development in rural areas and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided unless their use can be supported by robust evidence." 6.8 Approach 2 leads to many Key and Local Service Centres having a residual housing requirement of zero. This is the case in Tunstall. 6.9 For villages to sustain themselves for the lifetime of the plan period to 2027 it is important for some land to be allocated in the plan. 6.10 The amount of residual allocation could, for local service centres, be low at around 10% of existing housing stock for example. 6.11 This would allow for future development to come forward during the plan period, as the PPG expects, to ensure the village grows in a clearly planned way and to ensure the future viability of village facilities to 2027. 6.12 But also to help ensure appropriate housing types are available for the aging population and to sustain village services which rely on growing and reinvigorated communities.

Q2. Does the suggested amount of new housing to be provided in your village/town sound about right? If not, why not and what is an appropriate amount? 6.13 As set out above in order to be in conformity with the PPG it would be necessary for Tunstall to be allocated an amount of housing to allow for planned housing development within the plan period to 2027 rather than be left with a blanket zero due in part to recent and as yet undecided planning application. 6.14 The Issues and Options document at its paragraph 3.5 states: 6.15 "It is essential that the Council provides over and above the minimum amount of land needed to meet the target as this will provide flexibility and choice for future residents, developers and other stakeholders. Having a variety of sites also promotes a flexible approach which will help to overcome any site specific issues that may arise over the plan period. Over allocating land for development also enables the Council to clearly demonstrate that sufficient land is available and can come forward throughout the entirety of the plan period." 6.16 It is not clear which plan period is referred to; 2027 or 2031 (as a result of the Core Strategy review later this year).

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5754 - 3055 - Tunstall - None 5754 Support Woodbridge Housing Market Area Tunstall

A residual allocation of zero for Tunstall will not 'provide flexibility and choice for future residents' of that village. 6.17 In the absence of robust evidence Tunstall should be provided with a residual allocation that allows for future expansion of the village.

7.0 Conclusion 7.1 The PPG, which post-dates the SCDC Core Strategy, states that "all settlements can play a role in delivering sustainable development in rural areas [...] and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided". 7.2 Tunstall should have land allocated in the local plan to allow for the sustainable expansion of the village in the current plan period to 2027 and for when the plan period is extended to 2031 during the forthcoming Core Strategy review later in 2015. 7.3 Our client's site no.983 IS available for development because it is vacant and not in active use. 7.4 There is clear potential for the District Council to consider taking sites 509, 756 and 983 forwards as a group because that group of sites acting as one is a better solution to land allocation in Tunstall than other sites in Tunstall. 7.5 This includes site 730 that may be undeliverable because of the site ownership issue set out above and site 786 which has a comparatively poor relationship with the village settlement boundary. 7.6 Our client is willing to develop the site in whatever timeframe suits the village, whether this be within the next 5 years or phased across the plan period and is willing to consider an allocation across the three sites as described above. Summary: Tunstall should have land allocated to allow for the sustainable expansion of the village in the current plan period to 2027 and for when the plan period is extended to 2031 during the forthcoming Core Strategy review later in 2015. Our client's site no.983 IS available for development because it is vacant and not in active use. There is clear potential for the District Council to consider taking sites 509, 756 and 983 forwards as a group because that group of sites acting as one is a better solution to land allocation in Tunstall than other sites in Tunstall.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5759 - 3221 - Tunstall - vi 5759 Object Woodbridge Housing Market Area Tunstall

Respondent: John Higgins [3221] Agent: N/A

Full Text: I strongly object to all three sites being classed as "suitable" for the following reasons.

- The residual requirement has been stated as NIL. As there is already planning consent for 36 houses (plus the 50+ flat development at Snape Maltings). There is no justification/requirement for a further 23 houses.

- Although Tunstall has been positioned as an LSC in the Core Strategy Policy I would argue strongly that the range of facilities in the village are minimal and further residential development could not be supported.

- All three sites are outside both the present and proposed physical limits boundary for Tunstall, in open countryside, and their development would not be consistent with the scale and character of the village. The CSP states that any LSC development should be within "defined village envelopes".

- Sites 597 and 730 are situated within an AONB. Housing on these undeveloped fields would result in the loss of openness to this part of the ANOB where surely the principle objective is to preserve and protect the natural beauty of the area. Development would be in conflict with Policies which are in place that seek the conservation of the ANOB.

- Site 597 forms part of an agricultural field which has historically made an important contribution to the village in its undeveloped form and should be protected accordingly via SP15. Housing here would also create a ribbon style development which would adversely affect the character of the village.

- Site 597 has a dangerous access issue being situated on a short stretch of road between two busy junctions one of which has a blind bend. This danger is further compounded by a dramatic increase in recent years of agricultural and heavy goods vehicle traffic accessing Bentwaters in particular Summary: I strongly object to all three sites being classed as "suitable" for the following reasons.

- The residual requirement has been stated as NIL. As there is already planning consent for 36 houses (plus the 50+ flat development at Snape Maltings). There is no justification/requirement for a further 23 houses.

- Although Tunstall has been positioned as an LSC in the Core Strategy Policy I would argue strongly that the range of facilities in the village are minimal and further residential development could not be supported.

Change to Plan Remove sites 597, 730 and 786 as being suitable from SHLAA

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified No No No vi

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5764 - 3260 - Tunstall - None 5764 Object Woodbridge Housing Market Area Tunstall

Respondent: Charlie Higgins [3260] Agent: N/A

Full Text: I object as there is no requirement for this additional housing as there is already planning consent for 30 plus units. Two of the sites are in an AONB and in the case of site 597 would be situated along a road which is busy and dangerous.

Summary: I object as there is no requirement for this additional housing as there is already planning consent for 30 plus units. Two of the sites are in an AONB and in the case of site 597 would be situated along a road which is busy and dangerous.

Change to Plan withdraw sites 597, 730 and 786

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Yes Yes Yes None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5810 - 3270 - Tunstall - None 5810 Comment Woodbridge Housing Market Area Tunstall

Respondent: Mr Andy Durham [3270] Agent: N/A

Full Text: I support the recommendation of 0 extra houses for Tunstall, given that Tunstall will have more than met its housing number obligations by the set date, with the development of 33 houses near Ashe Road, and the continuing development at the Snape Maltings, which obviously counts towards Tunstall's contribution. I object to the 3 proposed sites (597, 730, 786) mainly because we have already met our quota via the aforementioned developments, but also due to concerns about the precedents set of encroaching onto the AONB which 2 of the sites do. I'm also slightly dubious about the benefits ascribed to the sites, one of which is the reduction in crime, because more housing means fewer areas for criminals to loiter! I would posit that building more homes in a service centre that has no real amenities, certainly not for young people, would be more likely to encourage crime than deter it, or at least increase the likelihood of anti-social behaviour. Summary: We in Tunstall are already well over our quota, in terms of taking extra housing, so the sites identified as suitable (as well as being unsuitable in my mind) are unnecessary.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5811 - 3269 - Tunstall - None 5811 Object Woodbridge Housing Market Area Tunstall

Respondent: Ali Doughty [3269] Agent: N/A

Full Text: There is no further need for housing as the residual requirement has been set at zero as 30+ houses are due to be built. All 3 sites are outside the village envelope and two - 597 and 730 - are within an ANOB. The latter must be protected. Access is a particular problem for these two sites as well, with dangerous junctions in the close vicinity.

Summary: There is no further need for housing as the residual requirement has been set at zero as 30+ houses are due to be built. All 3 sites are outside the village envelope and two - 597 and 730 - are within an ANOB. The latter must be protected. Access is a particular problem for these two sites as well, with dangerous junctions in the close vicinity.

Change to Plan The three sites 597, 730 and 786 must be reclassified as unsuitable.

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Yes Yes Yes None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5828 - 3271 - Tunstall - v 5828 Object Woodbridge Housing Market Area Tunstall

Respondent: Lesley Cresswell [3271] Agent: N/A

Full Text: I consider the following: 1. It will not make life better in the community because it will take away remaining green spaces. It seems a terrible shame that green field sites are even being considered as once they are lost they are lost for ever. 2. It will not reduce crime since it is already negligible. 3. We do not have the infrastructure to cope with increased traffic, there is no shop or school which would mean extra traffic on local roads. Local flooding happens regularly which impacts on the small roads in the area and there does not seem to be anything done about this and the hazard it causes.The junction in the village is hazardous with an accident there only last week. Increased traffic will only make this worse. 4. We already have likely developments in Ashe Road and Snape bridge well in excess of 40 dwellings, double the number proposed, which have not even started yet, plus numerous houses that have been up for sale for months or longer. I consider that with the 20 in this proposal that 60+ new dwellings houses for a place the size of Tunstall is excessive and will change the whole nature of the village and far exceeds the quota we should be expected to accept. I understand that Tunstall is classed as a local service centre because it has a garage and pub. However it has no other resources. The sites are in the AONB which I understand is supposed to mean it is not even considered unless there is an urgent need. I believe theat there is no urgent need. Whilst I understand that there is capacity in local primary schools there is none for older children. With this amount of increase where would these children go? I can see no justification for these proposals and the harm it would cause the area would far exceed any benefits. Summary: 1. It will not make life better in the community because it will take away green spaces. Green field sites should not be considered 2. It will not reduce crime since it is already negligible. 3. There is not the infrastructure to cope with increased traffic, there's no shop or school, meaning extra traffic on local roads. 4. The hazardous junction in the village has been the site of many accidents 5. The amount of proposed dwellings in the area is excessive for a village the size of Tunstall The harm the proposals would cause the area would far exceed any benefits.

Change to Plan The amount of new dwellings proposed should be reduced to those already approved.

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Yes No Yes v

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5846 - 3288 - Tunstall - None 5846 Comment Woodbridge Housing Market Area Tunstall

Respondent: Tunstall Parish Council (Mrs Judi Hallett) [3288] Agent: N/A

Full Text: Ref: Local Plan Documents - Issues and Options Consultation I write with reference to the above on behalf of Tunstall Parish Council. At a recent meeting of Tunstall Parish Council, Councillors and Tunstall residents discussed the following questions: 1. Current Balance of Housing in Tunstall - It is the Parish Council's opinion that Tunstall currently has the correct balance of housing to meet local needs. We have 16 houses under the control of Flagship Housing and a diverse range of houses from 'terraced' to 'detached'. We also have a number of flats at the Snape Maltings complex and outline planning permission for a development of a further 33 houses behind Street Farm, which we believe will include additional affordable housing. We have not been advised by any residents of the need for different types of housing. 2. How many additional houses should Tunstall provide between now and 2027 - With the 33 houses at Street Farm (SHLAA reference 499) and the 43 additional apartments at Snape Maltings, Tunstall Parish Council feel that the village has had 'more than its fair share' of development and that the local plan should recommend no further development. 3. Housing Sites - As detailed in points 1 and 2 above we believe Tunstall has absorbed all the housing development required of it already. With reference to the 'suitable' sites you have suggested in Table 1 we must stress that we find these to be completely 'unsuitable' for the following reasons: Ref Site Reasons for unsuitability for development 597 Land adjacent to The Red House, Orford Road This site lies within the AONB The junction of Orford Road and Snape Road is very dangerous and there have been numerous accidents Access to this site would be an issue This is an important open space which many consider an essential visual asset for our community - in many ways it defines the character of the village Traffic along this stretch of road, especially large commercial and agricultural vehicles, have dramatically increased over recent years.

730 Land at Three Corners, Woodbridge Road This site lies within the AONB This site is outside the existing and proposed Physical Limits boundary, as we agreed with the SCDC Planning Officers in 2010

786 Land at Plunkett's Barn Access to this site would be down a very narrow single track road which already accommodates much farm traffic. Surface water drainage problems may arise as a result of its development The development of this oddly shaped site would extend the village into countryside towards Blaxhall - the resultant asymmetric impact on the layout of the village seems to us both illogical and undesirable A development in this area would place added pressure on the village centre which comprises of a very complicated 4 way junction.

4. Development in other neighbouring parishes - We are aware of a number of potential houses being built at Rendlesham but it was felt these would not have a direct effect on Tunstall. They will however, only add to the bottleneck that is Melton. Finally, to reiterate our principal point, we believe that the village of Tunstall has agreed to development 'above and beyond' what would normally have been expected of it. In order for the community to grow in such a way that it continues to thrive, we need to be given adequate time to welcome and absorb the newcomers that come with each additional development in the village. If you have any queries please do not hesitate to contact me. Summary: To reiterate our principal point, we believe that the village of Tunstall has agreed to development 'above and beyond' what would normally have been expected of it. In order for the community to grow in such a way that it continues to thrive, we need to be given adequate time to welcome and absorb the newcomers that come with each additional development in the village.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: Tunstall_20150225 - Letter to SCDC re Issues and Options FINAL.docx

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6267 - 3333 - Tunstall - None 6267 Object Woodbridge Housing Market Area Tunstall

Respondent: Mrs Sharon Culley [3333] Agent: N/A

Full Text: We had no idea the cut off date to make comments regarding the proposed housing sites in Tunstall was last Friday 27th February.

However in the hope our comments will still be taken onboard we would like to register our views in that we are STRONGLY OPPOSED to the building of further houses in Tunstall. With 33 houses being erected opposite the garage in Tunstall we have more than our quota and there is also houses being built near the Maltings. The village is already very densely populated and it is such a shame that so many houses are second homes which are only resided in during some weekends. We are particularly opposed to the building on site allocated as 597 near the Red House in Tunstall. This is the only area of open land in the village which has not been built on - it would be tragic if this was developed.

Please could you take our views into account despite being past the cut off date. Summary: We are STRONGLY OPPOSED to the building of further houses in Tunstall. With 33 houses being erected opposite the garage we have more than our quota and there is also houses being built near the Maltings. The village is already very densely populated and it is such a shame that so many houses are second homes which are only resided in during some weekends. We are particularly opposed to the building on site allocated as 597 near the Red House in Tunstall. This is the only area of open land in the village which has not been built on.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6391 - 2655 - Tunstall - None 6391 Comment Woodbridge Housing Market Area Tunstall

Respondent: Member of Parliament (MP) (Rt. Hon Therese Agent: N/A Coffey MP) [2655]

Full Text: Thank you for the opportunity to comment on the site allocations and area specific policies for the local plan. I think it is a welcome step to encourage all the public to participate in this early stage of the process. I only usually intervene on strategic issues and policies on planning.

While I have detailed my comments on some individual areas below, I have three particular issues to discuss - i) the imbalance of housing allocations around the area with the vast amount of development inserted east of the A12, the side of Suffolk that has the AONB and nearly all the SSSls; iii) the absence of nominated sites in Framlingham and Leiston; iii) building on main roads and the absence of infrastructure, particularly roads, for major and cumulative developments with the risk of significant congestion and longer journey times as well as community facilities.

Allocation of housing across the district

The vast majority of the proposed housing lies east of the A12 and to the south of the district. This continues to move the centre of gravity south east which runs the risk of excluding significant parts of our area of new housing for local people and also the lack of infrastructure (either new or upgraded). There appears to be a surprising disparity between settlements on where is deemed appropriate for further development and where is not. For example, no further housing is recommended for Wickham Market while Wenhaston, lower down the settlement hierarchy, has been recommended for more housing despite having just had an application for 26 new homes approved (higher than the Local Plan allocation of 5-15). Separately, Saxmundham has been recommended for further housing after a significant amount already built and under construction. I do not object specifically to that but will make the point later about infrastructure. There is little difference between Wickham Market, Saxmundham and Framlingham apart from the railway station. It has been suggested that Wickham Market has already had some housing so need not have any more and Framlingham has been allocated a small amount. That is in contrast to Leiston which has been allocated up to 500 houses, though with no additional infrastructure. The experience elsewhere does not bear that out. While it makes sense to allow for housing in villages and parishes as well as market towns but in a sensible proportion that does not dwarf existing villages. Therefore, I suggest that villages that have already had housing approved in the last two years should not have further sites specifically designated but allow for windfall, within the existing village envelope and not on main roads (like the A12 in Yoxford or A1120 in Peasenhall or the High Road in the Trimleys or the A144). It also should be on the same side of the main road as the local facilities - which would rule out nominated sites specifically in Yoxford and Woodbridge. We should not repeat the mistakes of the past. Another guiding principle should be that new housing is as close as possible to existing facilities. There is development planned on the opposite side of the main road to key facilities in some areas, which would significantly shift the centre of gravity and mean people having to cross busy roads to get to the centre. Shifting the centre of gravity of further development away from shops and facilities in towns, as may be the case in Saxmundham, is a retrograde step for enhancing the sense of community. The council must counter the risk of our small market towns becoming car-based, seeking shopping, leisure and sporting activities away from the town.

I strongly support the protection of green gaps, acting as strategic barriers between settlements.

There is an absence of nominated sites in Leiston and Framlingham. It has been suggested that this is due to emerging town plans but they should not have been absented from this consultation.

Finally, the absence of infrastructure. There is already huge pressure on various parts of the A12 and there is no indication of what infrastructure additions or upgrades are being proposed to accommodate such significant increases. In more specific terms,

i) Martlesham area with 2000 houses, adding to the increasing retail presence on the Martlesham Heath industrial estate. The latter is already leading to significant increases in traffic, coupled with further housing already under construction in Martlesham. Significant improvements need to be made to the A12 at several junctions. ii) Woods Lane roundabout and the A1152. There are already at least 15,000 traffic movements per day at the Melton railway crossing (sourced from Network Rail three years ago). Without substantial improvements to roads here, the additional housing suggested in Melton, Eyke and Rendlesham will bring even greater traffic movement pressure on the round about, the railway crossing and the traffic lights on the junction of the A1152/B1438. iii) Given the council's full support for the 4 villages bypass, it is surprising that no housing has been considered for this area as bypasses usually lead to significant increases in housing. Meanwhile, up to 500 houses are being proposed for Leisten but with no road improvements and no support for the potential D2 route being suggested in conjunction with Sizewell C. iv) In Saxmundham, a substantial number of new housing has already been built. While there has been minor modification of the traffic lights in the centre of the town, there has been no improvements planned to help traffic in and through the town. v) Woodbridge site at the football ground -addressing the congestion and the replacement of sporting facilities within the town area. vi) Local community infrastructure will need significant improvement - pace Rendlesham, Saxmundham, Leisten, the Trimleys and the new development at Martlesham. On local sites, I have commented by exception and no comment is not a sign of endorsement.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6391 - 2655 - Tunstall - None 6391 Comment Woodbridge Housing Market Area Tunstall

Woodbridge Housing Area

Campsea Ashe Site 557 is a very unusual place to add more housing especially if there is going to be work on the track for Sizewell C. I agree with 745 and 990 being unsuitable SHLAA sites. They are far too large and inappropriate. Eyke Agree that 991 and OPP7 are unsuitable sites. 991 looks to double size of village whereas Opp7 suggests substantial new housing along A-road which is unsuitable. Hollesley Agree that 825 is unsuitable - losing a significant amount of green field opposite school. Orford Agree that 494/484 & 976 is unsuitable. Surprised some sites proposed with sea levels. Tunstall Disagree that 786, 597 and 730 would all be suitable as a whole as seems to double the size of the village which is unnecessary over-development. Wickham Market Would support 7761 and 776i as it is a significant market town. Woodbridge Agree that sites 937 and 453 are unsuitable due to being west of the A12. 839,750,750a, 974 unsuitable due to pressure on roundabout.

Framlingham Housing Area

Bramfield Agree that 493 is unsuitable as it is too far away from the centre. Peasenhall Agree with 832 being unsuitable as outside the envelope and inappropriate. Wenhaston The village has already had a significant amount of development therefore I don't see the need for any further sites to be added. Strongly oppose any greenfield sites. Yoxford Strongly oppose accepted SHLAA sites 642b and 794. They are both opposite or adjacent to existing housing but involves crossing a main road to get to existing village facilities.

Saxmundham Housing Area

Aldeburgh Agree with unsuitable SHLAA sites in first map. Should continue to look for windfall sites. Strongly agree that 768 shouldn't be brought forward. Benhall Agree that 411b and 411c should not be brought forward. They would dwarf the village and would constitute overdevelopment. Blythburgh Disagree with 4UCB being brought forward as junction already very difficult and wouldn't cope. Darsham Agree that 378 and 967 are unsuitable as are considerably out of the village. Strongly disagree with 794 as it is too close to the main road and a strategic error. Dunwich Agree that 713 is unsuitable as is too far away from the village centre. Knodishall Agree that 506 which would dwarf the village, 579 which would significantly reduce the gap to Aldringham and 971 which would bring an unwarranted urban feel to that side of the village are unsuitable. Little Glemham 625 would put particular pressure on A12 which would require substantial highway change if it were to go ahead. Saxmundham Strongly agree that the non-hatched sites are unsuitable. Of the sites that have been endorsed 1006 and 1009, there is a risk of this development being too far away from the high street shift the centre of gravity. If this was to go ahead then there should be consideration for a relief road from the North entrance to the B1119. Snape Agree that 758 is unsuitable as too far out of the centre of the village. Westleton Agree with unsuitability of sites. Strongly oppose any development on 327 and 935.

Felixstowe Housing Area/Area Action Plan

Waldrlngfield Support 961 being a SHLAA unsuitable site. We need to protect this as a local gap. Bucklesham Most sites are too big and too far away from village centre. Kirton It is my understanding the Falkenham Road site has been backed in a local consultation session run by the Parish Council. Concerned about over development if all the other sites were approved. Trimley St Martin Agree that 920 and 889 are completely unsuitable. Trimley St Mary Concern that the current road network could cope with significant development on 383F. Agree with unsuitability of 383,c,d,e & 451e as too far away from centre. Summary: Tunstall Disagree that 786, 597 and 730 would all be suitable as a whole as seems to double the size of the village which is unnecessary over-development.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6547 - 2581 - Tunstall - None 6547 Comment Woodbridge Housing Market Area Tunstall

Respondent: Suffolk County Council (Mr Robert Feakes) [2581] Agent: N/A

Full Text: Site Allocations Document - Issues and Options Consultation Suffolk County Council Response

1. Introduction

1.1 Thank you for consulting Suffolk County Council on the above document. This response aims to set out the issues which our two authorities will need to resolve as this document is brought forwards towards adoption, rather than seeking to resolve issues now. Comments are set out in relation to Suffolk County Council service responsibilities and policy objectives; matters on which our authorities need to cooperate.

2. Air Quality and Noise Assessment

2.1 There are a number of locations within Martlesham that are adjacent to the A12, which include 710, 479, 721, 644, 693, 517, 430. The bunding adjacent to the A12 at sites 517/430, provided initially to protect Martlesham Heath residents from mineral working noise, should be retained as it has been designed (it is high enough) to provide a good level of protection from road traffic noise for any new dwellings behind it.

2.2 Developments adjacent to the A1214 through Kesgrave, eg. 774a and also the A1156 Felixstowe Road would all be subject to traffic noise as these routes carry significant volumes of traffic. Also locations at Ufford adjacent to the A12 to include 586, 838a and 838b and at Woodbridge for plots 937, 900a and 703. There a number of IAs along the A12 at Martlesham Heath and Woodbridge and should additional residential receptors be built adjacent to the route, these would be extended, potentially requiring this authority to fund mitigation provision. Similarly for other locations adjacent the A12 at Darsham, Kelsale, Little Glemham, Saxmundham and Yoxford.

2.3 There is an Air Quality Management Area (AQMA) in Woodbridge at the Lime Kiln Quay Road/Melton Hill junction. This should be viewed as a constraint and taken into account looking at the impacts of traffic growth through Woodbridge.

3. Archaeology

3.1 It is suggested that an informative section is considered which highlights the archaeology of the area and its management in the development process. The following is provided as an initial suggestion:

Suffolk Coastal has a rich, diverse and dense archaeological landscape with the river valleys, in particular, topographically favourable for early occupation of all periods. The distinctive character of the historic environment in the District includes upstanding coastal archaeology of all dates, prehistoric burial tumuli on the open heathlands around the eastern margins of Ipswich and on the Felixstowe peninsula, the remains of Roman small towns at Felixstowe and Wenhaston, the internationally important Anglo-Saxon burial ground at Sutton Hoo, numerous medieval historic towns and villages with both above and below ground heritage assets, for example Woodbridge and Aldeburgh, and the strategically placed, Napoleonic Martello towers. These are among over 7,300 sites of archaeological interest currently recorded in the Suffolk Historic Environment Record for Suffolk Coastal. Suffolk County Council Archaeological Service routinely advises that there should be early consultation of the Historic Environment Record and assessment of the archaeological potential of proposed sites at an appropriate stage in the design of new developments, in order that the requirements of the NPPF are met with regards to designated and non-designated heritage assets.

3.2 Suffolk County Council's archaeologists would be pleased to liaise with the District Council on wording, and provide more detailed information on archaeology on the area if required. To briefly clarify two points within the documents, heritage assets include Scheduled Monuments (paragraph 5.17) and non-designated heritage assets also include archaeological sites (paragraph 5.19).

3.3 For those sites which have not previously been commented on through the Strategic Housing Land Availability Assessment process, comments on likely archaeological assessment requirements are set out as an appendix to this letter.

4. Education (including Early Years)

4.1 In order to meet the requirements of Paragraph 72 of the National Planning Policy Framework, and to support community wellbeing (as described in paragraph 3.15 of the Core Strategy), this plan must ensure the delivery of sufficient education places to meet demand arising from housing growth. Government policy is that new provision made necessary as a result of demand arising from new housing should be funded from developer contributions; the County Council can only access funding to provide new places made necessary as a result of population growth arising from the existing housing stock.

4.2 In respect of the statutory requirement to provide 15 hours per week of early education for 3 - 4 year olds (and eligible 2 year olds), there is clearly a variation in levels of existing capacity across the District, which will impact on what additional provision is needed. For many of the parishes, the allocations indicated will not necessitate the provision of new Early Years settings, but contributions are still likely to be sought in many instances.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6547 - 2581 - Tunstall - None 6547 Comment Woodbridge Housing Market Area Tunstall

4.3 Those settlements with more significant development (Leiston, Saxmundham, Woodbridge, Aldeburgh and Framlingham) are more likely to require contributions towards additional provision. The County Council does not normally seek allocations of land for additional provision, given that provision is largely made through the private, voluntary and independent sector providers. However, should any new primary schools be required, it is expected that early education provision will be co-located with the new primary schools.

4.4 In terms of primary education, the distribution of housing is a key determining factor as regards what additional provision is needed. Our authorities also need to consider the long term resilience of the primary school system, and consider the likelihood that the forthcoming review of the Suffolk Core Strategy will result in the allocation of additional dwellings to the rural areas.

4.5 For much of the District, specifically in the rural areas, existing schools are likely to be able to absorb the low levels of growth proposed. However, this capacity cannot be considered as 'available' to absorb growth proposed in the market towns. Paragraph 38 of the NPPF emphasises the priority which should be given to locating key facilities in close proximity to housing. Assuming that children can attend schools a long distance from their homes will increase the need to travel, reduce the proportion of journeys undertaken by sustainable modes and place an ongoing cost on the public purse for home to school transport.

4.6 It appears that the level of growth proposed in Framlingham (75-150 dwellings) and Leiston (250-500 dwellings) can be accommodated in local schools on their existing sites, though developer contributions will be required in Framlingham at primary level and may be required in Leiston if development is at the larger end of the scale.

4.7 It also appears that the level of growth proposed in Saxmundham can be accommodated at local schools, albeit in a limited capacity. However, if further iterations of this document bring forward additional allocations in Saxmundham, it is unlikely that this growth could be accommodated at Saxmundham Primary School. Equally, the 'neighbouring' schools cannot accept further pupils from growth in Saxmundham (beyond that already agreed). Therefore, any further growth at Saxmundham will need to be accompanied with detailed consideration of how growth can be managed at primary school level. It may necessitate the development of a new primary school, which will necessarily be funded through Section 106 agreements.

4.8 Existing schools cannot accept growth indefinitely. If there is significant growth at Framlingham and Saxmundham, beyond that envisaged by this document, it is likely to be appropriate for the Local Plan to identify new school sites in these towns. This will help to minimise the risk of sending children to schools outside their own communities.

4.9 In regard to Woodbridge, it is important to better understand exactly where the housing is going to be. In considering current forecasts it appears that spaces would be available at Kyson and Melton in particular which, according to the SHLAA sites map, would be the local schools for the majority of the proposed housing. Significant housing growth within the catchments of St Marys and Woodbridge Primaries may prove problematic.

4.10 Development of 75-150 dwellings in Aldeburgh is expected to generate between 19 and 38 additional pupils (based on 25 pupils per 100 dwellings). Aldeburgh Primary School is consistently at capacity for the forecast period, and the school cannot be expanded on its current site. Whilst there is capacity at Leiston and Coldfair Green Primary Schools, sending pupils from Aldeburgh to these schools is undesirable and would need to be considered alongside growth in these parishes. If the District Council does intend to allocate housing at Aldeburgh, this will need to be the subject of early discussion.

4.11 Rendlesham Primary School has recently been expanded to 315 - places. Further expansion; which may be necessary to cope with 75-100 dwellings (19-25 pupils); would be challenging.

4.12 At secondary level, the allocations envisaged by this consultation document are likely to create additional demand at:

- Thomas Mills High School, - Saxmundham Free School, - Stradbroke High School - Debenham High School - Halesworth High School - Bungay High School - Alde Valley School - Farlingaye High School - Kesgrave High School

4.13 The scale of development proposed is not envisaged as being problematic at secondary level, with the exception of growth within the Farlingaye catchment. It appears that allocated growth within the Farlingaye catchment could be around 345 dwellings (or be fewer), meaning up to 62 pupils aged 11-16 and 14 pupils aged 16+. Farlingaye High School is already consistently over capacity, and it is not possible to expand the school on its current site. Should Adastral Park come forward in the near future, this creates an opportunity for delivering additional secondary school capacity, to take pressure off Farlingaye. However, our authorities need to discuss contingencies for managing this

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6547 - 2581 - Tunstall - None 6547 Comment Woodbridge Housing Market Area Tunstall

growth.

5. Health and Wellbeing

5.1 The County Council is keen to discuss the extent to which this document can promote the objective of the Suffolk Health and Wellbeing Strategy. Particular issues are access to the countryside and green space via the public rights of way network, and consideration of whether allocations for supported housing are necessary.

6. Libraries

6.1 In order to ensure deliverability of the Plan, it will need to be demonstrated that provision can be made to increase library service levels through developer contributions. The County Council is currently developing a more detailed plan for how library service provision will be developed in order to meet the demands of planned growth, in order to inform discussions on CIL spending.

7. Minerals and Waste Plans

7.1 At present, the County Council has no comments as the Minerals and Waste planning authority, but our authorities will need to work to ensure consistency between Plans. Our authorities should consider how we might encourage the sustainable use of minerals in situ, in advance of development, in order to reduce the need for extraction elsewhere and to reduce the highway impacts of construction.

8. Natural Environment

8.1 The County Council is interested in the ways in which this DPD can support the objectives of Suffolk's Nature Strategy, and would be pleased to work with the District Council to consider how this DPD could promote natural environment objectives, such as developing ecological networks. This is relevant in the context of the health and wellbeing strategy (as referred to elsewhere in this response), and the availability of accessible green space is important for mitigating impacts on European designated sites.

9. Public Rights of Way

9.1 The NPPF refers to a need for the planning system to protect and promote the public rights of way network. The Suffolk Health and Wellbeing Strategy includes 'access to a healthy environment' as a key objective. The Plan should consider how it will meet those challenges.

9.2 There is an opportunity to give detailed thought as to how the Plan can encourage healthy and sustainable travel, improve access to the countryside and open space, and to improve leisure and recreation opportunities. Officers from the County Council would be pleased to support the development of the plan in respect of these opportunities.

10. Surface Water Management

10.1 The County Council would be pleased to provide surface water flood records, to help consider the deliverability of sites and whether or not any specific policy measures will be required. SuDS principles should be applied as appropriate, in accordance with national standards, to enhance recharge of underground aquifers as well as provide surface water management and environmental features.

11. Transport

11.1 The County Council has previously provided comments on potential highway impacts arising from each site individually. It is not envisaged that these allocations will require a cumulative assessment of transport impacts.

12. Waste Provision

12.1 Suffolk Coastal, outside of the Felixstowe AAP area, is served by Household Waste Recycling Centres at Leiston, Felixstowe and Foxhall.

12.2 Whilst there are no proposals under consideration at the current time to change the service provided at the Leiston site, or indeed to move it, there is a recognition that the site does suffer from congestion at peak times. It is likely that the impact of development in the local area will increase pressure on the site and the County Council will be seeking developer contributions to fund improvements in the current site or to fund a replacement, should an alternative site come forward.

12.3 The Foxhall site will require a modification and change to existing planning permissions beyond 2021, if it is to remain on site it will need a partial rebuild for certain and, possibly, modifications to the vehicular access arrangements. If this is not possible a new site will need to be found in the area and before 2020 at the latest. CIL funding may be sought to support these projects.

13. Water Management, Flood and Coastal Defences

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6547 - 2581 - Tunstall - None 6547 Comment Woodbridge Housing Market Area Tunstall

13.1 Water resources are critical in the east of Suffolk, as recognised in Anglian Water's recently updated Water Resources Management Plan. Any measures that can be incorporated in new developments to capture/reuse/recycle water should be encouraged.

13.2 The recently finalised Deben Estuary Plan (and forthcoming Alde/Ore Estuary Plan) should be considered in relation to the development of this Plan - in the same way as the Suffolk Shoreline Management Plan. These plans rely upon a willingness to embrace the principle of an integrated system - recognising the need to reconcile the continued wellbeing of the river systems, the interests of the communities and the ecological integrity of unique estuarine environments.

13.3 The concept within these estuary plans, of 'enabling development', proposed as one possible mechanism for funding local flood defences, should be encouraged where proper infrastructure can also be provided.

13.4 Where appropriate development funding should be directed towards flood and coastal defences. Without local contributions of this type, many of our existing settlements will be at risk in the future.

Appendix: Likely Archaeological Assessment Requirements

East Ipswich Plan Area

Martlesham 900a. This site was covered under advice in 2008 for 703. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham 893. This site is close to areas of prehistoric activity (County Historic Environment Record MRM 154, MRM 027). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Westerfield 939. This site is close to the medieval core of the settlement, and within the findspot of Roman, Saxon and Iron Age objects. There is high potential for the development to impact on archaeological remains of these periods. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham EMP1 694 - previous recommendation for early archaeological assessment (sites 721/694/644).

Ransomes EMP2 - This large area (15ha) lies adjacent to a series of burnt pits (County Historic Environment Record PFM 009) and cropmark features of a pre-historic/Roman trackway and associated features to the east (PFM 085). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Framlingham

Wenhaston 938a. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Wenhaston 938b. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. The development also has a frontage onto one of the historic streets of the late Saxon and medieval settlement. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Yoxford 794. No objection in principle but it would any application should include an desk-based assessment and appraisal of structures currently existing on the site. Depending on the results of desk-based assessment, the site may require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham

Aldringham 5668. Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work. Development should be sensitive to the particular historic character of the built environment.

Benhall 969. This site is in a topographically favourable location for early activity overlooking the River Fromus. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6547 - 2581 - Tunstall - None 6547 Comment Woodbridge Housing Market Area Tunstall

work.

Blythburgh 4UCB. This site is in an area of very high archaeological potential within the historic core of Saxon and Medieval Blythburgh. The development fronts historic streets of the settlement. It has remained undeveloped in more recent periods (e.g. as shown on historic OS maps) and there is good potential for preservation of earlier archaeological remains. There could be complex remains surviving. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Blythburgh 3UCB Development on this site should be sympathetic to the historic farmstead, and development proposals should include assessments of historic buildings which are to be altered by the development so that informed decisions can be made. The site has archaeological potential, close to the existing 16th century building and within the historic core of Blythburgh. It would require a planning condition under the NPPF to secure a programme of archaeological work.

Kelsale cum Carleton 884 This site has not been systematically investigated for archaeological remains. It is in a topographically favourable valley side location, and should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Knodishall OPP5 This site lies within the historic settlement core, on the green edge, and development has the potential to impact upon early settlement remains. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Middleton 779 This site lies within the historic settlement core. A prehistoric ring ditch is recorded to the west (County Historic Environment Record MDD 004). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham 1006 This site is in an area of high archaeological potential overlooking the valley of the River Fromus. Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Saxmundham 1009 This site has been partially evaluated for archaeological remains (geophysical survey and some archaeological trial trenching). There are no grounds to object to development, but development will require a planning condition under the NPPF to secure a programme of archaeological work. This should include record of farm buildings, and further evaluation in the first instance. The results of evaluation will inform the overall archaeological investigation strategy.

Woodbridge

Aldeburgh 982 This large site is in an area of high archaeological potential, on a south facing slope overlooking the estuary and Aldeburgh marshes. Medieval archaeological remains are recorded to the north (County Historic Environment Record ADB 004), and Bronze Age to the west (ADB 002). Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Much of the site is within the area of brickworkings associated with the former Read's Brickworks. Desk- based assessment and geophysical survey in the first instance would establish the impacts of this previous landuse. There would be potential for promotion of the heritage of the area.

Hollesley 829 This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the southwest (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Hollesley 9UCH This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the northeast (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Information on buildings on the site should be submitted with any application, should they be impacted on by proposed development.

Hollesley 8UCH. This site lies within the historic core of Hollesley, opposite the church and with a street frontage that has high potential for archaeological remains relating to early settlement. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Early evaluation of the street frontage would be advisable so that archaeological investigation can be factored in to project designs. Evaluation has been carried out towards the rear of the site and did not reveal significant remains.

Orford OPP4 This site is close to a possible mound site (County Historic Environment Record ORF 023), and the site of a windmill depicted on a plan of c1600 (ORF 019). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6547 - 2581 - Tunstall - None 6547 Comment Woodbridge Housing Market Area Tunstall

investigation strategies. Geophysical survey would be appropriate in the first instance.

Shottisham 812b Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work.

Shottisham 812d Exact map location not provided, but the site is within the Anglo-Saxon and Medieval core of the settlement (County Historic Environment Record STT 059), close to the church. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Tunstall 786 - This site lies within and on the edge of the historic settlement core. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Any application should also include an assessment of buildings that are to be affected by development.

Woodbridge 900a - This site lies within an area of archaeological potential, and Neolithic pits and Iron Age features were excavated to the south (County Historic Environment Record MRM 030). The site should be subject to archaeological assessment at an appropriate stage in the design of new development to establish the impacts of past land-use, and ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Summary: Tunstall 786 - This site lies within and on the edge of the historic settlement core. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Any application should also include an assessment of buildings that are to be affected by development.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6548 - 2581 - Tunstall - None 6548 Comment Woodbridge Housing Market Area Tunstall

Respondent: Suffolk County Council (Mr Robert Feakes) [2581] Agent: N/A

Full Text: Site Allocations Document - Issues and Options Consultation Suffolk County Council Response

1. Introduction

1.1 Thank you for consulting Suffolk County Council on the above document. This response aims to set out the issues which our two authorities will need to resolve as this document is brought forwards towards adoption, rather than seeking to resolve issues now. Comments are set out in relation to Suffolk County Council service responsibilities and policy objectives; matters on which our authorities need to cooperate.

2. Air Quality and Noise Assessment

2.1 There are a number of locations within Martlesham that are adjacent to the A12, which include 710, 479, 721, 644, 693, 517, 430. The bunding adjacent to the A12 at sites 517/430, provided initially to protect Martlesham Heath residents from mineral working noise, should be retained as it has been designed (it is high enough) to provide a good level of protection from road traffic noise for any new dwellings behind it.

2.2 Developments adjacent to the A1214 through Kesgrave, eg. 774a and also the A1156 Felixstowe Road would all be subject to traffic noise as these routes carry significant volumes of traffic. Also locations at Ufford adjacent to the A12 to include 586, 838a and 838b and at Woodbridge for plots 937, 900a and 703. There a number of IAs along the A12 at Martlesham Heath and Woodbridge and should additional residential receptors be built adjacent to the route, these would be extended, potentially requiring this authority to fund mitigation provision. Similarly for other locations adjacent the A12 at Darsham, Kelsale, Little Glemham, Saxmundham and Yoxford.

2.3 There is an Air Quality Management Area (AQMA) in Woodbridge at the Lime Kiln Quay Road/Melton Hill junction. This should be viewed as a constraint and taken into account looking at the impacts of traffic growth through Woodbridge.

3. Archaeology

3.1 It is suggested that an informative section is considered which highlights the archaeology of the area and its management in the development process. The following is provided as an initial suggestion:

Suffolk Coastal has a rich, diverse and dense archaeological landscape with the river valleys, in particular, topographically favourable for early occupation of all periods. The distinctive character of the historic environment in the District includes upstanding coastal archaeology of all dates, prehistoric burial tumuli on the open heathlands around the eastern margins of Ipswich and on the Felixstowe peninsula, the remains of Roman small towns at Felixstowe and Wenhaston, the internationally important Anglo-Saxon burial ground at Sutton Hoo, numerous medieval historic towns and villages with both above and below ground heritage assets, for example Woodbridge and Aldeburgh, and the strategically placed, Napoleonic Martello towers. These are among over 7,300 sites of archaeological interest currently recorded in the Suffolk Historic Environment Record for Suffolk Coastal. Suffolk County Council Archaeological Service routinely advises that there should be early consultation of the Historic Environment Record and assessment of the archaeological potential of proposed sites at an appropriate stage in the design of new developments, in order that the requirements of the NPPF are met with regards to designated and non-designated heritage assets.

3.2 Suffolk County Council's archaeologists would be pleased to liaise with the District Council on wording, and provide more detailed information on archaeology on the area if required. To briefly clarify two points within the documents, heritage assets include Scheduled Monuments (paragraph 5.17) and non-designated heritage assets also include archaeological sites (paragraph 5.19).

3.3 For those sites which have not previously been commented on through the Strategic Housing Land Availability Assessment process, comments on likely archaeological assessment requirements are set out as an appendix to this letter.

4. Education (including Early Years)

4.1 In order to meet the requirements of Paragraph 72 of the National Planning Policy Framework, and to support community wellbeing (as described in paragraph 3.15 of the Core Strategy), this plan must ensure the delivery of sufficient education places to meet demand arising from housing growth. Government policy is that new provision made necessary as a result of demand arising from new housing should be funded from developer contributions; the County Council can only access funding to provide new places made necessary as a result of population growth arising from the existing housing stock.

4.2 In respect of the statutory requirement to provide 15 hours per week of early education for 3 - 4 year olds (and eligible 2 year olds), there is clearly a variation in levels of existing capacity across the District, which will impact on what additional provision is needed. For many of the parishes, the allocations indicated will not necessitate the provision of new Early Years settings, but contributions are still likely to be sought in many instances.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6548 - 2581 - Tunstall - None 6548 Comment Woodbridge Housing Market Area Tunstall

4.3 Those settlements with more significant development (Leiston, Saxmundham, Woodbridge, Aldeburgh and Framlingham) are more likely to require contributions towards additional provision. The County Council does not normally seek allocations of land for additional provision, given that provision is largely made through the private, voluntary and independent sector providers. However, should any new primary schools be required, it is expected that early education provision will be co-located with the new primary schools.

4.4 In terms of primary education, the distribution of housing is a key determining factor as regards what additional provision is needed. Our authorities also need to consider the long term resilience of the primary school system, and consider the likelihood that the forthcoming review of the Suffolk Core Strategy will result in the allocation of additional dwellings to the rural areas.

4.5 For much of the District, specifically in the rural areas, existing schools are likely to be able to absorb the low levels of growth proposed. However, this capacity cannot be considered as 'available' to absorb growth proposed in the market towns. Paragraph 38 of the NPPF emphasises the priority which should be given to locating key facilities in close proximity to housing. Assuming that children can attend schools a long distance from their homes will increase the need to travel, reduce the proportion of journeys undertaken by sustainable modes and place an ongoing cost on the public purse for home to school transport.

4.6 It appears that the level of growth proposed in Framlingham (75-150 dwellings) and Leiston (250-500 dwellings) can be accommodated in local schools on their existing sites, though developer contributions will be required in Framlingham at primary level and may be required in Leiston if development is at the larger end of the scale.

4.7 It also appears that the level of growth proposed in Saxmundham can be accommodated at local schools, albeit in a limited capacity. However, if further iterations of this document bring forward additional allocations in Saxmundham, it is unlikely that this growth could be accommodated at Saxmundham Primary School. Equally, the 'neighbouring' schools cannot accept further pupils from growth in Saxmundham (beyond that already agreed). Therefore, any further growth at Saxmundham will need to be accompanied with detailed consideration of how growth can be managed at primary school level. It may necessitate the development of a new primary school, which will necessarily be funded through Section 106 agreements.

4.8 Existing schools cannot accept growth indefinitely. If there is significant growth at Framlingham and Saxmundham, beyond that envisaged by this document, it is likely to be appropriate for the Local Plan to identify new school sites in these towns. This will help to minimise the risk of sending children to schools outside their own communities.

4.9 In regard to Woodbridge, it is important to better understand exactly where the housing is going to be. In considering current forecasts it appears that spaces would be available at Kyson and Melton in particular which, according to the SHLAA sites map, would be the local schools for the majority of the proposed housing. Significant housing growth within the catchments of St Marys and Woodbridge Primaries may prove problematic.

4.10 Development of 75-150 dwellings in Aldeburgh is expected to generate between 19 and 38 additional pupils (based on 25 pupils per 100 dwellings). Aldeburgh Primary School is consistently at capacity for the forecast period, and the school cannot be expanded on its current site. Whilst there is capacity at Leiston and Coldfair Green Primary Schools, sending pupils from Aldeburgh to these schools is undesirable and would need to be considered alongside growth in these parishes. If the District Council does intend to allocate housing at Aldeburgh, this will need to be the subject of early discussion.

4.11 Rendlesham Primary School has recently been expanded to 315 - places. Further expansion; which may be necessary to cope with 75-100 dwellings (19-25 pupils); would be challenging.

4.12 At secondary level, the allocations envisaged by this consultation document are likely to create additional demand at:

- Thomas Mills High School, - Saxmundham Free School, - Stradbroke High School - Debenham High School - Halesworth High School - Bungay High School - Alde Valley School - Farlingaye High School - Kesgrave High School

4.13 The scale of development proposed is not envisaged as being problematic at secondary level, with the exception of growth within the Farlingaye catchment. It appears that allocated growth within the Farlingaye catchment could be around 345 dwellings (or be fewer), meaning up to 62 pupils aged 11-16 and 14 pupils aged 16+. Farlingaye High School is already consistently over capacity, and it is not possible to expand the school on its current site. Should Adastral Park come forward in the near future, this creates an opportunity for delivering additional secondary school capacity, to take pressure off Farlingaye. However, our authorities need to discuss contingencies for managing this

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6548 - 2581 - Tunstall - None 6548 Comment Woodbridge Housing Market Area Tunstall

growth.

5. Health and Wellbeing

5.1 The County Council is keen to discuss the extent to which this document can promote the objective of the Suffolk Health and Wellbeing Strategy. Particular issues are access to the countryside and green space via the public rights of way network, and consideration of whether allocations for supported housing are necessary.

6. Libraries

6.1 In order to ensure deliverability of the Plan, it will need to be demonstrated that provision can be made to increase library service levels through developer contributions. The County Council is currently developing a more detailed plan for how library service provision will be developed in order to meet the demands of planned growth, in order to inform discussions on CIL spending.

7. Minerals and Waste Plans

7.1 At present, the County Council has no comments as the Minerals and Waste planning authority, but our authorities will need to work to ensure consistency between Plans. Our authorities should consider how we might encourage the sustainable use of minerals in situ, in advance of development, in order to reduce the need for extraction elsewhere and to reduce the highway impacts of construction.

8. Natural Environment

8.1 The County Council is interested in the ways in which this DPD can support the objectives of Suffolk's Nature Strategy, and would be pleased to work with the District Council to consider how this DPD could promote natural environment objectives, such as developing ecological networks. This is relevant in the context of the health and wellbeing strategy (as referred to elsewhere in this response), and the availability of accessible green space is important for mitigating impacts on European designated sites.

9. Public Rights of Way

9.1 The NPPF refers to a need for the planning system to protect and promote the public rights of way network. The Suffolk Health and Wellbeing Strategy includes 'access to a healthy environment' as a key objective. The Plan should consider how it will meet those challenges.

9.2 There is an opportunity to give detailed thought as to how the Plan can encourage healthy and sustainable travel, improve access to the countryside and open space, and to improve leisure and recreation opportunities. Officers from the County Council would be pleased to support the development of the plan in respect of these opportunities.

10. Surface Water Management

10.1 The County Council would be pleased to provide surface water flood records, to help consider the deliverability of sites and whether or not any specific policy measures will be required. SuDS principles should be applied as appropriate, in accordance with national standards, to enhance recharge of underground aquifers as well as provide surface water management and environmental features.

11. Transport

11.1 The County Council has previously provided comments on potential highway impacts arising from each site individually. It is not envisaged that these allocations will require a cumulative assessment of transport impacts.

12. Waste Provision

12.1 Suffolk Coastal, outside of the Felixstowe AAP area, is served by Household Waste Recycling Centres at Leiston, Felixstowe and Foxhall.

12.2 Whilst there are no proposals under consideration at the current time to change the service provided at the Leiston site, or indeed to move it, there is a recognition that the site does suffer from congestion at peak times. It is likely that the impact of development in the local area will increase pressure on the site and the County Council will be seeking developer contributions to fund improvements in the current site or to fund a replacement, should an alternative site come forward.

12.3 The Foxhall site will require a modification and change to existing planning permissions beyond 2021, if it is to remain on site it will need a partial rebuild for certain and, possibly, modifications to the vehicular access arrangements. If this is not possible a new site will need to be found in the area and before 2020 at the latest. CIL funding may be sought to support these projects.

13. Water Management, Flood and Coastal Defences

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6548 - 2581 - Tunstall - None 6548 Comment Woodbridge Housing Market Area Tunstall

13.1 Water resources are critical in the east of Suffolk, as recognised in Anglian Water's recently updated Water Resources Management Plan. Any measures that can be incorporated in new developments to capture/reuse/recycle water should be encouraged.

13.2 The recently finalised Deben Estuary Plan (and forthcoming Alde/Ore Estuary Plan) should be considered in relation to the development of this Plan - in the same way as the Suffolk Shoreline Management Plan. These plans rely upon a willingness to embrace the principle of an integrated system - recognising the need to reconcile the continued wellbeing of the river systems, the interests of the communities and the ecological integrity of unique estuarine environments.

13.3 The concept within these estuary plans, of 'enabling development', proposed as one possible mechanism for funding local flood defences, should be encouraged where proper infrastructure can also be provided.

13.4 Where appropriate development funding should be directed towards flood and coastal defences. Without local contributions of this type, many of our existing settlements will be at risk in the future.

Appendix: Likely Archaeological Assessment Requirements

East Ipswich Plan Area

Martlesham 900a. This site was covered under advice in 2008 for 703. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham 893. This site is close to areas of prehistoric activity (County Historic Environment Record MRM 154, MRM 027). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Westerfield 939. This site is close to the medieval core of the settlement, and within the findspot of Roman, Saxon and Iron Age objects. There is high potential for the development to impact on archaeological remains of these periods. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham EMP1 694 - previous recommendation for early archaeological assessment (sites 721/694/644).

Ransomes EMP2 - This large area (15ha) lies adjacent to a series of burnt pits (County Historic Environment Record PFM 009) and cropmark features of a pre-historic/Roman trackway and associated features to the east (PFM 085). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Framlingham

Wenhaston 938a. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Wenhaston 938b. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. The development also has a frontage onto one of the historic streets of the late Saxon and medieval settlement. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Yoxford 794. No objection in principle but it would any application should include an desk-based assessment and appraisal of structures currently existing on the site. Depending on the results of desk-based assessment, the site may require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham

Aldringham 5668. Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work. Development should be sensitive to the particular historic character of the built environment.

Benhall 969. This site is in a topographically favourable location for early activity overlooking the River Fromus. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6548 - 2581 - Tunstall - None 6548 Comment Woodbridge Housing Market Area Tunstall

work.

Blythburgh 4UCB. This site is in an area of very high archaeological potential within the historic core of Saxon and Medieval Blythburgh. The development fronts historic streets of the settlement. It has remained undeveloped in more recent periods (e.g. as shown on historic OS maps) and there is good potential for preservation of earlier archaeological remains. There could be complex remains surviving. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Blythburgh 3UCB Development on this site should be sympathetic to the historic farmstead, and development proposals should include assessments of historic buildings which are to be altered by the development so that informed decisions can be made. The site has archaeological potential, close to the existing 16th century building and within the historic core of Blythburgh. It would require a planning condition under the NPPF to secure a programme of archaeological work.

Kelsale cum Carleton 884 This site has not been systematically investigated for archaeological remains. It is in a topographically favourable valley side location, and should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Knodishall OPP5 This site lies within the historic settlement core, on the green edge, and development has the potential to impact upon early settlement remains. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Middleton 779 This site lies within the historic settlement core. A prehistoric ring ditch is recorded to the west (County Historic Environment Record MDD 004). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham 1006 This site is in an area of high archaeological potential overlooking the valley of the River Fromus. Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Saxmundham 1009 This site has been partially evaluated for archaeological remains (geophysical survey and some archaeological trial trenching). There are no grounds to object to development, but development will require a planning condition under the NPPF to secure a programme of archaeological work. This should include record of farm buildings, and further evaluation in the first instance. The results of evaluation will inform the overall archaeological investigation strategy.

Woodbridge

Aldeburgh 982 This large site is in an area of high archaeological potential, on a south facing slope overlooking the estuary and Aldeburgh marshes. Medieval archaeological remains are recorded to the north (County Historic Environment Record ADB 004), and Bronze Age to the west (ADB 002). Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Much of the site is within the area of brickworkings associated with the former Read's Brickworks. Desk- based assessment and geophysical survey in the first instance would establish the impacts of this previous landuse. There would be potential for promotion of the heritage of the area.

Hollesley 829 This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the southwest (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Hollesley 9UCH This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the northeast (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Information on buildings on the site should be submitted with any application, should they be impacted on by proposed development.

Hollesley 8UCH. This site lies within the historic core of Hollesley, opposite the church and with a street frontage that has high potential for archaeological remains relating to early settlement. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Early evaluation of the street frontage would be advisable so that archaeological investigation can be factored in to project designs. Evaluation has been carried out towards the rear of the site and did not reveal significant remains.

Orford OPP4 This site is close to a possible mound site (County Historic Environment Record ORF 023), and the site of a windmill depicted on a plan of c1600 (ORF 019). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6548 - 2581 - Tunstall - None 6548 Comment Woodbridge Housing Market Area Tunstall

investigation strategies. Geophysical survey would be appropriate in the first instance.

Shottisham 812b Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work.

Shottisham 812d Exact map location not provided, but the site is within the Anglo-Saxon and Medieval core of the settlement (County Historic Environment Record STT 059), close to the church. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Tunstall 786 - This site lies within and on the edge of the historic settlement core. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Any application should also include an assessment of buildings that are to be affected by development.

Woodbridge 900a - This site lies within an area of archaeological potential, and Neolithic pits and Iron Age features were excavated to the south (County Historic Environment Record MRM 030). The site should be subject to archaeological assessment at an appropriate stage in the design of new development to establish the impacts of past land-use, and ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Summary: Tunstall 786 - This site lies within and on the edge of the historic settlement core. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Any application should also include an assessment of buildings that are to be affected by development.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5519 - 3110 - Ufford - None 5519 Comment Woodbridge Housing Market Area Ufford

Respondent: Mr Michael Cummings [3110] Agent: N/A

Full Text: I have a plot of land at Ufford approximately 1204 square yards and would like to know if it would be possible for this land to be considered for development as part of the SHLAA-site specific land availability assessment development.

The land is situated on Old Church Road and I enclose a plan of the area for your consideration. Summary: I have a plot of land at Ufford approximately 1204 square yards and would like to know if it would be possible for this land to be considered for development as part of the SHLAA-site specific land availability assessment development.

The land is situated on Old Church Road and I enclose a plan of the area for your consideration.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: Land at Old Church Road, Ufford.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5611 - 3178 - Ufford - None 5611 Object Woodbridge Housing Market Area Ufford

Respondent: David & Vallerie Mallett [3178] Agent: N/A

Full Text: I assume that your forward planning up to 2027 is in response to the government's National Planning Policy Framework which required local planning authorities to identify a deliverable five year supply of land for housing. And without such a plan there should be a 'presumption in favour of sustainable development'. I also understand that without a demonstration of land supply by yourselves the door was open to developers to take advantage of this legal loophole to force inappropriate developments onto greenfield sites in local areas despite informed local opposition.

Our green spaces and villages in this part of Suffolk are in imminent danger of being ruined by large, unsympathetic and inappropriate housing developments. This has to stop or be strictly controlled before our much needed farmland and rural landscapes are lost forever.

With regard to our own village (Ufford) unsuitable size of development puts increased strain on village facilities and the two recent planning proposals(Crown nursery and Lodge Road) could increase the village population by over 10%. Additionally there is the loss of valuable open space ,flora and forna and the impact on local medical and educational infrastructure. Indeed when viewing the planning proposals the density,type and style of development is totally out of keeping with the rural character of the village.

I am not against development per se, and indeed expect infill over a period of time. Your designation of an additional 15 houses by 2027 is also very reasonable, what is not acceptable is the negative aspects of housing estates forced onto greenfield land into a village which does not need or wish for them.

Anything that your planning can do to achieve such a balance and give clarity to residents is welcome. Summary: With regard to our own village (Ufford) unsuitable size of development puts increased strain on village facilities and the two recent planning proposals(Crown nursery and Lodge Road) could increase the village population by over 10%. Additionally there is the loss of valuable open space ,flora and forna and the impact on local medical and educational infrastructure. Indeed when viewing the planning proposals the density,type and style of development is totally out of keeping with the rural character of the village.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5644 - 3197 - Ufford - None 5644 Comment Woodbridge Housing Market Area Ufford

Respondent: Mr Bob Bradley [3197] Agent: N/A

Full Text: PROPOSED LAND DEVELOPMENT and ASSOCIATED TRAFFIC PROBLEMS in the UFFORD AREA

COMMENTARY

Following a discussion with our MP, Dr Coffey, on 6th October 2014 about traffic problems and land development, Bob Bradley, Adrian Smith and Brian Taylor held a meeting with our District and County Councillor, Michael Bond, on Tuesday 18th November 2014 to debate the issues further. At this meeting the focus was again the proliferation of land development proposals and the inadequacy of our local road system to cope with a greater volume of traffic. Councillor Bond was sympathetic towards our problems and also expressed concern for other parishes in the area. Many development proposals were discussed but of particular concern was the Ufford B1438 road corridor from Wickham Market to the A1152 at Melton crossroads.

The developments along this stretch of road, both in progress and proposed, are shown as black dots on the accompanying map. Also illustrated are the proposed developments at Woods Lane and the old Girdlestone works site on the A1152 at Melton.

Two major problems will be created if many of the proposed developments proceed to fruition: 1. A much greater burden of traffic at Melton crossroads. 2. A much higher density of traffic in and around Ufford.

From the meeting it was evident that little consideration is being given to the adverse cumulative effect that these developments will have on local road infrastructure. In view of this there was mutual agreement that the authorities must act to ensure that adequate road systems and/or improvements are in place before developments are even considered for planning approval.

Further discussion at the meeting involved the following specific traffic problems associated with Melton and Ufford.

THE MELTON PROBLEM

Melton village is the main singular gateway to the peninsula area of Suffolk Coastal District and has fallen victim to the areas popularity and business interests. The main difficulty at Melton is that the majority of peninsula traffic enters a pinch point at the crossroads with the B1438 serving Wickham Market and Woodbridge.

The main areas generating the increasing volume of traffic at the crossroads are: 1. The tourist attraction of the peninsula scenic area itself, including Bawdsey, Sutton Hoo, Orford, Snape Maltings and the Rendlesham Forest Centre. 2. The MOD Woodbridge military establishment. 3. Rendlesham village (a developing major residential site). 4. Bentwaters Parks (a developing commercial site of 380 hectare and around 360 buildings). Also, to a lesser extent, there is the traffic associated with the recreational facilities of Woodbridge Rugby Football Club and the Woodbridge Golf Club.

To compound the problem there are three additional areas of proposed development that will seriously affect the situation: 1. The relocation of the Suffolk Coastal District Council (SCDC) offices to the old Girdlestone works site at Melton (or any other development of this site). It should be noted that the parking facility at SCDC Melton Hill currently accommodates well over 200 vehicles. 2. The proposed residential development of 180 dwellings at Woods Lane, Melton which will generate a high volume of traffic. 3. Additional traffic coming from Wickham Market and Ufford on the B1438. (See THE UFFORD PROBLEM below).

THE UFFORD PROBLEM

To assess the impact of the likely increased traffic density in Ufford the following main developments and proposed developments along the B1438 road corridor were highlighted: 1. Deben Mews, Wickham Market, housing development. (11 dwellings) 2. Wickham Place, Wickham Market, housing development. (65 dwellings) 3. Lodge Road, Ufford, proposed housing development. (25 dwellings) 4. Crown nursery, Ufford, proposed housing development. (31 dwellings) 5. Notcutts nursery, Ufford, proposed relocation of Woodbridge Football Club and associated facilities (or any other development of this site). 6. Yarmouth Road, Melton, proposed housing development. (154 dwellings, plus a 60 bed nursing home and 50 assisted living apartments) 7. St Audry's Sports Club site, Melton, proposed housing development. (12 dwellings)

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5644 - 3197 - Ufford - None 5644 Comment Woodbridge Housing Market Area Ufford

This makes a total of 298 new dwellings, (not including the likely traffic volume from the 60 bed nursing home or the 50 assisted living apartments). Also, no assessment is made of the likely number of vehicles from any development of the Notcutts nursery site at Ufford.

It is to be expected that a significant number of vehicles using the proposed developments at 5, 6 and 7 above will enter Melton but drivers wishing only to find an easier route to the A12 will head for Ufford. Unfortunately for Ufford there is already evidence that the village is being used as a peak period 'rat run' for drivers from the peninsula area getting to and from the A12. This will undoubtedly become a major problem for Ufford as the congestion at Melton gets worse.

At our meeting with Councillor Bond we emphasised that, as a local resident group, we are not opposed to development but it was to be expected that any such undertakings must be appropriate in nature and sensible in scale. Above all, the relevant authorities must ensure that they and the developers give due respect and consideration for the welfare and safety of local communities with regard to road capacities.

In view of the proposed developments in and around Ufford we suggested two immediate local road improvements to ease the likely higher density of traffic.

1. The provision of a roundabout at the B1438 junction with the A12, essentially to handle the likely high volume of traffic using any proposed commercial or domestic development of the Notcutts nursery site. A roundabout at this location could offer a dedicated access to any development without the need to use the B1438 at all. It is also a probability that traffic from the proposed developments at Yarmouth Road, Melton and St Audry's, Melton will also access the A12 at Ufford to avoid congestion at Melton. A roundabout would also allow vehicles to go East on the A12 instead of travelling through the village towards Wickham Market to do so.

It has been stated that the A12 at this point offers an unencumbered run that speeds up traffic and therefore makes it an unsuitable location for a roundabout. It must be pointed out that this is not the case for vehicles travelling from the East. Here, the dual carriageway reduces to a single carriageway precisely at the point where vehicles from the B1438 are trying to join it. It should be appreciated that when vehicles are decelerating from high speeds and vying for position to join the single carriageway there is little room for error. This problem will be made worse by adding more traffic to the B1438. 2. The provision of an access slip road from the B1438 out of Wickham Market and onto the A12 towards Ipswich. This would remove the need for vehicles to go through Ufford to gain access.

Although the meeting with Councillor Bond was enlightening it was evident that there is no immediate central government funding or local authority funding available for any local road improvements. It was also considered highly unlikely that the developers would be able to make any contribution in this respect.

This serves only to re-emphasise that the authorities must act to ensure that adequate road systems and/or improvements are in place before developments are even considered for planning approval.

We will working with Ufford Parish Council and other local parishes to address this important issue. Summary: Although the meeting with Councillor Bond was enlightening it was evident that there is no immediate central government funding or local authority funding available for any local road improvements. It was also considered highly unlikely that the developers would be able to make any contribution in this respect.

This serves only to re-emphasise that the authorities must act to ensure that adequate road systems and/or improvements are in place before developments are even considered for planning approval.

We will working with Ufford Parish Council and other local parishes to address this important issue.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5658 - 3207 - Ufford - None 5658 Object Woodbridge Housing Market Area Ufford

Respondent: Carole & Roger Steele [3207] Agent: N/A

Full Text: I just wanted to pass a few comments on to you regarding the planning for Ufford. We have lived in the village for 20 years, we have enjoyed our time and would like to carry on enjoying the next few years. With all the planning that has been put forward it will be the death of this lovely village. We have no school and no shop so if all the planning goes ahead it will cause so much more traffic. The roads will not be able to cope and even now we get more traffic than we use too. We live in Lodge Rd, if planning goes ahead opposite our houses all our natural light will be blocked. The land is elevated, which means that houses will tower over us. This is green belt land, surely brownfield sites should be used first. Also there is the risk of flooding, even now when we have heavy rain it's like a river running down the road. With all the houses going up at Wickham Market and the infills that we already have had this will put pressure on the Doctors and the schools. Please could our lovely countryside be considered, none of us want a housing estate put on our doorstep it's so out of keeping. Summary: With all the planning that has been put forward it will be the death of this lovely village. We have no school and no shop so if all the planning goes ahead it will cause so much more traffic. The roads will not be able to cope and even now we get more traffic than we use too. There is the risk of flooding, when we have heavy rain it's like a river running down the road. Please could our lovely countryside be considered, none of us want a housing estate put on our doorstep it's so out of keeping.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5844 - 3285 - Ufford - None 5844 Comment Woodbridge Housing Market Area Ufford

Respondent: Ufford Parish Council (Mrs Judi Hallett) [3285] Agent: N/A

Full Text: Ref: Local Plan Documents - Issues and Options Consultation I write with reference to the above on behalf of Ufford Parish Council. Over the past few weeks, Ufford Parish Council and residents have discussed the following questions: 1. Current Balance of Housing in Ufford - It is the Parish Council's opinion that Ufford currently has the correct balance of housing to meet local needs. We have a number of houses under the control of Flagship Housing and a diverse range of houses from 'terraced' to 'detached'. We have not been recently advised by any residents of the need for different types of housing. 2. How many additional houses should Ufford provide between now and 2027 - Ufford Parish Council is aware that there is a need for the parish to provide some additional housing and we are in agreement with the draft local plan that 15 would be an acceptable number. However, only this week a development at Crown Nursery has been approved that will see an additional 34 houses built in the village. At recent UPC meetings, members of public have raised concerns about the current level of development plans and suggested that no further dwellings are required. 3. Housing Sites - We note that your draft document now shows all sites in Ufford as 'unsuitable' for development and we are in complete agreement with this. However, to reiterate our comments made in October 2014:

Ref Site Comments from Ufford Parish Council 586a Land adjacent to houses at Lodge Road Proposed number of houses (5) seems reasonable 997a Land at Crown Nursery This site now has planning permission for 34 dwellings!

4. Areas to be protected from Development - Ufford Parish Council feel very strongly that land between Spring Road, School Lane and Barrack Lane, a natural flood meadow, should be protected from development at all cost (Sites 988, 992 and 993 on Plan 3). We will be working closely with SCDC when the Ufford Conservation Area is re-appraised and we will be asking for this land to be included in the designated conservation area so that it can be protected. 5. Development in other neighbouring parishes - We are aware of a number of potential houses being built at Melton and Wickham Market. The continued development of the corridor best described as the 'Old A12' causes daily issues for Ufford residents. Commuters who have to travel between 8.00am and 9.00pm find themselves crawling through Melton, sometimes taking up to 30 minutes to cover half a mile. There is real concern about the lack of infrastructure improvements to allay the effects of the additional traffic caused by the number of additional dwellings in the area. If you have any queries please do not hesitate to contact me. Summary: It is the Parish Council's opinion that Ufford currently has the correct balance of housing to meet local needs. We have a number of houses under the control of Flagship Housing and a diverse range of houses from 'terraced' to 'detached'. We have not been advised by any residents of the need for different types of housing. Ufford Parish Council is aware of the need for the parish to provide some additional housing; we are in agreement that 15 would be an acceptable number. However, development at Crown Nursery has been approved that will see an additional 34 houses built.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: Ufford_150225 - Issues and Options response FINAL (3).docx

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5967 - 3320 - Ufford - None 5967 Comment Woodbridge Housing Market Area Ufford

Respondent: Mr Vincent Smith [3320] Agent: N/A

Full Text: District Local Plan consultation

I am writing with comments on the planning policy proposals set out in the December 2014 consultation document as they relate to Ufford.

Questions 1 and 2: general approach

The proposal indicates that Ufford will need to find the space for 15 new homes between now and 2027 - this in addition to the 13 houses built in the village or given planning permission since the beginning of 2010. It is not clear whether the proposed development of 5 or more houses at Lodge Road just off the High Street is included in the '13' given permission or whether they would be part of the proposed allocation of 15 future houses.

On any basis, however, the addition of nearly 30 new homes in a village of less than 1,000 inhabitants is a substantial increase over the planning period. By way of comparison, Orford, of similar size (and described as a 'Key Service Centre'), is said only to require 5‐10 new homes in the same period. The reasons for the allocations between areas is not fully articulated in the document - and I suggest that 15 new houses in Ufford is probably a little beyond what is either sensible (given the facilities in Ufford - see below) or the likely development plots available in the village.

The proposals also do not 'assess' sites which are not suitable for building at least 5 houses or are less than 0.25 h: since almost all of the recent development in Ufford has been of this kind, this seems a major omission from the Council's planning. I would have thought that all of the new houses built to 2027 in Ufford are likely to be in groups of less than 5 homes. It seems unreasonable for the Council simply to monitor the situation and to treat any such 'small' infill developments as planning "windfall" (para. 3.8): this in fact will mean that Ufford's housing numbers will increase by significantly more than the proposed allocation. "Windfall" gains should be offset against planned housing numbers.

Questions 6-•‐7: physical/planning boundary

The proposed plan does not appear to change the planning boundary for Ufford, and this seems sensible. As para. 3.32 of the document notes, retaining the existing boundary is most appropriate where development is likely to be of an

'infill' nature - as is the case in Ufford -•‐ ensuring that the physical cohesiveness of the village is retained.

I also believe it is important that the separate identity of Ufford is maintained. At present Ufford Park hotel and golf course and the nursery areas near the District Council's depot on Yarmouth Road ensure a stretch of openness between Ufford and Melton: this should be preserved. It would be unfortunate if piecemeal 'sub-rural' development created a built up link along the Yarmouth Road between Ufford and what I have seen referred to as the "greater Woodbridge" area.

Questions 30-•‐31: infrastructure/facilities

Although identified as a 'Local Service Centre', the services available in Ufford itself are very limited (there is no shop and only a Post Office van for 2 hours a week, for example). It is not clear whether the proposed plan has taken into account the variation in services available in different 'Local Service Centres' - Ufford is reliant on facilities in Wickham Market and Woodbridge (2 and 3 miles away).

As noted in a recent article in the village magazine ("Punch"), given the configuration of the road layout in the village, an increase in development in Ufford could well lead to traffic problems on the Yarmouth Road - and in particular in Melton at the crossroads, through which substantially increased traffic would flow as a result of planned and future development. Any plan will need to take proper account of this issue.

For those not using a car, an increased frequency in the daytime bus service between Wickham Market and Woodbridge through Ufford would be of significant benefit.

Planning maps

I note that 'Map 3 - Ufford SHLAA sites' identified two sites near Midsummer Cottage as 'unsuitable for development' (992 and 993), with one being adjacent to us (992), on the grounds, among others, of the increased flood risk development would cause. I fully agree with this. Any building on the water meadows to the west of Spring Lane which reduces their ability to absorb often large amounts of rain run-off will necessarily lead to an increase in the already significant risk of flood in Lower Ufford, as Byng Brook will become even more overloaded than at present. Midsummer Cottage - as noted in the plan, grade II listed and in the village conservation area - would be among the most immediately and worst affected.

Indeed I believe that the map should be amended to join SHLAAs 992 and 993 into one and also to extend the 'unsuitable for development' designation to the whole of the water meadows (up to and including SHLAA 988), precisely because of the flood risk: development of any of this area would also of course substantially and irretrievably

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5967 - 3320 - Ufford - None 5967 Comment Woodbridge Housing Market Area Ufford

compromise the landscape character of the village as a whole.

Finally I note that at least two of the SHLAAs on the map (838b and 997a) are already the subject of planning applications or advanced proposals for development. It would be unfortunate if this development plan were compromised by development on SHLAAs noted as 'unsuitable' even before the District Council has finalised them. Summary: I note that Map 3 identified two sites as 'unsuitable for development' (992 and 993), on the grounds of the increased flood risk. I fully agree with this. Any building on the water meadows to the west of Spring Lane which reduces their ability to absorb large amounts of rain run-off will necessarily lead to an increase in the already significant risk of flood in Lower Ufford, as Byng Brook will become even more overloaded than at present. Midsummer Cottage-as noted in the plan, grade II listed and in the conservation area-would be among the most immediately and worst affected.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6105 - 3357 - Ufford - None 6105 Comment Woodbridge Housing Market Area Ufford

Respondent: Artisan Planning & Property Services Ltd (Mr Max Agent: N/A Short) [3357]

Full Text: 1. Introduction and Site 997b (SHLAA 2014) 1.1 The site to which this representation relates is an area of land comprising the remaining area of land at Crown Nursery in the centre of Ufford village. The site is owned and operated by Crown Nursery and is presently an active employment area and business. This representation is made on their behalf by Landex Ltd., their chosen development partner. 1.2 The site is also identified as site 997b as shown on the map of Ufford SHLAA sites in the unnumbered Map Booklet of the Site Allocations and Area Specific Policies document (SAASP 2015). It is adjacent the identified existing physical limits boundary of the village and in the same position in the 'suggested' physical limits boundary in the Council's consultation document. 1.3 This representation is made on the basis that the SAASP does not make adequate allocation of land both quantitatively and qualitatively for housing and/or employment purposes and rejects the subject site, site 997b by its exclusion from the suggested settlement boundary. 1.4 Site 997b was the subject of representations/response to the Council's Call for Sites exercise in 2013/2014 which forms the evidence base for the 2014 SHLAA and is recorded by the Council as 'unsuitable' primarily because of its existing employment use and therefore against extant policy to lose to housing use and a technical deficiency based upon an apparent waste water capacity issue. 1.5 The starting point for housing land supply considerations and the allocation of land for that purpose, both within the Core Strategy 2013 (CS) (which is the overarching planning document for the District, and the SAASP 2015 is the agreed scale of growth over the plan period (2010 to 2027). This is recognised at paragraph 1.11 of the SAASP 2015. 1.6 However, this gives no recognition/acknowledgement of the Inspector's findings and recommendations in his Report on the Council's 2013 CS which was found to be 'sound' but only on the basis that the Council gave an undertaking to an early review. A summary extract from the Inspector's Report of June 6, 2013 is reproduced below setting out what the Inspector expected the Council to do in such a review:-•‐‑ o Include a policy on the presumption in favour of sustainable development. o Introduce a clear commitment to an early review of the Core Strategy to address full, objectively assessed housing needs; o Clarify that the full, objectively assessed housing need for the District in the plan period at this point is 11,000 new dwellings; o Amend plan to provide for at least 7,900 new homes in the plan period

2. The Representation 2.1 For the avoidance of doubt, the Council'ʹs analysis of site 997b in the SHLAAA Assessment 2014, in terms of its sustainability characteristics and suitability for development resulting in the site being considered unsuitable, is endorsed by the landowners who confirm that the land is available and deliverable within the next 5 years. 2.2 The assessment was oversimplified, rushed, superficial and there was no engagement/dialogue with the landowner. The Council's appraisal/assessment failed to take into account the current use of parts of the land for established employment purposes, the land's general characteristics land, its availability and deliverability for both employment and housing purposes. The Council simply missed the opportunity to allocate an appropriate area of land in this 'local service centre' designated village because its assessment of the land was wrong. 2.3 Moreover the 'Plan' has already been superseded by the grant of Planning Permissions 14/3558 and 14/3560 for a total of 34 new dwellings on part of the Crown Nursery land on February 16 2015 including all of site 997a (SHLAA) and part of site 997b. The Council's Nov. 2014 SHLAA assessment indicates that none of the submitted and considered sites are suitable (Table 1 within the SAASP 2015) which we also do not accept. The settlement boundary as suggested is therefore inappropriate. 2.4 The Council'ʹs CS 2013, in terms of housing land supply is predicated upon an allocation of land with which to provide 7900 dwellings over the plan period. There is nothing in the FPAAP 2015 to suggest that the Council has implemented one of the main recommendations of the Inspector's Report of the CS 2013 to undertake an update of its objectively assessed housing need or whether having done so, it reasserts the position it adopted in 2013 that 7900 dwellings was all that was required when at that time, the Inspector had evidence before him that suggested that the actual level of housing need was much greater and was at least 11,000 dwellings. 2.5 Notably, Issue 2 as identified by the Inspector in his Report of June 6 2013 was: - "Whether the overall level of housing provision and its distribution are justified and appropriate" 2.6 In his deliberations and in trying to address the issue identified above there are further key paragraphs within the Inspector's Report which are copied in full below.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6105 - 3357 - Ufford - None 6105 Comment Woodbridge Housing Market Area Ufford

46. However, in terms of the Framework, the scale of housing provision proposed falls substantially short of the objectively assessed need. Even if the theoretical capacity of all the sites included in the Strategic Housing Land Availability Assessment (SHLAA), existing commitments, potential brownfield opportunities, allocations carried forward from the previous Local Plan and a windfall allowance were taken into account, the provision would still fall some way short of the 11,000 dwellings required. While there is no persuasive evidence before the examination that environmental, infrastructure or other factors might restrict this amount of development if any required mitigation could not be achieved, this would have to be assessed. 53. The Council has proposed modifications intended to bring greater flexibility tothe identification of housing sites in the different settlements in the District (MM24, MM26, MM27, MM28, MM29). Taking these into account and with the main modifications that remove the ceiling on the amount of housing to be provided and clarify the approach to phasing, they would provide the necessary flexibility to assist in addressing housing needs and boosting the land supply in the initial part of the plan period. As such, I conclude that in this case having the CS in place at an early stage would support the achievement of sustainable development and bring forward sites to meet the housing needs of the area. An early review would be preferable to the alternative of suspension and likely withdrawal of the plan in terms of achieving the aims of the Framework taken as a whole. The main modifications that would set out the principles of the review are therefore necessary for the plan to be sound (MM3 (part), MM4 (part), MM25 (part)).

2.7 In para. 35 of the Inspectors Report the Council is reported to have responded to the Inspector that the indicative level of housing need in the District for the Plan Period at 11,000 dwellings 'was about right' In the absence of evidence to the contrary which is that of an up to date objective assessment of housing needs it is difficult to understand let alone accept why this new plan should be based upon a level of housing need which is already inadequate for the purpose. 2.8 In summary therefore, this representation takes the position that the Housing Section 3 of the SAASP 2015 Issues and Options, needs to bring clarity to the overall scale of housing growth based upon a 2015 assessment of the objectively assessed housing needs of the District and then to apply the agreed level of growth to the constituent identified spatial areas. The starting point base line figure of 7900 dwellings needed for the District in the 2013 CS and the calculations specific to the Felixstowe area are flawed and an under provision as the Council has already acknowledged in its response to the Inspector in 2013. 2.9 It is therefore inappropriate to prepare a site specific allocation document on the basis of a minimum identified need of 7900 dwellings as appears to be the case here. The appropriate starting point is the 2015 position of objectively assessed housing need which in itself will be an update of the recorded Council position before the CS Inspector of June 2013 when it agreed that the 11,000 dwellings need identified in evidence at that time was 'about right'.

Employment land 2.10 The Core Strategy 2013 identifies as an objective (5), to 'sustain, strengthen and diversify the rural economy' and to 'support growth and regeneration of the local economy' and those objectives cannot be realised without the allocation of additional land for employment purposes. This is where we disagree with the SAASP 2015 2.11 However, it may be that the existing designation of the Crown Nursery site for employment purposes, as was evident in the assessment of the two recent planning applications for parts of the site for residential development, may already be fulfilling what we say is necessary. However, this objection is wider and deeper than the simple lack of an appropriate land use designation for parts of 997b as we say that the positive allocation of a mixed use site here in Ufford (and in other locations within the District) would be both beneficial and advantageous in delivering the identified objectives of the CS. 2.12 Paragraph 4.2 of the SAASP 2015 fails to recognise the importance of small-•‐‑scale employment sites to the various communities and settlements located in the District. The following extract taken from the Felixstowe Peninsula Plan is just as appropriate to the rest of the District. "Many of these employment sites are in regular use and provide local employment opportunities as well as contributing to the economic growth and prosperity of the district" 2.13 That simple recognition should be developed and enlarged to include the allocation of additional employment land and/or mixed land use sites for the purpose as the way in which we work and where we do it, continues to evolve. In some instances that may just mean a regeneration of existing accommodation but in others it means new development of a much higher standard taking advantage of new technology and connectivity and contributing towards more sustainable development. 2.14 Representations made by the landowners of site 997b to the Council'ʹs 2013/2014 'call for sites' submission was that of a mixed use site for both housing and employment provision. The subsequent assessment by the Council failed to

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6105 - 3357 - Ufford - None 6105 Comment Woodbridge Housing Market Area Ufford

recognise that there is already small/medium scale employment located on the Crown Nursery land and that there is the opportunity to provide additional surplus land for further small-•‐‑scale employment accommodation. That is an opportunity not to be missed and is entirely in accordance with extant Planning Policy at all levels. 2.15 The Council's reported annual, Employment Land Availability Assessment simply records the amount of land already committed for industrial and business development within the district and in respect of the wider District concludes that no new land allocation is necessary as appears in the draft SAASP. We say that this does not go far enough in recognising the need and the opportunity elsewhere within the District in locations such as Ufford. 2.16 There is an identified need recorded at paragraph 5.4 of the FPAAP 2015 for a further 8.5 ha of additional land within the district which is required to support business and help facilitate the creation of new jobs. It is expected that part of the 8.5 hectares of employment land needed will be located within the Felixstowe Peninsula area in order to facilitate potential employment generating uses. We say that the surplus land at Crown Nursery is capable of delivering some of that employment land need and that should be recognised in the emerging plan. 2.17 The Plan anticipates and recognises that sites may come forward for employment purposes in the area (and therefore as yet not identified). In qualitative terms, the potential employment land available at Crown Nursery is capable of delivering the type of business activity that will not give rise to adverse impact on the local highway network or to neighbouring residents. Generally speaking the type of employment uses (B1 category) will not give rise to any adverse impact on the amenity of the area but will be able to contribute to the overall sustainability of the district. 2.18 The land at Crown Nursery should be reconsidered for its potential to offer deliverable employment land. Summary: There is an identified need recorded at paragraph 5.4 of the FPAAP 2015 for a further 8.5 ha of additional land within the district which is required to support business and help facilitate the creation of new jobs. It is expected that part of the 8.5 hectares of employment land needed will be located within the Felixstowe Peninsula area in order to facilitate potential employment generating uses. We say that the surplus land at Crown Nursery is capable of delivering some of that employment land need and that should be recognised in the emerging plan.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5475 - 3096 - Wickham Market - None 5475 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mr A G Ellam [3096] Agent: N/A

Full Text: Re: Proposed SHLAA Sites for Wickham Market (Map 3).

My comments are as follows:

Proposed allocation of land for building 776l: currently this land is used as allotments by residents of the village. These allotments are well used and would be an enormous loss to the village in terms of community activity, health benefits and psychological wellbeing for village residents.

Proposed allocation of land for building 776i: currently agricultural land that is regularly cultivated. A proposal to build up to 71 houses on this land could not (in my opinion) be supported by access arrangements - Spring Lane is a single track carriage way and would not be able to provide manageable, practical access to and from the proposed housing estate. Further, I would have concerns about the capacity of the river Deben to cope with the additional 'run off' of rain that would occur as a result of building on this land - the increased sewage may also overload the current capacity of the local sewage facility. Lastly, it would encroach on an attractive rural landscape. Summary: 776l:this land is used as allotments. They are well used and would be an enormous loss to the village in terms of community activity, health benefits and psychological wellbeing.

776i:agricultural land that is regularly cultivated. A proposal to build upto 71 houses on this land could not be supported by access arrangements-Spring Lane is a single track carriageway. I would have concerns about the capacity of the Deben to cope with additional 'run off' of rain that would occur-the increased sewage may also overload the current capacity of the local sewage facility. It would encroach on an attractive rural landscape.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5489 - 3106 - Wickham Market - None 5489 Object Woodbridge Housing Market Area Wickham Market

Respondent: Wickham Market Parish Council (Mr Richard Agent: N/A Jenkinson) [3106]

Full Text: Wickham Market Parish Council were pleased to receive the Site Allocations and Area Specific Policies Local Plan Document, Issues and Options Consultation document (Reference A) together with the associated map booklets. We note, with some comfort that as we have already had some 100 houses built in the village since 2010 that our allocation from now up to 2027 is zero.

Prior to receiving this document the Parish Council had held a number of meetings regarding possible future development in Wickham Market. During these meetings it became clear that there were some possibilities for development, but that certain options would be against the wishes of a large proportion of the local residents. The criteria used to assess whether a site was suitable or not were: Access Contiguous with the village Visual Aspect Land Use

We were also pleased to be invited to discuss the draft document with SCDC on 22nd September 2014. Having now received Reference A and the associated map booklets we have discovered that there are a number of items that are causing us concern. The main issue is with regards to sites 776l and 776i being indicated as having housing capacity. 776l was included in the previous SHLAA as suitable, but 776i was considered unsuitable. In Reference A both sites are now listed as suitable for housing development.

The 776l site is the Glebe allotments; these allotments have been well used for a considerable length of time and they are considered to be excellent allotments. They are centrally placed in the village allowing easy access, they have good soil and a number of long standing allotment holders. The Allotments Association have made it very clear that they do not wish to lose this area to development and it would be an enormous loss to the village in terms of community activity, health benefits and psychological wellbeing for village residents.

When the previous SHLAA was published the fact that the Glebe Allotments were included for possible development was perhaps the only issue where all residents were united in opposing this possible development. This fact was made clear to officers at our meeting on 22nd September 2014. Access to this site is only possible through Yew Tree Rise on the northern boundary. This access would cross a well-used footpath and increase the traffic in Yew Tree Rise to an unacceptable level. Parking is already at a premium in this estate and Yew Tree Rise is the main street parking area providing for High Street residents in addition to the estate residents. This means that Yew Tree Rise is, effectively, a single track road and as such would not be acceptable as access. Should Yew Tree Rise be made a no parking zone then the parking loss of would cause difficulty to those that currently use it as there is no nearby, suitable alternative.

As site 776l is used as allotments these would have to be re-provided should this land be used for development. The assumption is that the use would be moved into 776i, this would have disastrous consequences for the allotment holders. 776i is an east facing sloping field, exposed, poor draining and further away from the centre of the village making access more difficult. The current allotments provide a sustainable location easily accessible for most users by foot or cycle. DM33 states that The Council will resist the loss of existing allotments to other uses unless suitable alternative allotments of equivalent size and quality are provided in the locality. The only exceptions to this policy will be where: a. there is overwhelming evidence to show that there is unlikely to be any future demand for the allotments; and b. other allotments already exist and have the necessary spare capacity, and the District Council is satisfied that a recreation or community use is not appropriate. Neither of the above apply in this case.

The 776i site is the east facing field adjacent to the Glebe allotment. This site has no access unless it is through site 776l. To increase the traffic in Yew Tree Rise by cars accessing 100 houses, in addition to a new allotment site, would untenable. To the east of the site is Spring Lane, a single track road that it is not possible to widen so this is not suitable for highway access. At the south west of the site access is not feasible as it would encroach on an area designated as 'protected from development'. Consequently the only access is through 776l. Development of this site would significantly increase run-off and there are already issues of flooding of the Deben on the land below this site. One landowner is already having significant issues as when the River Deben floods, raw sewage overflows onto his caravan site causing a significant health and safety risk. Finally it would be a very visually obtrusive for those travelling south on the A12.

Consequently it is the view of Wickham Market residents that, under no circumstances, should the sites 776l and 776i be considered for housing development.

A more minor issue is that the land behind Hasnips, 200 High St, is now included in the built area boundary and this land is currently unacceptable for development due to access

restrictions. Development will create further problems for our High Street and is unlikely to 'preserve or enhance the character of the village conservation area'.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5489 - 3106 - Wickham Market - None 5489 Object Woodbridge Housing Market Area Wickham Market

It was also disappointing to note that the land that we suggested for employment or industrial development to the north of the Riverside Industrial Estate was not included in the plan.

Finally, should Wickham Market be required to take additional housing development then the view of the Parish Council, having taken account of the views of residents, is that this should be site 421. This site has the potential for good access. The site could be designed to ensure minimum visual and environmental impact on the neighbouring River Deben SLA. There is also the potential for additional accessible green space to be incorporated to serve the needs of the community and finally it is contiguous to the village. In addition it would enable us to reduce the speed limit on Border Cot Lane to 30mph which we feel would be a very positive way of increasing safety for village residents. Summary: Site 776l is the Glebe allotments; these have been well used for a considerable length of time and are considered to be excellent allotments. They are centrally placed allowing easy access, have good soil and a number of long standing allotment holders. The Allotments Association have made it clear that they don't wish to lose this area to development. It would be an enormous loss to the village in terms of community activity/health benefits and psychological wellbeing for residents. It is the view of Wickham Market residents that under no circumstances should sites 776l and 776i be considered for development.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5490 - 3106 - Wickham Market - None 5490 Object Woodbridge Housing Market Area Wickham Market

Respondent: Wickham Market Parish Council (Mr Richard Agent: N/A Jenkinson) [3106]

Full Text: Wickham Market Parish Council were pleased to receive the Site Allocations and Area Specific Policies Local Plan Document, Issues and Options Consultation document (Reference A) together with the associated map booklets. We note, with some comfort that as we have already had some 100 houses built in the village since 2010 that our allocation from now up to 2027 is zero.

Prior to receiving this document the Parish Council had held a number of meetings regarding possible future development in Wickham Market. During these meetings it became clear that there were some possibilities for development, but that certain options would be against the wishes of a large proportion of the local residents. The criteria used to assess whether a site was suitable or not were: Access Contiguous with the village Visual Aspect Land Use

We were also pleased to be invited to discuss the draft document with SCDC on 22nd September 2014. Having now received Reference A and the associated map booklets we have discovered that there are a number of items that are causing us concern. The main issue is with regards to sites 776l and 776i being indicated as having housing capacity. 776l was included in the previous SHLAA as suitable, but 776i was considered unsuitable. In Reference A both sites are now listed as suitable for housing development.

The 776l site is the Glebe allotments; these allotments have been well used for a considerable length of time and they are considered to be excellent allotments. They are centrally placed in the village allowing easy access, they have good soil and a number of long standing allotment holders. The Allotments Association have made it very clear that they do not wish to lose this area to development and it would be an enormous loss to the village in terms of community activity, health benefits and psychological wellbeing for village residents.

When the previous SHLAA was published the fact that the Glebe Allotments were included for possible development was perhaps the only issue where all residents were united in opposing this possible development. This fact was made clear to officers at our meeting on 22nd September 2014. Access to this site is only possible through Yew Tree Rise on the northern boundary. This access would cross a well-used footpath and increase the traffic in Yew Tree Rise to an unacceptable level. Parking is already at a premium in this estate and Yew Tree Rise is the main street parking area providing for High Street residents in addition to the estate residents. This means that Yew Tree Rise is, effectively, a single track road and as such would not be acceptable as access. Should Yew Tree Rise be made a no parking zone then the parking loss of would cause difficulty to those that currently use it as there is no nearby, suitable alternative.

As site 776l is used as allotments these would have to be re-provided should this land be used for development. The assumption is that the use would be moved into 776i, this would have disastrous consequences for the allotment holders. 776i is an east facing sloping field, exposed, poor draining and further away from the centre of the village making access more difficult. The current allotments provide a sustainable location easily accessible for most users by foot or cycle. DM33 states that The Council will resist the loss of existing allotments to other uses unless suitable alternative allotments of equivalent size and quality are provided in the locality. The only exceptions to this policy will be where: a. there is overwhelming evidence to show that there is unlikely to be any future demand for the allotments; and b. other allotments already exist and have the necessary spare capacity, and the District Council is satisfied that a recreation or community use is not appropriate. Neither of the above apply in this case.

The 776i site is the east facing field adjacent to the Glebe allotment. This site has no access unless it is through site 776l. To increase the traffic in Yew Tree Rise by cars accessing 100 houses, in addition to a new allotment site, would untenable. To the east of the site is Spring Lane, a single track road that it is not possible to widen so this is not suitable for highway access. At the south west of the site access is not feasible as it would encroach on an area designated as 'protected from development'. Consequently the only access is through 776l. Development of this site would significantly increase run-off and there are already issues of flooding of the Deben on the land below this site. One landowner is already having significant issues as when the River Deben floods, raw sewage overflows onto his caravan site causing a significant health and safety risk. Finally it would be a very visually obtrusive for those travelling south on the A12.

Consequently it is the view of Wickham Market residents that, under no circumstances, should the sites 776l and 776i be considered for housing development.

A more minor issue is that the land behind Hasnips, 200 High St, is now included in the built area boundary and this land is currently unacceptable for development due to access

restrictions. Development will create further problems for our High Street and is unlikely to 'preserve or enhance the character of the village conservation area'.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5490 - 3106 - Wickham Market - None 5490 Object Woodbridge Housing Market Area Wickham Market

It was also disappointing to note that the land that we suggested for employment or industrial development to the north of the Riverside Industrial Estate was not included in the plan.

Finally, should Wickham Market be required to take additional housing development then the view of the Parish Council, having taken account of the views of residents, is that this should be site 421. This site has the potential for good access. The site could be designed to ensure minimum visual and environmental impact on the neighbouring River Deben SLA. There is also the potential for additional accessible green space to be incorporated to serve the needs of the community and finally it is contiguous to the village. In addition it would enable us to reduce the speed limit on Border Cot Lane to 30mph which we feel would be a very positive way of increasing safety for village residents. Summary: Site 776i has no access unless it is through site 776l. At the south west of the site access is not feasible as it would encroach on an area designated as 'protected from development'. Development of this site would significantly increase run-off and there are already issues of flooding of the Deben on the land below this site. One landowner is already having significant issues; when the River Deben floods, raw sewage overflows onto his caravan site causing a significant health and safety risk. Finally it would be a very visually obtrusive for those travelling south on the A12.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5491 - 3106 - Wickham Market - None 5491 Support Woodbridge Housing Market Area Wickham Market

Respondent: Wickham Market Parish Council (Mr Richard Agent: N/A Jenkinson) [3106]

Full Text: Wickham Market Parish Council were pleased to receive the Site Allocations and Area Specific Policies Local Plan Document, Issues and Options Consultation document (Reference A) together with the associated map booklets. We note, with some comfort that as we have already had some 100 houses built in the village since 2010 that our allocation from now up to 2027 is zero.

Prior to receiving this document the Parish Council had held a number of meetings regarding possible future development in Wickham Market. During these meetings it became clear that there were some possibilities for development, but that certain options would be against the wishes of a large proportion of the local residents. The criteria used to assess whether a site was suitable or not were: Access Contiguous with the village Visual Aspect Land Use

We were also pleased to be invited to discuss the draft document with SCDC on 22nd September 2014. Having now received Reference A and the associated map booklets we have discovered that there are a number of items that are causing us concern. The main issue is with regards to sites 776l and 776i being indicated as having housing capacity. 776l was included in the previous SHLAA as suitable, but 776i was considered unsuitable. In Reference A both sites are now listed as suitable for housing development.

The 776l site is the Glebe allotments; these allotments have been well used for a considerable length of time and they are considered to be excellent allotments. They are centrally placed in the village allowing easy access, they have good soil and a number of long standing allotment holders. The Allotments Association have made it very clear that they do not wish to lose this area to development and it would be an enormous loss to the village in terms of community activity, health benefits and psychological wellbeing for village residents.

When the previous SHLAA was published the fact that the Glebe Allotments were included for possible development was perhaps the only issue where all residents were united in opposing this possible development. This fact was made clear to officers at our meeting on 22nd September 2014. Access to this site is only possible through Yew Tree Rise on the northern boundary. This access would cross a well-used footpath and increase the traffic in Yew Tree Rise to an unacceptable level. Parking is already at a premium in this estate and Yew Tree Rise is the main street parking area providing for High Street residents in addition to the estate residents. This means that Yew Tree Rise is, effectively, a single track road and as such would not be acceptable as access. Should Yew Tree Rise be made a no parking zone then the parking loss of would cause difficulty to those that currently use it as there is no nearby, suitable alternative.

As site 776l is used as allotments these would have to be re-provided should this land be used for development. The assumption is that the use would be moved into 776i, this would have disastrous consequences for the allotment holders. 776i is an east facing sloping field, exposed, poor draining and further away from the centre of the village making access more difficult. The current allotments provide a sustainable location easily accessible for most users by foot or cycle. DM33 states that The Council will resist the loss of existing allotments to other uses unless suitable alternative allotments of equivalent size and quality are provided in the locality. The only exceptions to this policy will be where: a. there is overwhelming evidence to show that there is unlikely to be any future demand for the allotments; and b. other allotments already exist and have the necessary spare capacity, and the District Council is satisfied that a recreation or community use is not appropriate. Neither of the above apply in this case.

The 776i site is the east facing field adjacent to the Glebe allotment. This site has no access unless it is through site 776l. To increase the traffic in Yew Tree Rise by cars accessing 100 houses, in addition to a new allotment site, would untenable. To the east of the site is Spring Lane, a single track road that it is not possible to widen so this is not suitable for highway access. At the south west of the site access is not feasible as it would encroach on an area designated as 'protected from development'. Consequently the only access is through 776l. Development of this site would significantly increase run-off and there are already issues of flooding of the Deben on the land below this site. One landowner is already having significant issues as when the River Deben floods, raw sewage overflows onto his caravan site causing a significant health and safety risk. Finally it would be a very visually obtrusive for those travelling south on the A12.

Consequently it is the view of Wickham Market residents that, under no circumstances, should the sites 776l and 776i be considered for housing development.

A more minor issue is that the land behind Hasnips, 200 High St, is now included in the built area boundary and this land is currently unacceptable for development due to access

restrictions. Development will create further problems for our High Street and is unlikely to 'preserve or enhance the character of the village conservation area'.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 5491 - 3106 - Wickham Market - None 5491 Support Woodbridge Housing Market Area Wickham Market

It was also disappointing to note that the land that we suggested for employment or industrial development to the north of the Riverside Industrial Estate was not included in the plan.

Finally, should Wickham Market be required to take additional housing development then the view of the Parish Council, having taken account of the views of residents, is that this should be site 421. This site has the potential for good access. The site could be designed to ensure minimum visual and environmental impact on the neighbouring River Deben SLA. There is also the potential for additional accessible green space to be incorporated to serve the needs of the community and finally it is contiguous to the village. In addition it would enable us to reduce the speed limit on Border Cot Lane to 30mph which we feel would be a very positive way of increasing safety for village residents. Summary: Should Wickham Market be required to take additional housing then the view of the Parish Council, having taken account of the views of residents, is that this should be site 421. This site has the potential for good access. The site could be designed to ensure minimum visual and environmental impact on the neighbouring River Deben SLA. There is the potential for additional accessible green space to be incorporated to serve the needs of the community and it is contiguous to the village. It would enable us to reduce the speed limit on Border Cot Lane to 30mph.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5683 - 3228 - Wickham Market - None 5683 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mike & Leila Gardner [3228] Agent: N/A

Full Text: My wife and I were among a large number of Wickham Market residents who attended a meeting last Thursday, 12 February, to hear an excellent presentation by Cllr. Dick Jenkinson about intentions by SCDC to review yet again, possible sites for additional housing in the village. The prime area of concern for almost all of those attending the meeting was the reinclusion of the Glebe Allotments and adjacent field as possible sites!

When we moved to the village just over five years ago, we were assured that development of this area was unlikely based on the results of a Public Inquiry in July 1989 when an application by 'Bovis Homes', was rejected.

Unfortunately, time passes and we are now facing a similar situation all over again when this time, SCDC appears to consider the sight 'suitable' for development. In the SCDC report it highlights that 'Wickham Market is deficient on Green Infrastructure' yet considers one area which contributes to open space, namely the allotments, as suitable for building.

There are two main aspects as to why the people of Wickham Market consider possible allocation of the Glebe site for development, as totally unsuitable.

1. The allotments are of great importance to a great many people and give huge benefit to the community. Being located close to the middle of the village, they are ideally located especially for senior citizens, handicapped people and those who do not drive. The area also provides a social aspect which is important bearing in mind the limited 'green spaces' available in the village. The field beyond the allotments is totally unsuitable for building due to the virtually impossible access but is used by numerous dog-walkers etc. and at least does provide some open space to the community.

2. Access to the Glebe Allotment area, should development go ahead, will be a nightmare for residents of Snowdon Hill, Yew Tree Rise, Fir Close and Meadowside. Car parking in Yew Tree Rise by residents living on Snowdon Hill, restricts this road to a single lane at most times of the day so considering using it to gain access to the Glebe area is totally impractical. We also have to consider access for emergency vehicles!

At the meeting of 12 February, alternative development sites were discussed and virtually all those attending favoured the sites identified in the Wickham Market plans as Numbers 421, off Border Cot Lane and 606 or 830a, as access to all would be far superior to consideration of the Glebe Allotments. Site 830a, would benefit from good access off the High Street opposite the new Hopkins Homes development and this should be seriously considered should the need for additional building be required.

I am sure I speak for many people in totally objecting to any consideration by SCDC to development on the Glebe Allotments and the adjacent field and trust the points outlined in this letter are worthy of consideration. Summary: 776L/776I:SCDC appears to consider the sight 'suitable' for development. In the SCDC report it highlights that 'Wickham Market is deficient on Green Infrastructure' yet considers one area which contributes to open space, namely the allotments, as suitable for building. At the meeting of 12 February, alternative development sites were discussed and virtually all those attending favoured the sites identified in the Wickham Market plans as Numbers 421, off Border Cot Lane and 606 or 830a, as access to all would be far superior to consideration of the Glebe Allotments. Site 830a, would benefit from good access off the High Street.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5691 - 3233 - Wickham Market - None 5691 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mr A Boffey [3233] Agent: N/A

Full Text: I am aware of your development plan which includes Wickham Market and I would like to strongly register my objection to two of the proposed sites - namely the allotments behind the George pub and the field next to the allotments for the following reasons:-

1. Access to these sites is proposed to be via Yew Tree Rise which is already a congested and dangerous access to the existing neighbourhood. Adding approximately another 100 houses will quadruple the houses using Yew Tree Rise for access and will make it a serious concern. 2. There are very few "Green" areas left within the village and these developments would remove 2 of the remaining areas. 3. There are several areas on the outskirts of the village with potentially good road access and I would consider them to be much more appropriate for any development that may be required. Summary: Access to these sites is proposed to be via Yew Tree Rise which is already a congested and dangerous access to the existing neighbourhood. Adding approximately another 100 houses will quadruple the houses using Yew Tree Rise for access and will make it a serious concern. There are very few "Green" areas left within the village and these developments would remove 2 of the remaining areas. There are several areas on the outskirts of the village with potentially good road access and I would consider them to be much more appropriate for any development that may be required.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5734 - 3243 - Wickham Market - None 5734 Object Woodbridge Housing Market Area Wickham Market

Respondent: Richard & Alison Fordham [3243] Agent: N/A

Full Text: Proposed development of allotments site 776i & 776l - Wickham Market

We wish to object to the proposed change of classification of the above sites from unsuitable to suitable for development.

Allotments provide people from all walks of life with exercise, vegetables, friendship and good health. We need more allotments not less. It's easy for Councils to push these proposals through but once built on, this public land has gone forever. People from all ages and social background take advantage of the allotments to grow their own food. Out allotments are a vital part of our community and we need to save them for future generations.

It takes years of hard work to get an allotment producing and to lose this important facility must be heart breaking. If the allotment land is re-designed as suitable for housing development it would amount to a massive failure of imagination that this most precious feature is lost to the community.

In 2012 The Government acknowledged the importance of allotments and to encourage and support local authorities to make more allotment land available. Growing your own produce as part of the long-term promotion of environmental sustainability health and well-being, community cohesion and social inclusion.

Access to the site would be a major issue; Spring Lane is narrow and single track and not suitable for large volumes of traffic. Access, as proposed, through Yew Tree Rise would cause issues with large numbers of vehicles emerging onto Snowdon Hill, into an already congested thoroughfare, makes no sense.

Planning for housing development requires greater imaginative thinking. Councils should be encouraging small developments, infills that do not put pressure on local services. Sufficient numbers of small development would provide the numbers of houses the council is looking to complete. Partnering with large house developers is a quick fix without considering the impact on green space, local community and people.

Wickham Market has experienced a great deal of housing development and future development is restricted by the need to build within the village boundaries. Development on the outskirts of the village make perfect sense. For instance extending the Wickham Place development into land adjoining at Pettistree should form part of the discussion. Summary: We wish to object to the proposed change of classification of the above sites from unsuitable to suitable for development. Allotments provide people from all walks of life with exercise, vegetables, friendship and good health. We need more allotments not less. It's easy for Councils to push these proposals through but once built on, this public land has gone forever. People from all ages and social background take advantage of the allotments to grow their own food. Out allotments are a vital part of our community and we need to save them for future generations.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5798 - 3263 - Wickham Market - None 5798 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mr Brian Clarke [3263] Agent: N/A

Full Text: In general terms any development in the Wickham Market area can only really be on a very small scale. All the proposed sites in the area are served by what are virtually single track roads as is now the case with High Street for the whole of its length due to the increased parking brought about by recent developments. The proposed sited in Dallingho Road and outlying areas in that direction would need to progress on single roads to the centre of the village causing absolute mayhem. Spring Lane is single track and anything to the south susceptible to flooding. With specific reference 776l then the proposed access is through Yew Tree Rise onto High Street and then either through village centre or south towards Hacheston, both directions are virtually single file traffic. The proposed site 77i has access through Spring Lane, again single track and not fit for large traffic flows. Any major development would have a further detrimental effect on the village and it is clear that the present facilties i.e doctors, school, sewers and public transport are nowhere near able to cope. Surely the Hopkins development at Featherbroom is more than sufficient and it would have been more sensible if this had been 'affordable' housing. Summary: In general terms any development in the Wickham Market area can only really be on a very small scale. All the proposed sites in the area are served by what are virtually single track roads as is now the case with High Street for the whole of its length due to the increased parking brought about by recent developments. Any major development would have a further detrimental effect on the village and it is clear that the present facilties i.e doctors, school, sewers and public transport are nowhere near able to cope.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5805 - 3106 - Wickham Market - None 5805 Comment Woodbridge Housing Market Area Wickham Market

Respondent: Wickham Market Parish Council (Mr Richard Agent: N/A Jenkinson) [3106]

Full Text: References:

A. Site Allocations and Area Specific Policies Local Plan Document, Issues and Options Consultation document 15 Dec 14 - 27 Feb 15 B. Wickham market Parish Council response dated 12 Jan 15

Dear Sir

SITE ALLOCATIONS AND AREA SPECIFIC POLICIES LOCAL PLAN DOCUMENT

A Public Meeting was held on 12 Feb 2015 to brief the residents of Wickham Market on the Suffolk Coastal District Council (SCDC) Local Plan and it was attended by 107 people. The brief was given by the Chairman of the Parish Council, Cllr R Jenkinson, and he gave an overview of the Local Plan documents. In particular he covered how Wickham Market may be affected in future.

It was explained that, despite the fact that Wickham Market had not been allocated any houses to be built by 2027, it was likely that the village would have to accept some development before that date.

The draft Local Plan shows that there are three sites in Wickham Market that are suitable for development, these are sites 776l, 776i and 617. Site 617 at 43 Road is currently being developed. Site 776l is the Glebe Allotments and Site 776i is the field to the east of the Glebe Allotments and to the west of Spring Lane.

The contents of the letter sent by Wickham Market Parish Council to SCDC on 12 Jan 15, Reference B, regarding the "Site Allocations and Area Specific Policies Local Plan Document" were briefed and there was unanimous agreement with the sentiment of the letter. However, it was felt that an additional letter should be sent to SCDC to clarify certain points and reinforce the initial comments.

There was unanimous agreement that site 776l should not be developed and should be classed as "Unsuitable for Development" in the SHLAA. The reasons given in Reference B are extant. In addition it should be noted that the Local Plan highlighted that Wickham Market was deficient in green infrastructure and building on the allotments would only make the situation much worse. There was such strong feeling that the Glebe Allotments should not be built on that it was felt that this site should become part of the "Area to be Protected from Development" within the village. This would make site 776i untenable as the only suitable access is through site 776l.

Three alternative sites for development were discussed. Of the sites discussed 66% of those attending felt that, if Wickham Market had to accept further development in the near future, then it should be on the 1.38Ha site 421 as this was the only site with suitable access. It was noted that this was in a Special Landscape Area (SLA), however 776l and 776i are also in SLAs.

The other two sites had some potential, but there were many factors to be considered and it was felt that these factors should be researched further in order to come up with the best solution. This further research would be best completed during the writing of a Wickham Market Neighbourhood Plan.

The area to the north of the Riverside Industrial estate was considered to be the best place to allocate any land required for employment/light industrial use within the Wickham Market CP. However, there was general agreement that the vacant business premises in Pettistree and Lower Hacheston should be used in advance of any site in Wickham Market. There was thought to be merit in widening the area considered for the Wickham Market Neighbourhood Plan to include Lower Hacheston and Pettistree. No agreement has been sought, as yet, from these neighbouring parishes.

In summary Wickham Market Parish Council, with the full support of many residents, request that SCDC:

a. Change the designation of sites 776l and 776i to "Unsuitable for Development" b. Additionally protect the site 776l by making it part of the "Area to be Protected from Development" c. Request that Wickham Market be allowed the time to develop a Neighbourhood Plan which should earmark some sites for development having resolved those issues that currently make these sites unacceptable. d. Accept the fact that if a site has to be found before the Neighbourhood Plan work is complete then it should be site 421.

We understand that, even though the Martlesham Heath development appears to have been given the green light to proceed, the requirement for houses is likely to rise from 7,900 to11,000. Consequently Wickham Market may need to accept some housing development before 2027. It would be vastly preferable if this development was done in the preferred location of the Wickham Market residents.

We look forward to your response.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5805 - 3106 - Wickham Market - None 5805 Comment Woodbridge Housing Market Area Wickham Market

Summary: In summary Wickham Market Parish Council, with the full support of many residents, request that SCDC:

a.Change the designation of sites 776l and 776i to "Unsuitable for Development" b.Additionally protect the site 776l by making it part of the "Area to be Protected from Development" c.Request that Wickham Market be allowed the time to develop a Neighbourhood Plan which should earmark some sites for development having resolved those issues that currently make these sites unacceptable. d.Accept the fact that if a site has to be found before the Neighbourhood Plan work is complete then it should be site 421.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5806 - 3265 - Wickham Market - None 5806 Object Woodbridge Housing Market Area Wickham Market

Respondent: Rev Ken Scott [3265] Agent: N/A

Full Text: RE: Site allocations and area specific policies development plan

I am writing with reference to the above plan, in particular the proposal for the areas 776i and 776L as shown on the map "Map 3 - Wickham Market SHLAA Sites"

The proposal to allow housing development on these two areas is not acceptable.

The loss of the allotments would be keenly felt by those who use them. They are a major asset to the village and are highly valued.

The traffic from the 100 or so houses would all have to exit the new estate either through Yew Tree Rise, or through an exit from the estate on to Spring Lane.

There is already congestion in Yew Tree Rise through parked cars narrowing the road to single lane only as you enter from the High Street, and if they were banned there would be serious parking problems for residents of garage-less houses in the High Street, as there is no other suitable parking close by. Additionally the exit onto the High Street from Yew Tree Rise is quite dangerous as visibility is not great and there are frequent occurrences of cars speeding at that point. Only this morning as I was walking back home from The Hill a car passed doing at least 40mph. (I am not aware of the Police ever checking speeds at this point, but it would be good if they did.) Traffic from another 100+ houses would increase the danger many times over.

And Spring Lane is narrow and the exit from that also has visibility problems as a result of the road layout and parked cars.

If area 356 is deemed 'not suitable' because of poor access, how much more should the proposed development in these two other areas also be deemed not suitable.

I would urge that these proposals are rejected. Summary: I am writing with reference to the proposal for the areas 776i and 776L. The loss of the allotments would be keenly felt by those who use them. They are a major asset to the village and are highly valued. The traffic from the 100 or so houses would all have to exit the new estate either through Yew Tree Rise, or through an exit from the estate on to Spring Lane. If area 356 is deemed 'not suitable' because of poor access, how much more should the proposed development in these two other areas also be deemed not suitable.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5842 - 3281 - Wickham Market - None 5842 Object Woodbridge Housing Market Area Wickham Market

Respondent: Wickham Market Allotment Association (Mr Ray Agent: N/A Lewis) [3281]

Full Text: As Chairman of the Wickham Market Allotment Association (WMAA) and representing the views of all allotment holders on the Glebe allotment site (shown as 776L on the referenced Local Planning Documents), I am writing to provide comments in support of our opposition to the Glebe Allotments being designated as suitable' for housing development and request that the designation be changed to 'unsuitable' for the reasons given below.

The Glebe land of approximately 13 acres was given to Wickham Market Church by two local gentlemen in the 18 century and approximately 4.2 acres have been allocated, and in continuous use as allotments, for well over 100 years. Prior to 1976 the Glebe was administered by the Vicar. After that date responsibility for administration and control passed to the Diocese. The Diocese then altered the arrangement for allotment tenancies and that part of the Glebe used for allotments was let to Wickham Market Parish Council who in conjunction with the Wickham Market Allotment Association (WMAA) has responsibility for administration, lettings, collecting rents, etc.

There are currently 53 allotments on the Glebe and at the time of writing all are in full and active use, with an increasing waiting list anticipated as usual with the onset of spring/summer, also due in part to the recent increase in the number of dwellings in Wickham Market. The rise in population is likely to sustain or further increase the demand for allotments.

The allotments are used by residents of Wickham Market as well as other villages and towns nearby. A large number of allotments have sheds, green houses, bee hives, and chicken runs, which is clear evidence of how vibrant and heavily used the allotments have become. Since its creation, more than a century ago, the allotment land has been carefully nurtured, enriched and cultivated by generations of local people in order to achieve allotment land of the highest growing quality. The central location of the allotments provides easy access for village residents by bicycle or by walking.

The Suffolk Coastal District Plan (Core Strategy & Development Management Policies. DM33 - Allotments, July 2013) states that the 'The Council will resist the loss of existing allotments to other uses unless suitable alternative allotments of equivalent size and quality are provided in the locality'. The exception to this policy is that there is overwhelming evidence' to show that there is no future demand for the allotments and that there is spare capacity on other allotments sites.

Relocating the allotments to another site would not be practical or achievable for the reasons given in the following paragraphs. The Glebe allotment site is already fully utilised and will be for the foreseeable future, and the other allotment site, Simon's Cross, is also full so neither of the stated exceptions to the policy apply.

To relocate the allotments to another site would be disastrous and mean that the allotment holders would have to start all over again. This would be a huge undertaking and it would take many years and an enormous amount of hard work before the land would become productive and achieve comparable growing quality to the existing site.

It has been indicated that the allotments could be moved to a site on 776i but this land would be quite unsuitable for several reasons. It has been previously used for farming and will be contaminated with herbicides, pesticides, etc which would not suit organic cultivation as practised by the majority of existing allotment holders today. Importantly, the land slopes away to the east, towards the Deben Valley and east facing allotments are notoriously far less productive since they will have less sunshine and be exposed to colder winds. The slope would also cause increase water run off and nutrient loss. It would also be too far away from the village centre and all the benefits of convenient and easy access for residents will be lost. Note that many residents in the village centre and along the High Street either have a small or no gardens at all and the allotments provide them the vital, extra garden space that allows them to grow sustainable foodstuffs for themselves and their families that they would otherwise not have.

There are a high proportion of existing allotment holders who are retired and enjoy their days growing and working on their allotment, and very importantly keeping themselves fit and healthy in the process. To undertake the task of moving to another allotment site and starting all over again would, for many of them, be a challenge too far.

The Glebe and the allotments are very much part of the medieval character of Wickham Market which was once, and still is to an extent, surrounded by farm land and countryside. Indeed many of the houses in the historic village centre were farm houses with fields to the rear. As the village has expanded over the years, some of the land has been built on and the last remaining area of countryside to link to the core of the village is the Glebe area. It would be an absolute tragedy to lose this green lung which is the last vestige of medieval Wickham Market and be hugely damaging to the historic character of village.

Running alongside the northern boundary of the Glebe are ancient footpaths which link the centre of the village to communities in Spring Lane and King Edwards Avenue. These footpaths are in regular use by families to enable them to safely take their children to school and visit the shops, library, and medical centre in the village. Should development of the Glebe go ahead then the footpath would be severed by a-new access road and would therefore render it much less safe for families and children. There is also fencing at the rear of the houses on Meadowside onto the footpath and if a new housing development were allowed on the Glebe then fencing along the rear of those houses would create a most unsightly and potentially unsafe urban corridor. The same is

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5842 - 3281 - Wickham Market - None 5842 Object Woodbridge Housing Market Area Wickham Market

true for the footpath running along western perimeter of the Glebe.

Furthermore, the Suffolk Coastal District Plan (Core Strategy & Development Management Policies. SP17 - Green Space, July 2013), specifically states that The Council will seek to ensure that communities have well-managed access to green space within settlements and in countryside and coastal areas, in order to benefit health, community cohesion, and greater understanding of the environment, without detriment to wildlife and landscape character'. Designating the Glebe (776L) as suitable for development, and the consequential damage this would have on Wickham Market, its character, its rural setting, and its people, is therefore completely at odds with this policy.

For the reasons given, we strongly request that the Glebe allotment (776L) be designated as 'unsuitable' for development in Wickham Market. We share the view with Wickham Market Parish Council, the custodians, of this ancient village, that there are other sites and locations in the area which are far better suited for development which do not appear on your plans. Summary: There are currently 53 allotments on the Glebe and all are in full and active use, with an increasing waiting list anticipated as usual with the onset of spring/summer, also due in part to the recent increase in the number of dwellings in Wickham Market. The rise in population is likely to sustain or increase the demand. Relocating the allotments to another site would not be practical or achievable. The Glebe allotments are already fully utilised and will be for the foreseeable future; the other allotment site is also full so neither of the stated exceptions to the policy apply.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5865 - 3301 - Wickham Market - None 5865 Object Woodbridge Housing Market Area Wickham Market

Respondent: Anne Westover [3301] Agent: N/A

Full Text: SITE ALLOCATIONS AND AREA SPECIFIC POLICIES CONSULTATION

In response to the SCDC consultation on the site allocations and area specific policies I am writing to comment on a number of points (page 3-4) and object to the housing allocation proposed for Wickham Market. I have referred to the SCDC 2013 Development Plan.

I consider that the two sites labled as 776i and 776l and indicated as having a joint capacity for 102 houses are unsuitable for development for a number of reasons.

I note that the village should not need to accommodate new housing prior to 2027 but understand that should planning applications be submitted the council are likely to view these positively.

Although SCDC state that the SHLAA document (March 2014) should be given 'limited weight in the assessment of planning applications' (page 1) the inclusion of these sites will give great encouragement to the landowner and developers who appear to be working together in the preparation of planning layouts.

I note that the SHLAA does state that relevant stakeholders have been involved in the assessment of sites but it would appear that in our case the views expressed by the Parish Council at meetings with yourselves in 2014 have been overlooked. I am pleased to note that landscape and conservation teams have been consulted, and would be pleased to see the assessment notes if these are available for public viewing.

Comments relating to current Wickham Market Glebe allotment Site 776l

This site forms the larger of the village's two allotment sites and I am led to believe by a neighbour that the land has been in this use for well over 100 years.

The allotments are located at the heart of the village and provide a green space for those walking past, looking towards them, and working on them. The allotmenteers benefit from the healthy work, social aspect and the food produced all year round. The allotmenteers comprise a wide mix of young and old people including many retired and elderly.

The soil has been improved throughout the long period of use and crop production is excellent. There are many established productive ponds, bushes, fruit trees and shrubs and a resulting wealth of wildlife. The site provides a wildlife corridor with birds, amphibians, grass snakes and hedgehog all present. Local Plan policy SP14 relating to Biodiversity applies in this respect with the allotments providing a valuable habitat.

The allotments benefit from a reasonable amount of shelter although there are times when cold winds affect the plots. The site is easy to access by foot, cycle and by car. Parking is available for those living further afield or needing to carry in tools and materials. It is also used for vehicles delivering manure and bigger items. The site appears to be relatively safe, secure due it being partially overlooked.

Comments relating to both Wickham Market Sites 776i and 776l

The site 776l lies adjacent to the designated Conservation Area and helps form the open green setting to this area. Many historic properties including the church benefit from the setting afforded to them by the sense of openness on their eastern boundary. Views of the church spire are obtained across the allotments and field to the east (776i) ensuring its visual connection with the wider countryside. The land is visible from the A12 and from areas within the River Deben valley Special Landscape Area (SLA) to the east. New housing will be visible and will restrict views from the SLA towards the historic core of the village.

The previous planning refusal, appeal and Inspectors decision dated 8th September 1989 Ref T/APP/J3530/A/112357/P5 provides useful guidance on the poor suitability of site 776l for housing. I have attached this decision for your reference. The inspector highlighted many aspects which are still of concern to current residents and allotment holders. Since this time local community participation, health benefits arising from outdoor activities, green infrastructure and local food production have been promoted by the government, District and our County Council. Our village allotments fit into these objectives perfectly and should be considered as an exemplar site worthy of the highest level of protection.

The SCDC Development plan policy DM33 appears to give strong protection to allotment land. Providing an alternative site (within 776i?) is not a practical option. Much of this field is sloping, the soil is of poorer quality and the site faces to the east from where the strong, cold winds will have an impact on the success of crops. Access for allotment holders from the village will be difficult. Loss of food production over a period of many years whilst a new site becomes established will be significant.

The Local plan policy SP17 Green space states that the council will seek to ensure that communities have access to green space within settlements. Allotments are referred to in the supporting text paragraphs 3.171- 3.173, with their role in the network of green space and healthy benefits clearly recognised. In addition to this the plan (paragraph 6.16) states that there is a green infrastructure deficiency within the area including Wickham Market. I am not sure whether

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5865 - 3301 - Wickham Market - None 5865 Object Woodbridge Housing Market Area Wickham Market

the Green infrastructure strategy for SCDC are has been finalised but this deficit should presumably be addressed in specific proposals and allocations.

The draft sustainability appraisals, December 2014 for the two sites contain Objective scorings which could be interpreted differently. The most obvious being SA Objective 1: 'To improve the health of the population overall' has been given an Impact Score of Minor Positive for site 776l if developed. This seems to be at odds with the detrimental impact which will result from the loss of allotments.

Access to both sites 776i and 776l is problematical as it would mean traffic coming up Yew Tree Rise, used by residents on the High Street for much need parking. Significant numbers of extra vehicles coming on/off the High Street will not be welcome. There are increasing traffic and parking problems on the High Street following various new, some back land developments at several locations to the north. Access for vehicles from Spring Lane is likely to be problematical and not desirable.

The two sites taken together will produce a development area completely out of scale with this part of the village and will have a significant impact on its special character.

I urge the Council to re-designate the sites 776l and 776i as 'unsuitable/NOT suitable for development'. Their role in helping to support our community and provide valuable existing green space is well established.

This year is International Year of Soils so it would seem fitting to ensure that our local allotments are protected for the community and future generations of residents.

Other matters in response to the consultation document

I would welcome a more detailed assessment of other smaller sites within the village for new housing and this could be done in conjunction with the Parish Council. New housing sites must be in scale with the village and its unique character. Sites should include homes that are both suitable in size and affordable (both in respect of RSL/rent and low price/ownership) to local people and families, new properties should not be dominated by larger and more expensive homes.

With respect to your questions 30 and 31 regarding community and well-being I have addressed my main concern regarding allotment provision. I welcome your strategic objectives 13, 14 and 15. However there needs to be support from officers to help our community achieve these objectives and to ensure that green space and links are both included and improved when new development takes place.

To cater for a growing and aging population the need for a sheltered and care/nursing home facility will become ever more important. I would like to see the current sites of Kitson Court and Lehmann House protected for these purposes in perpetuity. These homes are perfectly located close to the heart of the village and provide much needed support for residents and their families, many of whom are resident in the village.

Additional employment site/s (your questions 16 and 17) may need to be provided either within or in close proximity to the village. An employment site at Parma Industries/Anglia Grain on the High Street was unfortunately lost to housing recently. Other suitable sites (including those existing) must be protected for such use in the future, specifically Riverside at Bordercote Lane, Old School Farm and Bridge Farm complex.

The development plan policy SP15 Landscape and Townscape refers to the protection of 'sites, gaps, gardens and spaces that make an important contribution to a particular location in their undeveloped form...'. The map showing the suggested physical limits for the village indicates just one such area. This encapsulates the old vicarage and the Pightle field and was designated in the 1990's local plan.

There are several other areas, including the Glebe allotments which are worthy of this designation. I am not sure if your officers have reviewed the suitable sites but I am happy to provide further suggestions in due course. The PC may also be considering this matter further. In particular there are several High Street locations where this designation should apply and these may be highlighted as part of your Conservation Area Appraisal review.

With respect to the Historic Environment I note that you ask, question 26 for contributions towards a list of non- designated heritage assets. This may be something which our village may wish to contribute toward but may also need more time to consider. I would like to suggest our village cemetery on the High Street and the Bier House are added to such a list. Our cemetery group will be happy to show officers around if needed.

With respect to Historic Parks and Gardens I note the reference to AP4. I welcome the proposal to identify all designated and non-designated historic parks and gardens. I was involved with the research and preparation of this policy and SPG 6 with Steve Ratcliffe in the 1990's when employed by SCDC as Landscape Officer. I would like to correct the point that most of the sites included and shown on the proposals map do not have a national designation as you state. Several parks (e.g. , Campsea Ashe, Little Glemham, Woodbridge cemetery) are listed on the English Heritage register but the remaining (e.g. Rookery, Grove Park and Cockfield) have a local designation only. The Suffolk Gardens Trust may also be able to assist further with identifying parks and gardens.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5865 - 3301 - Wickham Market - None 5865 Object Woodbridge Housing Market Area Wickham Market

Please let me know if you have any queries regarding this letter, I await your response and anticipate receipt of this letter. Summary: Access to both sites 776i and 776l is problematical as it would mean traffic coming up Yew Tree Rise, used by residents for much need parking. There are increasing traffic and parking problems on the High Street following various new, some back land developments at several locations to the north. Access for vehicles from Spring Lane is likely to be problematical and not desirable. I urge the Council to re-designate the sites 776l and 776i as 'unsuitable/NOT suitable for development'. Their role in helping to support our community and provide valuable existing green space is well established.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: Bovis 1989 Inspectors appeal decision.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5960 - 3318 - Wickham Market - None 5960 Object Woodbridge Housing Market Area Wickham Market

Respondent: Andrew & Pam Lord [3318] Agent: N/A

Full Text: We have been made aware of plans to convert an allotment area and field in Wickham Market into houses (possibly 100 houses). We live in Yew Tree Rise and are especially concerned about potential access past our property. The entire area is very congested, with cars from the High Street houses parking up Yew Tree Rise. The bend around there is blind and with rows of cars parked, often means you have to reverse all the way back to let cars through. another 100 houses would make this impossible.

Please reconsider the plan for Wickham - the new development in Wickham Place should count for our contribution. Summary: We have been made aware of plans to convert an allotment area and field into houses. We live in Yew Tree Rise and are especially concerned about potential access past our property. The entire area is very congested, with cars from the High Street houses parking up Yew Tree Rise. The bend around there is blind and with rows of cars parked, often means you have to reverse all the way back to let cars through. another 100 houses would make this impossible.

Please reconsider the plan for Wickham-the new development in Wickham Place should count for our contribution.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6078 - 3348 - Wickham Market - None 6078 Object Woodbridge Housing Market Area Wickham Market

Respondent: John & Mary Sculpher [3348] Agent: N/A

Full Text: Site Allocations and Area Specific Policies Development Plan Document

As part of the consultation on the Site Allocations and Area Specific Policies Development Plan Document I am writing to protest about the designation of Sites 776i and 776L as suitable for development.

I consider that this designation is wrong on three grounds: the loss of green space at the centre of the village, the loss of allotment land, and the problems of access.

The Loss of Green Space I accept that Wickham Market may tick the boxes to be regarded a 'Service Centre', but the reality is that there is precious little green space within the parish boundaries. Since 2010 significant housing development has been completed, or is still on-going Site 776L (the George Allotments) provides valuable open space at the heart of the village. As well as those who work the allotments a far larger number use the various footpaths bordering sites 776L and 776i to get to the shops, walk the dog, or to simply take exercise. Those same footpaths along the edges of a housing estate would not provide the same sense of openness and calm.

The Loss of Allotment Land It is sometimes suggested that allotments can simply be relocated by providing alternative land. This is not the case. The central position of the George Allotments has resulted in them being very well used for many years. The soil structure has been improved by constant working and is now very productive.

Even if alternative land were available, it would take years to bring 'virgin' land to a similar state of fertility. Since no land is available close to the centre any new plots would have to be more remote and therefore less accessible and less secure. None of this is desirable. The allotments have been on this site for over a hundred years and provide a space for relaxation, exercise and of course food production. They are a significant benefit to the health and wellbeing of the village and their loss would adversely affect the local quality of life. The demand for allotments in the village has been so great that some years ago additional land was cleared by Community Service personnel to meet the need. The new housing in the village has very small gardens and the recent addition of over a hundred new dwellings will only increase the demand for the plots

Problems of Access You will recall that when the application from Bovis Homes to build on the George Allotments was refused in the late 1980s, access was a major factor. The only possible access to site 776L is via the strip of land between 9 Yew Tree Rise and 1 Fir Close, which was left by Bovis for this purpose. If the junction of Yew Tree Rise and High Street was considered unsafe for additional traffic nearly thirty years ago, the situation is now significantly worse. There is constant parking on the bend of Yew Tree Rise making it effectively a single track road. Most of these cars belong to residents on the High Street, who cannot park closer to their homes. Whilst this parking does not generally cause major problems at present, it certainly would were the road to provide access to an additional 30 (site 776L) homes. If additional double yellow lines were introduces I fear the problem would only be pushed further along the road.

The junction is dangerous due to the speed of traffic going up, and down, the hill. The High Street is narrow at this point. It is a bus route and the main route into and through the village for large vehicles. Visibility at the junction is particularly poor to the right, down the hill. Vehicles accelerate up the hill and many vehicles exceed the speed limit as they pass the Yew Tree Rise junction. A short survey would demonstrate this fact. If the traffic density at the junction were to be increased the danger of serious accidents would become very high. On several occasions family members have turned left at the junction after checking the road was clear, only to see in the rear view mirror a vehicle almost on their tail as they pull away from the junction.

It seems equally unlikely that any suitable access could be made to site 776i, except through the same strip of land. Spring Lane is quite unsuitable and it is difficult to see how adequate modifications could be made to it. The development of site 776i and 779L together would therefore generate additional

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6078 - 3348 - Wickham Market - None 6078 Object Woodbridge Housing Market Area Wickham Market

the traffic of approximately 100 homes funnelling through a junction that is already under pressure.

In summary sites 776i and 776L are not suitable for development. The Parish Council has previously indicated sites that would be more suitable and I understand they will be re-emphasising this view at the next meet with you. The Parish Council's view has strong local support following the public meeting held in the Village Hall on 12th February 2015.

Green space in a community is part of the character of an area. It seems unreasonable that Wickham Market should be asked to identify even more housing land. Many of the roads around the village are narrow and have poor visibility making them unsuitable for increased traffic. Recently the main road through the village was closed for gas main work and the damage to verges and road surfaces on the minor roads reflects their inadequacy. We are rapidly becoming pot-hole central. One of the logical places to put additional housing would be next to the Wickham Place development to the south of the village, however it appears this cannot be considered as it is outside the Parish boundary. Because of an ancient line on the map and tick box policies it appears we risk becoming an over-developed urban island. It would make more sense to consider the wider local area as a whole. Summary: Green space in a community is part of the character of an area. It seems unreasonable that Wickham Market should be asked to identify even more housing land. Many of the roads around the village are narrow and have poor visibility making them unsuitable for increased traffic. Recently the main road through the village was closed for gas main work and the damage to verges and road surfaces on the minor roads reflects their inadequacy.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6188 - 483 - Wickham Market - None 6188 Comment Woodbridge Housing Market Area Wickham Market

Respondent: Anglian Water (Sue Bull) [483] Agent: N/A

Full Text: Thank you for the opportunity to comment on the Issues & Options Consultation document (December 2014).

Neighbourhood Plans Whilst Anglian Water (AW) has no comment to make on the neighbourhood area designation stage of a Neighbourhood Plan we are pleased to be consulted on the plans once they progress to draft plan stage. We are currently considering the Leiston Neighbourhood Plan and will make comment within the consultation period.

Felixstowe Area Action Plan Anglian Water are submitting representation on this consultation.

Site Allocations

Please find attached RAG spreadsheet summarising Anglian Water's comment on each site. It is important to note that this assessment does not take account of the cumulative impact of all the sites on the capacity of the Water Recycling Centres; the sites are assessed individually.

Asset Encroachment

Please note Sites 12ucl,13ucl,350,350b,408a,583a,672a,776i and 776L and WE04 are within the 400m consultation zone of the Water Recycling Centre (WRC) (formally referred to as Sewage or Wastewater Treatment Works). Initial assessment has indicated that there is an odour risk. Further discussion with Anglian Water is needed. Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage.

If a landowner or potential developer wishes to pursue an enquiry for development it is recommended they contact AW at the earliest opportunity to discuss the level of risk and the requirement for an odour risk assessment to be carried out.

Anglian Water does not want to thwart development or apply a blanket embargo on all development within 400 metres of our WRC, however we must balance this with protecting our new and existing customers from the risk of nuisance/loss of amenity whilst allowing us to provide the essential sewage treatment service to our customers and for this reason we take a risk based approach.

Similarly, development should be located a minimum of 15 metres from Pumping Stations to avoid the risk of nuisance/loss of amenity . With development proposals close to a foul pumping station,(site 693), it may be the layout of the site can be adjusted so as not to encroach on the 15 metre protection zone. The landowner/developer is advised to contact AW at the earliest opportunity to discuss.

Where there are sewers crossing the site, the site layout should be designed to take these into account; this existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The sewers should be located in highways or public open space. If it is not possible to accommodate the existing sewers within the design then diversion may be possible under section 185 of the Water Industry Act 1991 or entering into a build over/near agreement may be considered.

Details of Anglian Water encroachment policy can be viewed at: http://www.anglianwater.co.uk/developers/encroachment.aspx

Sewerage Network

The foul (or used water) flows from future growth will have an impact on the existing foul sewerage network. As outlined within the attached RAG sheet, upgrades to the network is likely to be required for a number of developments . The foul infrastructure requirements will be dependant on the location, size and phasing of the development.

We would want to see policy to ensure necessary infrastructure to serve allocations is planned and implemented before development proceeds (and dwellings occupied). To ensure this is carried through to a tactical level, we would at planning consent stage request the use of appropriate conditions to ensure infrastructure is in place before development is connected to the public sewerage network.

Surface Water and Flood Risk

Appropriate management of flood risk and the consideration of climate change is critical for long term resilience.

Whilst fluvial flooding is a significant constraint to the location of development, other forms of flooding such as surface water should be a consideration.

All developments should seek to reduce flood risk and incorporate Sustainable Drainage Systems (SuDS). We would

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6188 - 483 - Wickham Market - None 6188 Comment Woodbridge Housing Market Area Wickham Market

wish to see in policy that all developments should adhere to the surface water management hierarchy outlined in Part H of Building Regulations with disposal to a surface water sewer seen as a last resort. Under no circumstances will surface water be permitted to discharge to the public foul sewerage network and no new flow will be permitted to discharge to the combined network. We would want the document to clearly state that a surface water drainage solution will need to be identified and implemented prior to the construction of hard standing areas. The solution would need to be agreed with all stakeholders.

Engagement with developers

Anglian Water offers a pre planning service which includes a capacity check to determine the impact of sewerage from a proposed development. We will also work with the developer or land owner during this process to develop foul and surface water (where applicable) drainage solutions which will not cause a detriment to our existing or future customer. We would encourage the prospective developer to contact us at the earliest convenience to discuss drainage proposals to serve the development. Details regarding this service can be found at http://www.anglianwater.co.uk/developers/pre- planning-service-.aspx

Anglian Water are keep to engage with Suffolk Coastal District Council on Local Plan consultations and on individual planning applications. Summary: 776i: Encroachment advisory zone for WRC - risk score 35, Sewers Crossing Site 776l: Encroachment advisory zone for WRC - risk score 15, Sewers Crossing Site

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: 5002_Suffolk_Coastal_allocation_-_sites_consultation_sheet_(RSP)_-_Jan-15(1).pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6332 - 3390 - Wickham Market - None 6332 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mr A Manley [3390] Agent: N/A

Full Text: Re: Local Plan Document - Issues and Options Consultation - Site Allocations for Wickham Market

Please find below details of my objections to two specific sites, 776L and 776i, which are designated as "being suitable for development for housing" for the Wickham Market area.

Area designated as 776L

The 776L site is the Glebe allotments; these have been well used for a considerable length of time and they are considered to be excellent allotments. They are centrally placed in the village allowing easy access, they have good soil and a number of long standing allotment holders. The Allotments Association and the majority of residents of Wickham Market have made it very clear that they do not wish to lose this area to development and it would be an enormous loss to the village in terms of community activity, health benefits and psychological wellbeing for village residents. Ifeel that this area should be designated as a permanent green space for the community to enjoy in perpetuity.

Access to this site is only possible through Yew Tree Rise on the northern boundary. This access would cross a well- used footpath and increase the traffic in Yew Tree Rise to an unacceptable level. Parking is already at a premium in this area as the nearby High Street is very narrow with parking restrictions and a number of houses have no parking facilities. Yew Tree Rise is the main parking area used by these High Street residents. This means that Yew Tree Rise is, effectively, a single track road and as such would not be acceptable as access, particularly for large construction vehicles. Should Yew Tree Rise be made a no parking zone then the parking loss would cause considerable difficulty to those that currently use it as there is no suitable nearby alternative.

As site 776L is used as allotments these would have to be re-provided elsewhere should this land be used for development. It has been suggested by you that they could be moved onto site776i, but this would have disastrous consequences for the allotment holders for the following reasons: 776i is an east facing sloping field, exposed, with poor drainage and is further away from the centre of the village making access more difficult. The current allotments provide a sustainable location, easily accessible for most users by foot or cycle. Document DM33 states that the Council will resist the loss of existing allotments to other uses unless suitable alternative allotments of equivalent size and qualitv are provided in the locality. The only exceptions to this policy will be where: a) there is overwhelming evidence to show that there is unlikely to be any future demand for the allotments; and b) other allotments already exist and have the necessary spare capacity, and the District Council is satisfied that a recreation or community use is not appropriate.

Neither of the above apply in this case.

With the lack of green space available close to the High Street this area provides a pleasant and rural feel to residents of the village within easy walking distance from the centre.

Comments on the impact designations shown on the Draft Sustainability Appraisal Summarv document for site 776L

SA Objective Ref Impact: Comments 2. To maintain and improve levels of education and skills in the population overall. Stated as 0

Should be * The impact would not be zero as allotments encourage people to learn about propagating their own food, providing education to local families with the children observing the managing of the soil and the growing of the plants. 8. To improve the quality of where people live and to encourage community participation. Stated as + Should be * The stated impact is definitely not a positive. To build on this allotment site would result in a considerable loss to the community and relocating it to site 776i is not viable. 10. To maintain and where possible improve air quality Stated as O Should be * You cannot maintain air quality by adding considerably more housing and additional traffic near the centre of the village. This would have a detrimental effect on air quality. 14. To reduce the effects of traffic on the environment Stated as + Should be ** Traffic would be increased significantly by the addition of housing on this site. It cannot be a +. 16. To reduce vulnerability to flooding Stated as O Should be * Although not a flood plain as such the run off will increase the chances of flooding in the surrounding Deben area. 19. To conserve and enhance the quality and local distinctiveness of landscapes and townscapes Stated as ?

Should be * The building of houses on this site will not enhance the quality and distinctiveness of the area.. It takes away a facility close to the village centre where a green environment currently exists for all to enjoy.

The conclusion from this must be that the area 776L is not suitable for housing development as was previously decided by the Planning Inspectorate in the 1990's when Bovis Homes tried to develop the site.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6332 - 3390 - Wickham Market - None 6332 Object Woodbridge Housing Market Area Wickham Market

Area Designated 776i

The 776i site is the east facing field adjacent to the Glebe allotment. This site has no access unless it is through site 776L. To increase the traffic in Yew Tree Rise by cars accessing 100 houses, in addition to a new allotment site, would be untenable. To the east of the site is Spring Lane, a single track road that it is not possible to widen so this is not suitable for access. At the south west of the site access is not feasible as it would encroach on an area designated as 'protected from development'. Consequently the only access is through 776L. Development of this site would significantly increase water run-off and there are already issues of flooding of the Deben on the land below this site. One landowner is already having significant issues as when the River Deben floods, raw sewage overflows onto his camp site causing a significant health and safety risk.

Comments on the impact designations shown on the Draft Sustainability Appraisal Summary document for site 776i

(See attached Document)

SA Obiective Ref

I therefore ask you to give good consideration to the negative impact that the development of these sites would have on the area - not least the removal of an important facility for local residents - and remove them from your development plan. Summary: As site 776L is used as allotments these would have to be re-provided elsewhere should this land be used for development. It has been suggested by you that they could be moved onto site776i, but this would have disastrous consequences for the allotment holders. The 776i site is the east facing field adjacent to the Glebe allotment. This site has no access unless it is through site 776L. To increase the traffic in Yew Tree Rise by cars accessing 100 houses, in addition to a new allotment site, would be untenable.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: AM.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6341 - 3391 - Wickham Market - None 6341 Object Woodbridge Housing Market Area Wickham Market

Respondent: Rachel Turner [3391] Agent: N/A

Full Text: Re: Site Allocations and Area Specific Policies Local Plan Document, Issues and Options Consultation document 15 Dec 14 - 27 Feb 15

Dear Sir

I recently attended the meeting on Thursday 1 h February at the Wickham Market village hall regarding sites in the village identified by SCDC as being potentially suitable for the construction of further housing. The meeting was well attended and various options discussed. However, of all the sites identified there was one that caused unanimous concern due to its inclusion - the site of the Glebe allotments. I do not believe there was a single person in the room who thought the site of the Glebe allotments is one suitable for development. I would like to add my voice to those who think that the site of the Glebe allotments should be removed from the list of potential sites for housing development.

Not only would the loss of the site mean the loss of a vital green space within the village it would also mean the loss of a whole section of the community. When I first moved to the village in 2012, it was while enquiring about taking on an allotment plot that I met the site manager who gave me the first proper welcome to the village I had received along with a bunch of flowers from his plot as a welcome gift. I took on a plot and in so doing met and made many friends here in the village of all ages and backgrounds. I know from other plot holders that I am not the only person who has got to know and found a place in the community through the Glebe allotments. I do not know the people who live in the house two doors down from me but I do know all the plot holders in the row of plots mine is in as well as many more around the site. It takes more than housing to build a community and the Glebe allotments prove this. Should the allotments be developed into housing, far more would be lost by the destruction of this asset to the community than gained.

As well as the social importance of the site, the Glebe allotments provide an invaluable informal educational resource in the community. I and many other gardeners on the site have gained invaluable knowledge and advice passed on from the older gardeners on the site who have worked the ground there for many years. This includes advice that cannot be gained from gardening books or television gardening programmes such as the most successful plants and varieties to be grown in local conditions as well as the sharing and growing of local and old varieties of plants. I have personally gained a wealth of knowledge and advice from the older gardeners on the plot and we have shared plants, resources and food. I would like to think that one day, I too would have the opportunity to pass this on to future gardeners on the site. I also fear that should the Glebe allotments be developed that many of the older gardeners would not be able to practically make the transition to the site that has been offered as an alternative and that this unique and special flow of knowledge and education would cease. Several of the older gardeners I have spoken to have said that they could not start again on a new site further out of the village.

I feel that the council should be supporting and protecting social, educational and green assets to the community such as Glebe allotments and as such that the site should not be one considered as suitable for development. Would you be able to provide any reassurance that the council would be able to fund the equivalent in terms of community educational garden projects to try to replace what would be lost if the site were developed and the older generation cut out as a result?

There are many other practical reasons too why the Glebe allotment site would not be suitable for development not least practicality of access and the unsuitability of the alternative site offered for allotments. I would like to note that several other more suitable site options were discussed at the meeting that would much better serve the community and the village. However, I wanted to raise some of the less tanglible but still highly important reasons for your consideration as to why the Glebe allotment site is unsuitable and should be taken off the list of potential sites for housing development.

Summary: There are many practical reasons why the Glebe allotment site would not be suitable for development not least practicality of access and the unsuitability of the alternative site offered for allotments. I would like to note that several other more suitable site options were discussed at the meeting that would much better serve the community and the village. However, I wanted to raise some of the less tanglible but still highly important reasons for your consideration as to why the Glebe allotment site is unsuitable and should be taken off the list of potential sites for housing development.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6342 - 3392 - Wickham Market - None 6342 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mr David Bescoby [3392] Agent: N/A

Full Text: Re: Site Allocations and Area Specific Policies Local Plan Document, Issues and Options Consultation document, site ref 7761 - Wickham Market I am writing to lodge my strongest objection to SCDC having again highlighted the Glebe allotments (776l) in Wickham Market as a potentially suitable site for housing development within the above planning document. In doing so, SCDC has shown a disappointing lack of understanding regarding the historical and social underpinnings of the village in general and the importance of these centrally located allotments to the fabric of village life.

The site assessment of anticipated effects for site 776l against draft sustainability appraisal objectives appears flawed in the following respects:

SA Objective 1: It is doubtful that the development of the site will have a minor positive benefit in improving the health of the population overall. Quite the opposite for the local population facing a loss of local organic food production not to mention the lost benefits of social interaction and physical exercise for the 53 or so allotment holders and their families.

SA Objective 3: Surely within a built environment, the potential for crime and anti• social behaviour will increase, so how can developing this site be of positive benefit in this respect?

SA Objective 4: The allotments have the potential for alleviating poverty through the cheap production of quality food and certainly benefit social cohesion. Developing this site would therefore have a detrimental impact.

SA Objective 7: According to the Site Allocations and Area Specific Policies planning document, Wickham Market has already met its allocated housing requirements.

SA Objective 8: It is ludicrous to suggest that developing this site would have a minor positive effect on improving the quality of where people live and encourage community participation. The loss of the allotments as a community asset and central green space would both reduce community participation and the quality of the local environment.

SA Objective 14: How would a housing development on this site be of minor benefit to reducing the effects of traffic on the environment? Surely development increases traffic while the loss of green space reduces the capacity of the environment to buffer the impact!

SA Objective 17: To conclude that loss of a central green space of nearly 2 ha has a neutral effect on biodiversity and geodiversity goes against all recognised ecological principles. There is an acknowledged shortage of green spaces in Wickham Market and the SCDC plan (core strategy & development management policies SP17 Green Spaces) seeks to assure communities have access to green space within settlements.

SA Objective 18: It is dismaying that the assessment concludes that developing this site has no negative impact on the conservation of an area of documented historical importance to the village. There have been allotments on the site for over 130 years.

SA Objective 19: The lack of certainty regarding this objective surely highlights why this site should never have been considered suitable for development. The loss of this historical amenity will have a significant negative effect on the quality and local distinctiveness of the landscape and 'villagescape'. The Glebe allotments are interwoven into the historical narrative of Wickham Market and today provide, perhaps more than ever, an essential asset for a wide spectrum of the community living in Wickham Market and further afield.

It is important that SCDC really grasps the long-term significance of proposed development in villages like Wickham Market, for such fundamental and far reaching changes will have serious ramifications for the future success of these settlements. Change in inevitable and the need for a regional housing planning policy is accepted, but ignoring key elements that define a place such as its heritage, historical topography, folk memory and its cultural setting within the wider landscape risks serious irreversible damage. In the case of Wickham market, a historically rural village having undergone significant transformation over the past 60 years and now lacking in central green spaces, there is a need for sensitivity and caution. The loss of the last central undeveloped area of the village, not least an area of significant cultural importance and a vibrant and much valued community asset, would frankly be a disaster. I hope that in the spirit of the issues and options consultation, SCDC will see fit to change the SHLAA status of this site to unsuitable for development. Summary: . In the case of Wickham market, a historically rural village having undergone significant transformation over the past 60 years and now lacking in central green spaces, there is a need for sensitivity and caution. The loss of the last central undeveloped area of the village, not least an area of significant cultural importance and a vibrant and much valued community asset, would frankly be a disaster. I hope that in the spirit of the issues and options consultation, SCDC will see fit to change the SHLAA status of this site to unsuitable for development.

Change to Plan

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6342 - 3392 - Wickham Market - None 6342 Object Woodbridge Housing Market Area Wickham Market

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6351 - 3400 - Wickham Market - None 6351 Object Woodbridge Housing Market Area Wickham Market

Respondent: Julie Cuninghame [3400] Agent: N/A

Full Text: Re: Suggested Developments in Wickham Market/ Site Allocation and Area Specif ic Policy Development Plan Document

I write to register my objection to the idea of the land long used as allotments at the Glebe site in Wickham Market being developed f or housing. This land was the subject of a previous proposal for development at which time many objections were raised and the idea was rejected on appeal by HMPI as being detrimental to the village amenities. If anything the position now is that the allotments are used even more fully by local residents than they were in times past. When my husband and moved to the village the availability of an allotment was of great importance to him. He was a keen and productive vegetable and fruit grower for our family use. Sadly he died two years ago, but know that he would be appalled to think that others could not be still working the plots in future. It takes years f or an allotment to be brought to a stage where the land can produce good crops and allotments cannot just be moved to a new site without great difficulty for the plot holders.

The paths alongside the site are also well used by local residents and dog walkers and would be a serious loss of access on foot. Wickham Market Village is not well served with open spaces and to develop this well-loved and green and ecologically beneficial area would be detrimental to the public good and against the wishes of many villagers. Summary: 776i/776l: This land was the subject of a previous proposal for development at which time many objections were raised and the idea was rejected on appeal by HMPI as being detrimental to the village amenities. The paths alongside the site are also well used by local residents and dog walkers and would be a serious loss of access on foot. Wickham Market Village is not well served with open spaces and to develop this well-loved and green and ecologically beneficial area would be detrimental to the public good and against the wishes of many villagers.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6352 - 3401 - Wickham Market - None 6352 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mr & Mrs Sean Swift [3401] Agent: N/A

Full Text: It has been brought to our attention by our Neighbour Mr George Hering that during an open public meeting held on the 12'" February 2015 the Chairman of the Wickham Market Parish Council, Cllr Richard Jenkinson gave an address to the public that a proposal for an area of Industrial Land has been put forward to be created on the North side of the Village, it is with this proposal that we wish to make an objection.

It is our belief that if this Industrial Estate is created it will have a thoroughly negative effect on the area of Countryside it would stand on thereby causing damage to the Conversation Area on which it would encroach. This Conservation Area of Wickham Market currently consists of rolling views of arable farm land backed by ancient woodland which extends down toward the Deben Valley, it is with huge concern we believe that creating a large industrial area will have a significant and tremendously detrimental effect on edge of this picturesque village.

The existing industrial estate currently has many empty units on it for Let as does nearby Bridge Farm so to see the justification of extending an already half redundant industrial estate seems futile. It is our belief that an industrial estate, should one be justified in rural Wickham Market, would be better located nearer access to the A12 which would also stop heavy duty machinery and Commercial traffic being forced down the already narrow WM high street or on the approaching road into the Village from Charsfield.

Finally we fear that this application has not been made available to the public and residents of WM for a fair reaction to be made, we are sure the reservations that we have to this proposal will be shared by many other residents of the village should they be given the chance to voice their concerns and objections and be given the opportunity to be heard. Summary: It is our belief that if this Industrial Estate is created it will have a thoroughly negative effect on the area of Countryside it would stand on thereby causing damage to the Conversation Area on which it would encroach. This Conservation Area of Wickham Market currently consists of rolling views of arable farm land backed by ancient woodland which extends down toward the Deben Valley, it is with huge concern we believe that creating a large industrial area will have a significant and tremendously detrimental effect on edge of this picturesque village.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6356 - 3404 - Wickham Market - None 6356 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mr & Mrs R C Read [3404] Agent: N/A

Full Text: Proposal to Extend Riverside Industrial Estate

The public meeting held on the 12th February 2015 highlighted future local planning proposals and residential development.

We are writing this letter to express our strong views against the area proposed as an extension to the present industrial estate.

The area marked 421 on Map 3 - Wickham Market SHLAA Sites has been turned down for residential development due to its impact on the landscape so how could an industrial area not have an incredibly detrimental bearing on the locale. As this tract of land is adjacent to a conservation area it is surprising and shocking that anybody could propose this site for such a purpose. It is presently in use as agricultural land in the human food chain and building on agricultural land has to our knowledge always been against policy. This particular area forms part of the charm and beauty of Wickham Market along with the quaint High Street cottages and Mill/River area. Indeed a local photographer regularly uses this area for pictures to enter a well known calendar competition.

Another objection is the traffic problem already appalling in the High Street. The cottages have no private parking and therefore need to use the roadside which causes chaos when commuters take a short cut to the Al4. One lady who uses the local bus service to get from Spring Lane to the Market Square said on one occasion the bus had to stop at least 12 times. Whilst residents and visitors have long accepted this situation it will become intolerable if more lorries and work vehicles use this congested route which is already proving difficult to access safely at times.

We would question the following:-

* Has enough research into the need for extra units been carried out (there are empty units both here and locally) * Have other areas been suggested which will not impinge on residential property or spoil an area of great beauty * Have all local residents been given a chance to give their views (many may have been unable to attend the meeting) * Has the traffic situation been thoroughly looked into * Have all paperwork in support of this proposal been made available to the public

We are given to understand that with the construction of Sizewell C more units would be needed in Wickham Market. With my personal involvement with Sizewell B all companies were told that any local business must be kept to the Leiston area and I would think that as the population of Leiston is most affected by the influx of traffic and operatives this would be the case again.

Our address will underline why we are personally horrified as this prospect. We have almost completed our dream retirement home on land purchased because of the location to amenities and the wonderful view over the countryside and we find this situation most distressing. All the properties immediately bordering this proposed site are new builds/barn conversation and purchased within the last 12 - 24 months and it is obvious that all these new residents will lose a great deal of money on the value of their properties If indeed they do not become virtually unsellable if this scheme is given the ahead.

Finally, whilst nobody would want an industrial site in their back garden there must be other areas within the parameters of the local council which have a more convenient access to the A12 and would not be directly disadvantageous to any residential properties. Summary: The area marked 421 on Map 3 has been turned down for residential development due to its impact on the landscape. How could an industrial area not have a detrimental bearing on the locale. This tract of land is adjacent to a conservation area; it is shocking that anybody could propose this site for such a purpose. It is in use as agricultural land in the human food chain and building on agricultural land has always been against policy. This area forms part of the charm and beauty of Wickham Market along with the High Street cottages and Mill/River area.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6392 - 2655 - Wickham Market - None 6392 Comment Woodbridge Housing Market Area Wickham Market

Respondent: Member of Parliament (MP) (Rt. Hon Therese Agent: N/A Coffey MP) [2655]

Full Text: Thank you for the opportunity to comment on the site allocations and area specific policies for the local plan. I think it is a welcome step to encourage all the public to participate in this early stage of the process. I only usually intervene on strategic issues and policies on planning.

While I have detailed my comments on some individual areas below, I have three particular issues to discuss - i) the imbalance of housing allocations around the area with the vast amount of development inserted east of the A12, the side of Suffolk that has the AONB and nearly all the SSSls; iii) the absence of nominated sites in Framlingham and Leiston; iii) building on main roads and the absence of infrastructure, particularly roads, for major and cumulative developments with the risk of significant congestion and longer journey times as well as community facilities.

Allocation of housing across the district

The vast majority of the proposed housing lies east of the A12 and to the south of the district. This continues to move the centre of gravity south east which runs the risk of excluding significant parts of our area of new housing for local people and also the lack of infrastructure (either new or upgraded). There appears to be a surprising disparity between settlements on where is deemed appropriate for further development and where is not. For example, no further housing is recommended for Wickham Market while Wenhaston, lower down the settlement hierarchy, has been recommended for more housing despite having just had an application for 26 new homes approved (higher than the Local Plan allocation of 5-15). Separately, Saxmundham has been recommended for further housing after a significant amount already built and under construction. I do not object specifically to that but will make the point later about infrastructure. There is little difference between Wickham Market, Saxmundham and Framlingham apart from the railway station. It has been suggested that Wickham Market has already had some housing so need not have any more and Framlingham has been allocated a small amount. That is in contrast to Leiston which has been allocated up to 500 houses, though with no additional infrastructure. The experience elsewhere does not bear that out. While it makes sense to allow for housing in villages and parishes as well as market towns but in a sensible proportion that does not dwarf existing villages. Therefore, I suggest that villages that have already had housing approved in the last two years should not have further sites specifically designated but allow for windfall, within the existing village envelope and not on main roads (like the A12 in Yoxford or A1120 in Peasenhall or the High Road in the Trimleys or the A144). It also should be on the same side of the main road as the local facilities - which would rule out nominated sites specifically in Yoxford and Woodbridge. We should not repeat the mistakes of the past. Another guiding principle should be that new housing is as close as possible to existing facilities. There is development planned on the opposite side of the main road to key facilities in some areas, which would significantly shift the centre of gravity and mean people having to cross busy roads to get to the centre. Shifting the centre of gravity of further development away from shops and facilities in towns, as may be the case in Saxmundham, is a retrograde step for enhancing the sense of community. The council must counter the risk of our small market towns becoming car-based, seeking shopping, leisure and sporting activities away from the town.

I strongly support the protection of green gaps, acting as strategic barriers between settlements.

There is an absence of nominated sites in Leiston and Framlingham. It has been suggested that this is due to emerging town plans but they should not have been absented from this consultation.

Finally, the absence of infrastructure. There is already huge pressure on various parts of the A12 and there is no indication of what infrastructure additions or upgrades are being proposed to accommodate such significant increases. In more specific terms,

i) Martlesham area with 2000 houses, adding to the increasing retail presence on the Martlesham Heath industrial estate. The latter is already leading to significant increases in traffic, coupled with further housing already under construction in Martlesham. Significant improvements need to be made to the A12 at several junctions. ii) Woods Lane roundabout and the A1152. There are already at least 15,000 traffic movements per day at the Melton railway crossing (sourced from Network Rail three years ago). Without substantial improvements to roads here, the additional housing suggested in Melton, Eyke and Rendlesham will bring even greater traffic movement pressure on the round about, the railway crossing and the traffic lights on the junction of the A1152/B1438. iii) Given the council's full support for the 4 villages bypass, it is surprising that no housing has been considered for this area as bypasses usually lead to significant increases in housing. Meanwhile, up to 500 houses are being proposed for Leisten but with no road improvements and no support for the potential D2 route being suggested in conjunction with Sizewell C. iv) In Saxmundham, a substantial number of new housing has already been built. While there has been minor modification of the traffic lights in the centre of the town, there has been no improvements planned to help traffic in and through the town. v) Woodbridge site at the football ground -addressing the congestion and the replacement of sporting facilities within the town area. vi) Local community infrastructure will need significant improvement - pace Rendlesham, Saxmundham, Leisten, the Trimleys and the new development at Martlesham. On local sites, I have commented by exception and no comment is not a sign of endorsement.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6392 - 2655 - Wickham Market - None 6392 Comment Woodbridge Housing Market Area Wickham Market

Woodbridge Housing Area

Campsea Ashe Site 557 is a very unusual place to add more housing especially if there is going to be work on the track for Sizewell C. I agree with 745 and 990 being unsuitable SHLAA sites. They are far too large and inappropriate. Eyke Agree that 991 and OPP7 are unsuitable sites. 991 looks to double size of village whereas Opp7 suggests substantial new housing along A-road which is unsuitable. Hollesley Agree that 825 is unsuitable - losing a significant amount of green field opposite school. Orford Agree that 494/484 & 976 is unsuitable. Surprised some sites proposed with sea levels. Tunstall Disagree that 786, 597 and 730 would all be suitable as a whole as seems to double the size of the village which is unnecessary over-development. Wickham Market Would support 7761 and 776i as it is a significant market town. Woodbridge Agree that sites 937 and 453 are unsuitable due to being west of the A12. 839,750,750a, 974 unsuitable due to pressure on roundabout.

Framlingham Housing Area

Bramfield Agree that 493 is unsuitable as it is too far away from the centre. Peasenhall Agree with 832 being unsuitable as outside the envelope and inappropriate. Wenhaston The village has already had a significant amount of development therefore I don't see the need for any further sites to be added. Strongly oppose any greenfield sites. Yoxford Strongly oppose accepted SHLAA sites 642b and 794. They are both opposite or adjacent to existing housing but involves crossing a main road to get to existing village facilities.

Saxmundham Housing Area

Aldeburgh Agree with unsuitable SHLAA sites in first map. Should continue to look for windfall sites. Strongly agree that 768 shouldn't be brought forward. Benhall Agree that 411b and 411c should not be brought forward. They would dwarf the village and would constitute overdevelopment. Blythburgh Disagree with 4UCB being brought forward as junction already very difficult and wouldn't cope. Darsham Agree that 378 and 967 are unsuitable as are considerably out of the village. Strongly disagree with 794 as it is too close to the main road and a strategic error. Dunwich Agree that 713 is unsuitable as is too far away from the village centre. Knodishall Agree that 506 which would dwarf the village, 579 which would significantly reduce the gap to Aldringham and 971 which would bring an unwarranted urban feel to that side of the village are unsuitable. Little Glemham 625 would put particular pressure on A12 which would require substantial highway change if it were to go ahead. Saxmundham Strongly agree that the non-hatched sites are unsuitable. Of the sites that have been endorsed 1006 and 1009, there is a risk of this development being too far away from the high street shift the centre of gravity. If this was to go ahead then there should be consideration for a relief road from the North entrance to the B1119. Snape Agree that 758 is unsuitable as too far out of the centre of the village. Westleton Agree with unsuitability of sites. Strongly oppose any development on 327 and 935.

Felixstowe Housing Area/Area Action Plan

Waldrlngfield Support 961 being a SHLAA unsuitable site. We need to protect this as a local gap. Bucklesham Most sites are too big and too far away from village centre. Kirton It is my understanding the Falkenham Road site has been backed in a local consultation session run by the Parish Council. Concerned about over development if all the other sites were approved. Trimley St Martin Agree that 920 and 889 are completely unsuitable. Trimley St Mary Concern that the current road network could cope with significant development on 383F. Agree with unsuitability of 383,c,d,e & 451e as too far away from centre. Summary: Wickham Market Would support 7761 and 776i as it is a significant market town.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6424 - 3412 - Wickham Market - None 6424 Comment Woodbridge Housing Market Area Wickham Market

Respondent: Helen Taylor [3412] Agent: N/A

Full Text: Site Allocations and Area specific policies - Local Plan Document Wickham Market

I am writing with regard to the above document to voice my opposition to the fact that within this plan, sites nos 776L (Glebe Allotments) (field beside Glebe Allotments adjoining Spring Lane) have been allocated for possible housing development in Wickham Market.

As an existing allotment holder on the Glebe Allotments site, I feel that to lose this site would be highly detrimental to the village environment. It is conveniently situated just off the High Street, which means that allotment holders are able to walk or cycle to the site, avoiding unnecessary and environmentally damaging vehicle journeys. The site is level, well drained and has excellent quality soil which has been further improved by allotment holders, many of whom have been on the site for some years. The site is well used and the allotment holders derive financial, social, physical and psychological benefits from tending the land and growing their own produce. Its situation next to a public footpath means that it is a social meeting place for many in the village.

The allotment site is a small green oasis central to the village, and provides a haven for wildlife within a residential area. Walking past the site in early morning it usually alive with birdsong. The green pockets within a village are important not just for wildlife but to enhance the lives of village residents.

I understand that, if this site was developed, an alternative allotment site of equal quality would be provided. The proposed alternative site in the adjoining field has many disadvantages compared to the current site. It would be further from the High Street, on sloping arable land which would require considerable effort to bring this land into a reasonable state for growing for allotment use. For many existing plot holders, who have cultivated their land for decades, this substantial effort would likely be a disincentive, and many would probably give up their plots.

I would also be opposed to the development on the site 776i, the field adjacent to the Glebe allotment site. There is no satisfactory access to this site, and the only way of providing one (via Yew Tree Rise), would lead to increased vehicle movements on a road which is already constricted because of resident's parking.

I believe that there are other areas of land within the village which would be better suited for development, for example 421 (land off Border Cot Lane) and land near Old School Farm.

I hope Suffolk Coastal District Council will be listening to both Wickham Market Parish Council (who have advised against development on either site) and village residents like myself and will reconsider their decision on site 776L and 776i. Summary: The allotment site is a small green oasis central to the village, and provides a haven for wildlife within a residential area. I believe that there are other areas of land within the village which would be better suited for development, for example 421 (land off Border Cot Lane) and land near Old School Farm.

I hope Suffolk Coastal District Council will be listening to both Wickham Market Parish Council (who have advised against development on either site) and village residents like myself and will reconsider their decision on site 776L and 776i.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6430 - 3413 - Wickham Market - None 6430 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mrs E Foden [3413] Agent: N/A

Full Text: I have lived in Wickham Market for over forty years. I am writing to register my disapproval of plans to develop the Glebe allotments and adjoining land here.

This land has been tended and soil improved for many years by the successive allotment holders and it would mean an unacceptable loss of pleasant green space in the heart of the village.

I am totally opposed to such a development and having attended the recent meeting here I know I am far from being the only one. It was a very unpopular proposal. Summary: I have lived in Wickham Market for over forty years. I am writing to register my disapproval of plans to develop the Glebe allotments and adjoining land here.

This land has been tended and soil improved for many years by the successive allotment holders and it would mean an unacceptable loss of pleasant green space in the heart of the village.

I am totally opposed to such a development and having attended the recent meeting here I know I am far from being the only one. It was a very unpopular proposal.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6432 - 3415 - Wickham Market - None 6432 Object Woodbridge Housing Market Area Wickham Market

Respondent: Pamela Johnson [3415] Agent: N/A

Full Text: I wish to protest most strongly at the inclusion of the Wickham Market Glebe allotments as a suitable site for building. It seems inconceivable that when planners are looking at future building sites they should have latched on to the Glebe allotments, a virtually accessible area for large vehicles, access only up a small residential road used for parking by High Street residents, and therefore at times a one track stretch of road.

Access to the Glebe would beam the destruction of parts of a mature hedge and across a well used public footpath used by shoppers and children going to and from school.

Also the loss of a busy useful village amenity where men and women have worked to my knowledge for well over 27 years, producing food for their households.

To get am allotment in a good productive state requires the dedication of an individual ,plus time, energy, expense and constant care.

The allotments are part of the "lung" of the parish, a greenspace for the recreation of the retired as well as young families to grow their own produce. It is a valuable space where people of the community meet for social interaction and the exchange of knowledge and information,

I earnestly urge the council planners to think again and leave this useful and productive apace to serve future generations of Wickham Market. Summary: To get an allotment in a good productive state requires the dedication of an individual ,plus time, energy, expense and constant care.

The allotments are part of the "lung" of the parish, a greenspace for the recreation of the retired as well as young families to grow their own produce. It is a valuable space where people of the community meet for social interaction and the exchange of knowledge and information, also the loss of a busy useful village amenity where men and women have worked to my knowledge for well over 27 years, producing food for their households.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6433 - 3416 - Wickham Market - None 6433 Object Woodbridge Housing Market Area Wickham Market

Respondent: Anne Seward [3416] Agent: N/A

Full Text: Re Site Allocations & Area Specific Development Plan Document Table 1 SHLAA sites Ref 776L

On 12thJuly 1989 Suffolk Coastal District Council was successful in defeating an application to develop housing on the Wickham Market Glebe Allotment. The Inspector from the Department of the Environment dismissed the Appeal and the evidence he used then still holds good to-day.

This means the SHLAA status for 776L (Glebe Allotment) should be corrected from SUITABLE to NOT SUITABLE.

No further applications for developments can be accepted.

I attended the recent Wickham Market public meeting and was very pleased to read the good report in to-day's EADT. I congratulate all involved in such a successful event and thank them for all their hard work.

From 1988 I have enjoyed all aspects of membership of the Glebe Allotment. There are more young families using this village amenity and with housing having smaller, or no, gardens there will be a continuous need for allotments. Summary: On 12thJuly 1989 Suffolk Coastal District Council was successful in defeating an application to develop housing on the Wickham Market Glebe Allotment. The Inspector from the Department of the Environment dismissed the Appeal and the evidence he used then still holds good to-day.

This means the SHLAA status for 776L (Glebe Allotment) should be corrected from SUITABLE to NOT SUITABLE.

No further applications for developments can be accepted. There are more young families using this village amenity and with housing having smaller, or no, gardens there will be a continuous need for allotments.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6436 - 3419 - Wickham Market - None 6436 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mr Gerald O'Brien [3419] Agent: N/A

Full Text: I write in connection with the meeting held in Wickham Market 12 February 2015 convened to discuss the further development of this village.

Of major concern is the proposed development of areas 776i & 776L shown on your maps & Table 1. In the late 1980's a meeting was concerned to discuss these area & the SCDC rejecting development in these areas. Among those reasons given was:- landscape impact and the need for the gardens (allotments) strategically situation which provide both food & recreation for peoples of all ages and circumstance & had done for generations - what has changed?

It will not have escaped your attention that the village infrastructure, roads & footpaths particularly are under considerable strain and dangerous;

Yet, you consider Plot 421 as unsuitable on the basis of "Landscape impact" It has to be asked what Landscape? And why has Landscape not be considered in respect of 776i 776L the reason given in your earlier report. At least Plot 421 would give an opportunity for road widening (and safety). Consider; that Broad Road access to the village amenities and schools would be safer than the present High St where the footpath in places is less the 2 feet.

Similarly if Plot 606 is considered "not suitable" on the basis of poor access. Why is it that Plots 776i & 776L are suitable, Surely it is easier to build infrastructure on open ground when such development in the High Street is impossible.

I await you comments Summary: It will not have escaped your attention that the village infrastructure, roads & footpaths particularly are under considerable strain and dangerous;

Yet, you consider Plot 421 as unsuitable on the basis of "Landscape impact" It has to be asked what Landscape? And why has Landscape not be considered in respect of 776i/776L the reason given in your earlier report. At least Plot 421 would give an opportunity for road widening. Consider; that Broad Road access to the village amenities and schools would be safer than the present High St where the footpath in places is less the 2 feet.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6450 - 3428 - Wickham Market - None 6450 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mr David Mercer [3428] Agent: N/A

Full Text: I recently attended a public meeting arranged by the Parish Council, a very well attended meeting, where information was given concerning the SCDC proposals headed Site Allocations and Area Specific Policies, Issues and Options Document.

I, as most of the rest of the meeting , was disturbed to hear you had designated Glebefield Allotments and the field to the east as the only suitable plots for development in Wickham Market. This is, as you will know, contrary to the wishes of the people of the village and the Parish Council (sites 776l and 776i)

I do wish to ask you to reconsider and offer one or two points to support the retention of these sites in their present use.

In terms of the effect to the village, I would regret the loss or relocation of the well-used allotments facility and also the removal of open green space in the central area of the village. The limited green areas having been noted in your documentation. The other major objection is to the drastic detrimental effect, in the short and long term, of this number of properties being built where vehicle access is so poor and road availability for onward travel is so restricted in both directions. A further objection would be over other issues of infrastructure of the village itself. We already suffer from High Street residents having to find parking space which is often in Yew Tree Rise. If this is to be an access point for the proposed development site then it would have to be double yellow both sides causing a need for High Street residents parking elsewhere. Could space be allocated in the site? I can see the attraction of the sites being near to the present sewerage works but I doubt these are adequate and that extra provision will be needed somewhere. I have been led to understand there have been difficulties with the facility now without any additional houses. The situation with schools, health, community services and traffic flows generally, would be further stretched by any additional housing in the village. However, if it has to come, I feel fringe sites to the north or south would be a better solution in terms of vehicle access as they could use, possibly improved, north and south access from the A12 without going through the village center pinch points.

I trust residents' feelings rather than developers wishes might be favourably received. Summary: In terms of the effect to the village, I would regret the loss or relocation of the well-used allotments facility and also the removal of open green space in the central area of the village. The limited green areas having been noted in your documentation. The other major objection is to the drastic detrimental effect, in the short and long term, of this number of properties being built where vehicle access is so poor and road availability for onward travel is so restricted in both directions. I trust residents' feelings rather than developers wishes might be favourably received.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6455 - 3434 - Wickham Market - None 6455 Object Woodbridge Housing Market Area Wickham Market

Respondent: J Carpenter M Margetts [3434] Agent: N/A

Full Text: At the an open public meeting held on the 12th February 2015, the Chairman of the Wickham Market Parish Council, Cllr Richard Jenkinson, gave an address to the public to explain the Wickham Market Local Plan in detail. He reported some very clear views that had been expressed by the public about the allocation of residential development. Whilst some of his address referred to the published plan which had been made available for public access and review, he surprisingly brought into discussion a proposal for an area of Industrial Land to the North of the village. It is with this proposal that I want to make an objection. He showed an area of land that joined the residential proposal 421, and continued straight across the back of the existing industrial estate and as he quoted "for the sake of neatening up the boundary" it went past the Industrial area and behind a residential areas that forms part of the conservation are of WM. SCDC has already refused a residential proposal on 421 on account of "landscape impact". If this Industrial land proposal is left to stand it would have a devastating effect on the local Wickham Market landscape and a hugely negative effect on the character of the village and to the conservation area to which it will border. The WM conservation document describes this area as follows: 'from the Northern approach to the village Bridge Farm, Deben Mills, the river and the Bridge combine to create a picturesque rural approach. This is further enhanced by the traditional cottages which mark the beginning of the village and the fact that the countryside appears to wrap itself around the back of these to the north and south thereby forming a soft edge to the village'. Replacing the countryside with Industrial land and possible development on such as a lengthy border at the edge of the village will create a hard and ugly line destroying the current soft and picturesque views of the Deben Valley. We question wheter enough research and justification been done to the requirement of this amount of Industrial expansion? There are empty industrial units to let at the current industrial estate and nearby Bridge Farm. We would argue that an industrial estate would be better placed somewhere nearer the A12 where Industrial traffic wouldn't need to use the very narrow approach roads to the Old Wickham Market village centre which is already creating a danger to all pedestrians and through traffic? The plan submitted seems as though its being hurried through with little thought to the consequences of the appearance of the village or consultation with the residents. Lastly, this application has not been made available to the public for their comment and reaction and I am sure many other residents of Wickham Market, given the chance, will have further reservations and concerns to this Industrial land proposal. Summary: Replacing the countryside with Industrial land and possible development on such as a lengthy border at the edge of the village will create a hard and ugly line destroying the current soft and picturesque views of the Deben Valley. There are empty units to let at the current industrial estate and nearby Bridge Farm. We would argue that an industrial estate would be better placed somewhere nearer the A12 where Industrial traffic wouldn't need to use the very narrow approach roads to the Old Wickham Market village centre which is already creating a danger to all pedestrians and through traffic?

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6456 - 3435 - Wickham Market - None 6456 Object Woodbridge Housing Market Area Wickham Market

Respondent: Dr A J Nelson [3435] Agent: N/A

Full Text: HOUSING DEVELOPMENT ON LAND REAR OR NEW VICARAGE (776L) AND LAND WEST OF SPRING LANE (776i) I would like to register my strong objection to the above proposed development, for the following reasons: 1 - Poor Access. The only feasible access route would involve opening up the top end of Yew Tree Rise in order to access the allotments site (776L). Even with its current level of traffic from 37 properties, the blind bend on Yew Tree Rise is a serious traffic hazard, exacerbated by the continual parking of vehicles by High Street/Snowdon Hill residents, which reduces the road to a single track. Refuse lorries and other large vehicles routinely mount the pavement in negotiating the bend in the road. Yew Tree Rise is clearly unsuitable for the proposed almost four-fold increase in traffic. 2 - Loss of Allotments. Describing the site currently occupied by allotments (776L) as "land to rear of New Vicarage, Crown Lane" is disingenuous. You must be aware the allotments are an important resources for the residents of Wickham Market, and the loss of this amenity would have a very negative impact on the village. Summary: Describing the site currently occupied by allotments (776L) as "land to rear of New Vicarage, Crown Lane" is disingenuous. You must be aware the allotments are an important resources for the residents of Wickham Market, and the loss of this amenity would have a very negative impact on the village. The blind bend on Yew Tree Rise is a serious traffic hazard, exacerbated by the continual parking of vehicles by High Street/Snowdon Hill residents, which reduces the road to a single track. Refuse lorries and other large vehicles routinely mount the pavement in negotiating the bend in the road.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6457 - 3436 - Wickham Market - None 6457 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mr George Herring [3436] Agent: N/A

Full Text: At the an open public meeting held on the 12th February 2015, the Chairman of the Wickham Market Parish Council, Cllr Richard Jenkinson, gave an address to the public to explain the Wickham Market Local Plan in detail. He reported some very clear views that had been expressed by the public about the allocation of residential development. Whilst some of his address referred to the published plan which had been made available for public access and review, he surprisingly brought into discussion a proposal for an area of Industrial Land to the North of the village. It is with this proposal that I want to make an objection. On screen, he showed an area of land that joined the residential proposal 421, and continued straight across the back of the existing industrial estate and as he quoted "for the sake of neatening up the boundary" it went past the Industrial area and behind a residential areas that forms part of the conservation are of WM. SCDC has already refused a residential proposal on 421 on account of "landscape impact". If this Industrial land proposal is left to stand it would have a devastating effect on the local Wickham Market landscape and a hugely negative effect on the character of the village and to the conservation area to which it will border. The WM conservation document describes this area as follows: 'from the Northern approach to the village Bridge Farm, Deben Mills, the river and the Bridge combine to create a picturesque rural approach. This is further enhanced by the traditional cottages which mark the beginning of the village and the fact that the countryside appears to wrap itself around the back of these to the north and south thereby forming a soft edge to the village'. Replacing the countryside with Industrial land and possible development on such as a lengthy border at the edge of the village will create a hard and ugly line destroying the current soft and picturesque views of the Deben Valley. Has enough research and justification been done to the requirement of this amount of Industrial expansion? There are empty industrial units to let at the current industrial estate and nearby at Bridge Farm. If necessary wouldn't an industrial estate be better placed somewhere nearer the A12 where Industrial traffic wouldn't need to use the very narrow approach roads to the Old Wickham Market village centre. The plan submitted seems as though its being hurried through with little thought to the consequences of the appearance of the village or consultation with the residents. Lastly, this application has not been made available to the public for their comment and reaction and I am sure many other residents of Wickham Market, given the chance, will have further reservations and concerns to this Industrial land proposal. Summary: Replacing the countryside with Industrial land and possible development on such as a lengthy border at the edge of the village will create a hard and ugly line destroying the current soft and picturesque views of the Deben Valley. There are empty industrial units to let at the current industrial estate and nearby at Bridge Farm. If necessary wouldn't an industrial estate be better placed somewhere nearer the A12 where Industrial traffic wouldn't need to use the very narrow approach roads to the Old Wickham Market village centre.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6459 - 3438 - Wickham Market - None 6459 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mr A M Boreham [3438] Agent: N/A

Full Text: I am writing to you to register my concern and objection to the Glebe Allotments and field in Wickham Market being listed by yourself as suitable for development and building on in the future. The question of using the Glebe Allotments has been looked as before and was found not suitable for this purpose. The situation with is property has not changed, in fact the site has been increased in size because of the demand for this type of land. This being so, and with the continuous use and cultivation of the land, I cannot see why it should now be considered suitable for development and building on. Summary: I am writing to you to register my objection to the Glebe Allotments and field in Wickham Market being listed by yourself as suitable for development in the future. The question of using the Glebe Allotments has been looked as before and was found not suitable for this purpose. The situation with is property has not changed, in fact the site has been increased in size because of the demand for this type of land. With the continuous use and cultivation of the land, I cannot see why it should now be considered suitable for development and building on.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6460 - 3439 - Wickham Market - None 6460 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mr M Oakley [3439] Agent: N/A

Full Text: I wish to register my opposition to the potential development of the Land rear of the New Vicarage in Wickham Market. Whilst being in favour of sensible development of in-fill sites I am opposed to this being done at the expense of popular and well used community facilities, in this case Allotments. Secondly and in this case more importantly is the issue of public safety. Access is proposed from Yew Tree Rise which itself is fairly narrow with a steep incline and sharp bend making visibility of oncoming vehicles often difficult. Added to this is the use of the hill in Yew Tree Rise by residents of High Street who have no off-road parking and who are prohibited from parking on the High Street. If we are to have another 30 properties and their accompanying vehicles and service vehicles I believe strongly that Yew Tree Rise will become "unsafe". If planning permission is sought in the future for the development of this land I will vigorously oppose it. The land beside the telephone exchange would seem to be far more appropriate for development and would enable the authorities to reduce the speed limit further back towards the turning to Easton. Summary: Access is proposed from Yew Tree Rise which itself is fairly narrow with a steep incline and sharp bend making visibility of oncoming vehicles often difficult. Added to this is the use of the hill in Yew Tree Rise by residents of High Street who have no off-road parking and who are prohibited from parking on the High Street. If we are to have another 30 properties and their accompanying vehicles and service vehicles I believe strongly that Yew Tree Rise will become "unsafe". The land beside the telephone exchange would seem to be far more appropriate for development.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6461 - 3440 - Wickham Market - None 6461 Object Woodbridge Housing Market Area Wickham Market

Respondent: Dennis & Karen Crane [3440] Agent: N/A

Full Text: We were made aware by George Hering another resident of Gospel Hall Close that a proposal had been put forward by the Parish Council for an allocation of Industrial Land behind this residential close. We strongly object to this plan being adopted. We feel it will detract from the conservation area in which we live and potentially create noise, light and industrial traffic pollution to the lower end of the High Street which is already suffering from traffic congestion problems. We urge SCDC to reject this proposal and ask the Parish Council to find a more appropriate site with better road access to the A12 bypass. Summary: We were made aware that a proposal had been put forward by the Parish Council for an allocation of Industrial Land behind this residential close. We strongly object to this plan being adopted. We feel it will detract from the conservation area in which we live and potentially create noise, light and industrial traffic pollution to the lower end of the High Street which is already suffering from traffic congestion problems. We urge SCDC to reject this proposal and ask the Parish Council to find a more appropriate site with better road access to the A12 bypass.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 6500 - 3453 - Wickham Market - None 6500 Object Woodbridge Housing Market Area Wickham Market

Respondent: Mr R J Last [3453] Agent: N/A

Full Text: Following the Wickham Market Public Planning Meeting on the 12th February 2015,I learned that there is a proposal to extend the Riverside Industrial Estate. I strongly oppose this proposal as it borders on the village Conservation Area within which are residential properties overlooking the Deben Valley with its typical Suffolk undulating fields and tree lined River Deben. In the summer months this view is silhouetted by stunning sunsets over trees which the residents are privileged to enjoy. They have had to abide by strict planning constraints including existing trees and hedge planting because of the Conservation Area only to find that somebody wants to dump an industrial estate in front of these views despite these supposed stringent planning requirements.

As you will see from my address I am directly affected by this proposal which had deeply disturbed me as at present I am spending a considerable amount of money converting The Barn and its outbuilding to provide me with my retirement home only to find that my desires and aspirations to live with this idyllic view will be dashed by this proposal. These buildings are part of Wickham Market's heritage and have overlooked this landscape since their conception. I am sure other residents who are affected by this proposal will be disturbed at the possibility of losing this vista, not to mention the fact that their properties will be devalued. I also understand that the proposed residential development 42l, which would appear to be linked to the industrial proposal, has been refused on the grounds of "landscape impact", surely the same would apply to this proposal.

Other matters which concern me with this proposal are firstly, the B1078 which has become a rat run for commuter traffic going East and West to avoid the A14 and A12 around Ipswich and must be used to access Riverside Industrial Estate. During the week the traffic in the High Street comes to a standstill with vehicles mounting the pavements trying to push their way through and a larger industrial area would only exacerbate this scenario. It has taken me up to ten minutes to exit on to the High Street only then able to turn North as going into the village is blocked up to the B1078. Secondly, if more industrial units are required, which I doubt as there are units in and around the village unoccupied, surely it would be sensible to locate them outside the village with easy access to the A12 without their traffic coming into the village and inconveniencing the residents. Summary: I strongly oppose the proposal extend the Riverside Industrial Estate as it borders on the village Conservation Area within which are residential properties overlooking the Deben Valley with its typical Suffolk undulating fields and tree lined River Deben. In the summer months this view is silhouetted by stunning sunsets over trees which the residents are privileged to enjoy. They have had to abide by strict planning constraints including existing trees and hedge planting because of the Conservation Area only to find that somebody wants to dump an industrial estate in front of these views despite these supposed stringent planning requirements.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5525 - 1890 - Woodbridge - None 5525 Object Woodbridge Housing Market Area Woodbridge

Respondent: Mr Derek Downer [1890] Agent: N/A

Full Text: We are fully aware of the supposed need for more housing, but as to why it is always the green field sites and not the brown field areas is difficult to explain; other than the economic cheapness of developing one against the other. Most of the need in this area is for homes for people escaping from London and retirement. Little thought seems to have been given to the need for schools and medical facilities, work and not least the services such as water, sewerage and power requirements. We are quite sure that the existing services to the present site could not be used for another 90 houses or so. In this area we have the proposed development of the B.T. site of some 2000 units; and that is just the beginning as the site plan shows large areas for future development; The Bloor Homes site at the top of Main Road, Martlesham (100 plus units), the development of the area between Sandy Lane, Ipswich Road and Dukes Park (150 plus units) and now another 96 homes on the Woodbridge Town Football club site. It so happens that we have very little recreational space this side of the A12. Little thought seems to have been given to the increased traffic requirements that such developments would generate. Starter homes are a great idea, but no one seems to have thought that most of these will be required by young people and that they will need to work and have transport links, plus schools for their children. We have a good example of the latter by what we see from the present Seckford Heights site in which 18 starter homes develop more movements than the rest of the site put together, also the fact that the greater part of the movements are at peak times. ( This is not a figment of nimbyish bias, but as was proved by an earlier traffic movement survey carried out when a previous attempt to remove the football club was made some four or five years ago.) The original layout of the Persimmons Seckford Heights site with Fynn Road as the axis was made without any thought to future development when the existing road to the football club at the end of Seckford Hall Road was closed off. Fynn Road is "S" shaped in configuration and makes no allowance for the residents exiting their sites and the movement of other vehicles on the road. There is a solution to this problem in either not going ahead with the development or the construction of an entirely new access road into the site. This could very easily be done by making a connection into the Ipswich Road at the end of the present football club car park where the elevation between the site and the road is least. This could also provide a green area at this end of the site instead of down at the bottom adjacent of the A12 roundabout where it would be of no use to anyone. Fynn Road would need to become a no through road to traffic, although pedestrian access could be accommodated. Having seen the latest communication from Hopkin Homes, it is so obvious that if there is another Notcutt site at Melton, then why not build the houses there? There would be no access problems there and then leave the sports clubs where they are. W.T.F.C premises are used by many other organisations, such as the W.I., Weight Watchers etc., etc. Summary: It so happens that we have very little recreational space this side of the A12. Little thought seems to have been given to the increased traffic requirements that such developments would generate. Starter homes are a great idea, but no one seems to have thought that most of these will be required by young people and that they will need to work and have transport links, plus schools for their children. Little thought seems to have been given to the need for schools and medical facilities, work and not least the services such as water, sewerage and power requirements.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 5531 - 3123 - Woodbridge - None 5531 Comment Woodbridge Housing Market Area Woodbridge

Respondent: Miss Alma Bartley [3123] Agent: N/A

Full Text: Dear Sirs. When discussions are taking place please can an answer be found to the problem of the derelict building at the bottom of Crown Place. Some time ago it appears that plans were approved for housing on this site. Nothing has happened and this is quite a disgrace to the town. It is almost the first place people see as they enter the town by car and does not give a good impression. It was bad when I came here 12 years ago and has of course become a much worse situation since then. Summary: Dear Sirs. When discussions are taking place please can an answer be found to the problem of the derelict building at the bottom of Crown Place. Some time ago it appears that plans were approved for housing on this site. Nothing has happened and this is quite a disgrace to the town. It is almost the first place people see as they enter the town by car and does not give a good impression. It was bad when I came here 12 years ago and has of course become a much worse situation since then.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5847 - 3289 - Woodbridge - None 5847 Object Woodbridge Housing Market Area Woodbridge

Respondent: Francis Dunn [3289] Agent: N/A

Full Text: I am writing to register my objection to the proposed housing development: - Prominent position giving poor view of entry to Woodbridge. - Increased noise and air pollution. - Traffic access.

My main concerns are linked to increased traffic since already: - vehicles from both Fynn Road and the Oxford Drive area feed onto Seckford Hall Road causing congestion at the junction with Old Barrack Road, particularly at busy periods. - vehicles park on Seckford Hall Road right up to a blind bend. - Old Barrack Road is fed by a number of side roads and is used regularly by public transport so causing further congestion at the Ipswich Road junction. - Ipswich Road junction lacks clear sight of traffic from Woodbridge due to a bend and dip (traffic increased when the Sutton Hoo site developed) coupled with vehicles coming out of California.

As the main road into and out of Woodbridge from the East, Ipswich Road is bound to see greatly increased usage from the BT development of 2000 homes. This and other developments in the area will cause us to suffer from more noise and air pollution and I fear greater risks of accidents at the Seckford Hall Road/Old Barrack Road and the Ipswich Road junctions. Therefore I urge that if planning permission has to be granted then access should be by a new road onto the mini- roundabout where the road to Martlesham Top Street feeds off and Fynn Road should be closed off at the point where it ends now by the Football Ground. Summary: As the main road into/out of Woodbridge, Ipswich Road is bound to see increased usage from the BT development of 2000 homes. This and other developments in the area will cause us to suffer more noise and air pollution and a greater risk of accidents at the Seckford Hall Road/Old Barrack Road and Ipswich Road junctions. If planning permission has to be granted then access should be by a new road onto the mini-roundabout where the road to Martlesham Top Street feeds off and Fynn Road should be closed off at the point where it ends by the Football Ground.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

O - 5848 - 3290 - Woodbridge - None 5848 Object Woodbridge Housing Market Area Woodbridge

Respondent: Malcolm & Carol Alder [3290] Agent: N/A

Full Text: As residents of Seckford Heights we are aware of the proposed development on Woodbridge Town Football Club site and would like to raise objections to this planning application.

General Location

We feel that this would completely alter the landscape to visitors entering the historic town of Woodbridge. As you enter via the A12 from Martlesham the area looks green and relatively unspoilt, if a housing estate was built on the proposed land this would completely change it into a modern brick and tile heap placed on top of a hill.

Access

The plans clearly show that all traffic coming in and out have to use one access that comes out onto the Woodbridge Road. When leaving Seckford Road in the morning the sun is straight in your eyes making it particularly difficult to see when entering Barrack Road and waiting to get onto the Woodbridge Road. This is a spot just waiting for a fatal accident as it is on the brow of a hill with a bus stop and a road opposite making it a cross road. Although a crossing has been installed very close to the Pub at the junction, school children still ride their bikes from the road opposite across the Woodbridge Road to get to Barrack Road. This is a particularly dangerous move as the children have to cross in front of drivers turning right, a situation that will only get worse if this development went ahead.

If the Woodbridge Football Club moves to the proposed side, it can hardly be called 'Woodbridge' more like Ufford!!! Being a member of the club I very much doubt if many members would use this new venue for social events which are needed for the club to survive. Summary: SHLAA site reference 900a: As residents of Seckford Heights we are aware of the proposed development on Woodbridge Town Football Club site and would like to raise objections to this planning application. We feel that this would completely alter the landscape to visitors entering the historic town of Woodbridge. As you enter via the A12 from Martlesham the area looks green and relatively unspoilt, if a housing estate was built on the proposed land this would completely change it into a modern brick and tile heap placed on top of a hill.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6005 - 3065 - Woodbridge - None 6005 Comment Woodbridge Housing Market Area Woodbridge

Respondent: Historic England (Mr Tom Gilbert-Wooldridge) Agent: N/A [3065]

Full Text: Suffolk Coastal Site Allocations and Area Specific Policies *

Thank you for your letter dated 12 December 2014 regarding the above consultation.

We would like to make the following comments:

Section 3: Housing

Q1: Do you have any thoughts on the approach to housing distribution that the Council has followed? The Council's approach to housing distribution, which follows a more considered approach to reflect the wide variety of settlement types and character and their needs and aspirations for future development, seems preferable to a more rigid approach of distributing housing equally between settlement types. However, it will require a careful and detailed analysis of settlements to ensure that distribution of housing is appropriate. The historic environment is a critical factor in this analysis in terms of considering the ability of settlements to accommodate new housing without undue harm to heritage assets. We hope that through the Strategic Housing Land Avaialbity Assessment (SHLAA) and Sustainability Appraisal (SA) processes that heritage impacts are properly considered when assessing sites. Our advice on assessing site specific proposals (see our SA letter of 12 December 2014) remains relevant.

Q3: Using the information in the Map Booklets, which housing sites are most appropriate?

* We have limited our assessment of sites to those settlements in Tables 2 to 6 where there is an indicative suggested housing allocation. We have used the map booklets for each housing market sub-area, and focused on those sites shown as "suitable" in the SHLAA.

Please note that due to time and resource constraints we have not been able to assess every site in great detail. Our comments on sites have been based on rapid desk-based analysis and limited site visits and we have not had the opportunity to ascertain precise impacts. We have focussed on those sites with the potential for the greatest historic environment impact. This does not mean there are no issues with any other site and we reserve the right to comment further on any site as and when proposals develop.

Please also note that we have not considered areas of archaeological interest beyond scheduled monuments in most cases, nor have we looked at historic landscape issues beyond registered historic parks & gardens. However, wider archaeological and landscape impacts are important considerations and need to be factored into site assessment. The possible cumulative impact of a number of site allocations in one location could cause significant harm to the historic landscape. Advice from conservation and archaeological staff at district and county levels should be sought, along with consultation of the Suffolk Historic Environment Record (HER) for specific heritage assets.

*

Martlesham Heath The SHLAA sites shown in Map 3 of the map booklet for Martlesham Heath (430, 517, 644 and 693) are not mentioned in the accompanying table. They appear to extend beyond the site boundary of the Adastral Park site. This is significant as the SHLAA sites include or adjoin a number of scheduled monuments to the south and east at Spratt's Plantation and Brightwell Heath. We have commented on historic environment issues in this location in relation to the Adastral Park applications. We would welcome clarification on the SHLAA sites and the intended allocations for Martlesham (notwithstanding the potential neighbourhood plan).

Westerfield Westerfield is a village centred on a cross roads with ribbon development along all four roads leading into the village, and with a number of proposed development sites. There is scope for some further infill frontage development along the roads leading into the village and site 939 would have no impact on the historic environment. The development indicated in front of Mill Farmhouse (Grade II) would result in some harm to the setting of this listed building. English Heritage is also concerned that development in depth on the east side of the road leading into the village from the south (sites 564 and 622) would harm the setting of the Grade I listed Church of St Mary Magdalene and the adjacent Grade II listed former Rectory. However, there may be scope for some frontage development to these sites along this road. The drainage ditch in the field containing site 622 may be of some historic interest and advice on this should be sought from the County Archaeologist on its archaeological potential.

To the north of the village there are three development sites proposed; 702a, 702b and 702c. Site 702c is modest in size and would have no impact on the historic environment. However, sites 702a and 702b both would adversely impact on the setting of an important group of listed buildings comprising the Grade II* Westerfield Hall, the Grade II Westerfield Hall Farm and the Grade II Swan's Nest. Currently this group of buildings are detached from the village and enjoy and open view out over the fields to the east. Development on site 702a would effectively bring them in to the

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6005 - 3065 - Woodbridge - None 6005 Comment Woodbridge Housing Market Area Woodbridge

village, while development on site 702b would be extremely harmful to their setting and block important views out from to the east.

The proximity of Westerfield to Ipswich and the Borough Council's proposed Ipswich Garden Suburb is an important consideration when looking at potential site allocations around the village. There could be considerable change to the wider setting of Westerfield and its heritage assets as a result of the garden suburb, and village allocations could have cumulative impacts. Given that the indicative allocation for Westerfield is only 10-20 dwellings, and there are a large number of 'suitable' sites in the village, we hope this amount can be accommodated without unacceptable harm to heritage assets.

*

Easton Easton is a linear village arranged along the valley floor, with the ground sloping steeply up to the northeast. Site 672a abuts the boundaries of the Easton Conservation Area and rises away from the road to encircle round behind the primary school. Development on this site would adversely impact on the setting of Verandah Cottages (Grade II listed) which lies immediately to the southeast of the site and there is also the potential for harm to the character and appearance of the conservation area through the new housing rising up the slope and being visually prominent along the skyline. Depending on the extent to which the development climbs up the hill, there is also the potential for it to impact on the setting of the moated scheduled site at Bentries Farm, which is on the higher ground above the village and has commanding views south back towards this site. The tall stacks on Verandah Cottages are currently clearly visible in these views.

Framlingham We note that the intention is for the indicative suggested housing allocation of 75-150 dwellings for Framlingham to be delivered through the emerging Neighbourhood Plan, and as such, the Map Booklet does not cover this settlement. However, it should be noted that Framlingham has a very rich historic environment, with many designated heritage assets including a conservation area centred on the historic core, multiple listed buildings and a large scheduled monument covering Framlingham Castle and its surroundings (the castle is also in the guardianship of English Heritage). We are very keen to engage in the Neighbourhood Plan as it evolves.

In terms of the SHLAA, we would welcome the opportunity to comment on Framlingham sites that might be considered 'suitable' and/or 'developable' to ensure that they are appropriate from a historic environment perspective.

Peasenhall Peasenhall is a linear village that follows the watercourse running parallel to the main road through the village. Site 400 is located adjacent to the boundaries of the conservation area, but a well-designed development that replicates the traditional relationship of cottages to the road might be acceptable. A conventional modern housing development of detached and semi-detached properties set in the middle of their plots would be harmful to the character and appearance of the conservation area. Therefore, if this site is to be pursued we would strongly recommend that a development brief is prepared to guide how development of this site should proceed.

Wenhaston Wenhaston is a village that has seen significant 20th century development; its historic centre is marked by a cluster of Grade II listed houses towards the northern end of the village, with the Grade I listed Church of St Peter sited on high ground immediately south of this cluster. A number of development sites are proposed in the village. Site 518 is away from the main part of the village and is unlikely to impact on the historic environment. Site 695 is a triangular site enclosed on two sided by 20th century housing and again will have no impact on the historic environment, though the southeastern boundary of this site is very prominent on the skyline in the approach to the village along Hall Road, and would therefore benefit from careful treatment.

Site 938b is of some concern to English Heritage. This is located immediately west of the cluster of Grade II houses that form the historic core of the settlement, and to the north of the Grade I listed church. The tower of the church is currently clearly visible across this site and development on this site would harm the setting of the Grade I church. Furthermore, Back Road and Bramfield Road that abut the site are narrow, traditional country lanes bounded by high hedgerows that would require significant change to support housing development. Such changes along Back Road in particular would again be harmful to the wider setting of the church. Site 938a is of less concern to English Heritage, though we would question whether it is suitable for development in depth and suggest that frontage development along Heath Road would be more appropriate. Site 733 is a triangular site at the northern end of the village where the land drops away, and the topography is such that a well-designed development would be unlikely to adversely impact on the setting of nearby heritage assets. Development of this site would also provide the opportunity to enhance the current rather scruffy appearance of the site's southern corner.

*

Aldeburgh Aldeburgh is an important historic settlement with a large number of heritage assets. Sites 608 and 982 are all remote from the historic core and are unlikely to adversely impact on any designated heritage assets.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6005 - 3065 - Woodbridge - None 6005 Comment Woodbridge Housing Market Area Woodbridge

Leiston We note that the intention is for the indicative suggested housing allocation of 250- 500 dwellings for Leiston to be delivered through the emerging Neighbourhood Plan, and as such, the Map Booklet does not cover this settlement. However, it should be noted that Leiston has a number of designated heritage assets, including a conservation area and several listed buildings, with the scheduled monument of Leiston Abbey situated to the north of the settlement (the abbey is also in the guardianship of English Heritage). We would wish to engage in the Neighbourhood Plan as it evolves.

In terms of the SHLAA, we would welcome the opportunity to comment on Leiston sites that might be considered 'suitable' and/or 'developable' to ensure that they are appropriate from a historic environment perspective.

Saxmundham Saxmundham is an important historic settlement that has seen extensive 20th century housing development, though most of this has been to the east of the High Street, on land running up to the A12. The Grade II* listed Church of St John the Baptist is located east of the High Street on Church Hill, which rises east away from the settlement. The church itself is prominent in views approaching the settlement from the south. It is noted that new housing has recently been completed on the site on the north side of Church Hill directly opposite the church and development of sites 1006 and 1009 would continue this precedent. However, development on the southern end of site 1009 would have the potential to adversely impact on the setting of the church. In particular the rising ground may place houses in the backdrop of the views of the church from the southwest. English Heritage therefore recommends that a landscaped buffer is retained at the southern end of site 1009 adjacent to Church Hill in order to protect the setting of the church.

*

Orford Orford is an important historic settlement with a large number of heritage assets, including an extensive conservation area, the Grade I listed Chruch of St Bartholomew and the Grade I listed and scheduled Orford Castle (the castle is also in the guardianship of English Heritage). Site OPP4 appears remote from the historic core and is unlikely to adversely impact on any designated heritage assets.

Woodbridge Woodbridge is an important historic settlement with a large number of heritage assets, including a several highly graded assets. Sites 635, 703, 900a and 7636 are all remote from the historic core and are unlikely to adversely impact on any designated heritage assets.

Section 4: The Economy

Q12: What do you consider to be the main issues which need to be addressed to ensure the Martlesham site remains successful into the future? The Martlesham Heath Business Campus (including Adastral Park) is a site we have commented on in recent years relating to the proposed redevelopment for employment and housing purposes. Our primary concern has been impact on a number of scheduled monuments consisting of pre-historic barrows at Spratt's Plantation, Brightwell Heath and beyond. Impact on the historic buildings and structures within the site (connected to the military use of the site) and on the wider historic landscape have also featured as concerns (for example, see our advice letters on the Adastral Park scheme from 2008 and 2009). Any redevelopment proposals for the Martlesham site will need to take the historic environment into account, with sufficient wording in any new or revised policies for this site.

Q14: Should the Ransomes Europark allocation be extended onto the land adjacent within the AONB? Extending the employment allocation into the AONB could have an impact on a number of scheduled monuments immediately to the east (and presumably affect the AONB itself). There are several pre-historic bowl barrows (burial sites) as part of the Seven Hills barrow cemetery. We strongly recommend that potential impacts on the significance and setting of these scheduled monuments is considered before any decision is made on extending the allocation.

Q18: Are there any tourist related matters that you would like to bring to our attention? We remain interested in proposals relating to Snape Maltings following our advice on various schemes over the years. We would welcome the updating of Policy AP166 providing that any revisions are compatible with the conservation of the site's heritage assets. The maltings are a sensitive historic site, with a conservation area and two listed buildings. Care will need to be taken that any updated policy still ensures the conservation and enhancement of these heritage assets, and we would be happy to comment on any emerging draft wording. We note the intention to delete Policy AP165 relating to an interpretative centre for

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6005 - 3065 - Woodbridge - None 6005 Comment Woodbridge Housing Market Area Woodbridge

East Lane Bawdsey connected to the military heritage of coastal defences in this location. The intention is to rely on the Core Strategy for any proposals in this location. We hope that this approach would ensure the conservation and enhancement of the various heritage assets in this location, including the Martello Towers.

We also note the perceived need (from town and parish councils) for improved visitor management in tourist hotspots such as Orford, with car parking identified as an issue. Any improvements to visitor management, including new car parks, should take into account potential impacts on the historic environment and specific heritage assets.

Q19: Given the definition of Main Town Centre uses in the NPPF, the unique character of the individual market town and the desire to see the town centres remain viable and vibrant areas into the future, do you think the town centre boundary as currently defined is the most appropriate? We do not have a strong view on the exact form of town centre boundaries, but consider that they are a useful tool to help with the vitality and viability of town centres. All of the district's town centres (including Felixstowe which is covered by the emerging Area Action Plan) have important historic environments with many heritage assets. Efforts to retain and enhance the vitality and viability of town centres should therefore conserve and enhance the historic environment. In 2013, we published a review of retail and town centre issues in historic areas, which may contain a number of relevant recommendations and case studies for this plan. The review can be downloaded from our website at: http://www.english-heritage.org.uk/professional/advice/advice-by-topic/heritage-and- growth/changingface-high-street/

Section 5: The Environment

Q26: Are there any buildings/groups of buildings that you would wish to nominate for consideration as non-listed heritage assets? We welcome the Council's commitment to producing a register of non-listed heritage assets. This should consider all heritage asset types, rather than just buildings (e.g. historic parks and gardens). While we do not have any specific nominations, we have produced advice on local listing to help with the selection and management of non-listed heritage assets, which can be found on our website at: http://www.englishheritage.org.uk/caring/listing/local/local- designations/local-list/

Beyond the issue of local listing and conservation area designation, it is unfortunate that the consultation document does not discuss the overall approach to the historic environment in this plan. Paragraph 126 of the National Planning Policy Framework states that: "local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment". The NPPF also states that local plans should include strategic policies to deliver the protection and enhancement of the historic environment (paragraph 156) and should identify land where development is inappropriate because of its environmental or historic significance (paragraph 157).

The Local Plan as a whole should be able to demonstrate that it sets out a positive strategy for the historic environment. This means that, on balance, the Local Plan has a positive effect on the historic environment and heritage assets. Different sections of the Local Plan should form part of the overall positive strategy, such as proposals for housing, regeneration, town centres or employment development. Policies throughout the Local Plan should help deliver the conservation of the historic environment with appropriate references where necessary. At the same time, a specific historic environment policy is encouraged as it helps to emphasise and implement the "positive strategy" required by the NPPF.

The Core Strategy does not have a specific historic environment policy, with certain aspects covered in other policies such as SP15 (Landscape and Townscape) and DM21 (Design Aesthetics) and policies for specific settlements. The saved policies from the old Local Plan again cover certain aspects such as conservation areas (Policy AP1) and historic parks and gardens (Policy AP4) or specific locations. There is a lack of a clear strategy relating to the historic environment at present, and we would encourage greater clarity. This should set out the Council's approach to the management of designated and non-designated heritage assets (including archaeology) and how issues such as heritage at risk will be tackled. We welcome the intention to retain and update Policies AP1 and AP4 from the old Local Plan, but this should be as part of wider review and update of the Council's approach to the historic environment.

We have attached a copy of our draft Good Practice Advice Note on the historic environment in Local Plans, which has been subject to public consultation in 2014 and should be published in its final form later this year (see: http://www.englishheritage.org.uk/publications/guidelines- and-standards/consultations/). We hope this is of assistance when drafting the next iteration of this plan. We would also be happy to discuss the Council's approach to the historic environment.

We hope that the above comments are of assistance. Please do not hesitate to contact me if you have any queries. We look forward to the next iteration of this plan. Summary: Woodbridge is an important historic settlement with a large number of heritage assets, including a several highly graded assets. Sites 635, 703, 900a and 7636 are all remote from the historic core

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6005 - 3065 - Woodbridge - None 6005 Comment Woodbridge Housing Market Area Woodbridge

and are unlikely to adversely impact on any designated heritage assets.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: gpa1-he-local-plans-consultation.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6085 - 2839 - Woodbridge - None 6085 Comment Woodbridge Housing Market Area Woodbridge

Respondent: RSPB (Jacqui Miller) [2839] Agent: N/A

Full Text: Re: Suffolk Coastal District Council Site Allocations and Area Specific Policies Issues and Options Consultation Thank you for inviting the RSPB to comment on the Site Allocations and Area Specific Policies Issues and Options Consultation. We are pleased to provide the following response. Whilst we are generally supportive of the approach at this stage, we consider that more work will be required (specifically relating to Habitats Regulations Assessment, green infrastructure and ecological networks) to ensure that the final documents are fully justified and effective. Site Allocations and Area Specific Policies Issues and Options Document Q25. Do you have any thoughts on the approach set out [to Natural Environment and Coastal Change]? The Natural Environment section needs to set out how it will ensure that no adverse effects will arise to European nature conservation sites (Special Protection Areas, Special Areas of Conservation and Ramsar sites) as a result of policies within the Site Allocations DPD. This should encompass the need for Habitats Regulations Assessment (HRA) at the strategic level and later, at the level of individual projects. HRA of the Site Allocations DPD will be required as it will constitute a plan or project, as defined by the Conservation of Habitats and Species Regulations 2010 (as amended). HRA will also be required later, at the individual project level due to the greater certainty and level of detail available with regard design and number of units etc. at this stage. Such an approach would be in accordance with the Council's Development Management Policy DM27 - Biodiversity and Geodiversity, and with paras. 14 and 119 of the National Planning Policy Framework. Similarly we recommend that Para. 1.33 on HRA should be updated as above, to incorporate details as to when HRA will be expected. With reference to Table 9 Designated Nature Conservation Sites, we note that there should be five (not four) SPAs recorded within the Suffolk Coastal district. These comprise the Orwell (part of Stour and Orwell Estuaries SPA), Deben Estuary, Alde-Ore Estuary, Sandlings and - Heaths and Marshes). Para. 5.5 references the Deben and Orwell as the relevant SPAs/SACs/Ramsar within the district - we suggest that this is amended to reflect that there are several other European sites within the area (see comment above). Q28. Are Biodiversity Action Plan, local ecological networks, priority habitats and priority species given sufficient policy coverage? Ecological networks and green infrastructure Due to the linkages between ecological networks and green infrastructure provision, we have considered both together in our response here. The RSPB consider that work to identify potential enhancement measures for local ecological networks could build on the work carried out as part of the 2008 Haven Gateway Green Infrastructure Strategy and the 2011 Green Infrastructure Strategy for the Suffolk Coastal district. At present the district Green Infrastructure Strategy appears focused on recreational provision. Whilst important, we consider that there is also an opportunity to expand the Strategy to include biodiversity targets. This should aim to create networks of sites of biodiversity value that 'fill the gaps' between existing green space features and sites of importance for biodiversity. Joined up networks are more functional and allow species to move between sites, helping them to adapt to the likely effects of climate change. We recommend that the currently available maps of priority habitat types are supplemented by map(s) showing designated sites (including international sites, SSSIs and County Wildlife Sites). These maps of current biodiversity resource can then be used to identify those areas which could be targeted for restoration, buffering or linkage through habitat creation or restoration. While it is important to note that existing designated wildlife sites should not have their ecological function undermined through a desire to use them for any other purposes which may be detrimental to their interest features, new greenspaces should perform multiple functions. Para. 6.2 of the Issues and Options consultation document refers to Core Strategy Objective 14 relating to Green Infrastructure, which states that: Access to green space is important for people's mental and physical well-being. Green spaces also have a function to play in helping to adapt to climate change and can be used to form green corridors which can benefit and boost wildlife. In addition, the creation of new green infrastructure is required to mitigate the impact of new development, to provide alternative recreation/leisure space for existing and new residents, to help relieve pressure on the estuaries and their populations of over-wintering birds. Objective 14 makes the following commitments: A comprehensive green infrastructure network will be achieved by establishing and maintaining a network of accessible good quality play spaces, sport and recreation facilities (including allotments) based on established standards. In addition there will be a growing network of natural green spaces across the district based upon local standards to be created. We recommend that the implementation of the opportunities identified within the 2011 Green Infrastructure Strategy should be prioritised. We also suggest that the creation of a Green Infrastructure advice pack for developers would be beneficial, similar to that produced by St Edmundsbury Borough Council1. Following this example, we recommend that consideration be given to the division of the district into zones with their own ecological and community objectives and targets, based on and informed by local priorities. These should promote the masterplanning and design of green infrastructure from the outset of any housing scheme, so that it provides a coherent framework for the overall development and makes a clear contribution to local ecological networks. Any major housing scheme should have a green infrastructure strategy detailing what will be provided, where it will go, when it will be completed, sources of funding and who will carry out long-term maintenance. It is important that green infrastructure is not seen as a 'bolt on' at the end of the development process. Development schemes should also consider the ecological function of the site, through the protection and enhancement of existing features and/or the creation of new ones. Designs should be appropriate to the landscape and seek to benefit locally important species and habitats. Again, this could be informed by the green infrastructure advice pack and the targets for the locally relevant zone. Species and habitats

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6085 - 2839 - Woodbridge - None 6085 Comment Woodbridge Housing Market Area Woodbridge

Alongside the need to avoid and mitigate potential negative effects on the environment, we recommend that the Council explicitly makes a recommendation that opportunities within developments for biodiversity enhancement should be sought. This would be in accordance with Development Management Policy DM27, which states: All development proposals should: (a) protect the biodiversity and geodiversity value of land and buildings and minimise fragmentation of habitats; (b) maximise opportunities for restoration, enhancement and connection of natural habitats; and (c) incorporate beneficial biodiversity conservation features where appropriate. The NPPF (para. 109) also requires that: "The planning system should contribute and enhance the natural and local environment by:...minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Governments' commitment to halt the overall decline in biodiversity, including establishing coherent ecological networks that are more resilient to current and future pressures." The RSPB consider that there are opportunities through this document and/or supplementary documents to set standards for design and planning of housing developments to incorporate provision of biodiversity enhancements. Measures proposed could include nest boxes/bricks for swifts and bats, wildflower mixes, green roofs, hedgerow management for wildlife and maximising the wildlife potential of SuDS. These measures could also make a contribution to local ecological networks and the conservation of priority and BAP species, such as the swift, house sparrow and hedgehog. The RSPB would be pleased to provide further advice regarding such measures. Additional sources of information With regard our response to question 28 covering green infrastructure, ecological networks and priority habitats and species, we recommend that the Council also have regard to the detailed guidance contained in the following publications. 1St Edmundsbury Green Infrastructure Information Pack: A guide for developers and planners delivering green infrastructure. Available at http://www.westsuffolk.gov.uk/planning/upload/StEdmundsburyGIInformationPack.pdf

requirements in section 9.28)

section 3.15 (p101) and Table 5.1 (p131) on nestbox provision

out twelve principles of good spatial planning, illustrated by case studies

infrastructure and biodiversity See also Annex C Felixstowe Area Action Plan Issues and Options Document Should policies be written to consider proposals for development affecting protected wildlife or geodiversity sites or landscape areas or are they adequately covered by the Core Strategy? Core Strategy policies need to be 'supported by appropriate detail' (see para.6.5) within the AAP to ensure protection/consideration of national and international wildlife sites (SPA/SAC/Ramsar/SSSI) and protected and priority species is commensurate with that given to e.g. the Heritage Coast and AONB. We recommend that a specific policy emphasising the importance of biodiversity and protected sites should be included. Which sites across the Felixstowe Peninsula need to be identified to protect and enhance biodiversity and geodiversity as detailed in Core Strategy policy SP14? All designated wildlife sites should be identified. These should include non-statutory sites such as County Wildlife Sites, as well as those benefitting from statutory protection such as SSSIs and European sites (SPAs, SACs and Ramsar sites). In addition, sites supporting priority habitats and species under the Natural Environment and Rural Communities Act (2006) should be identified. It should be noted that such protection should not be limited to consideration of impacts from development directly on or adjacent to a protected site, but should include indirect impacts such as those of increased recreational pressure. We also note that, for the purposes of HRA, impacts resulting from allocations within the Felixstowe AAP should be considered in-combination with those arising from the Site Allocations and Area Specific Policies document, particularly with regard to potential impacts resulting from recreational pressure on the Deben Estuary SPA and Ramsar site and the Stour and Orwell Estuaries SPA and Ramsar site. How can the Felixstowe Peninsula AAP promote a network of green infrastructure? Please also refer to our answer to Q28 from the Site Allocations and Area Specific Policies, above. Para. 7.1 states that the Felixstowe Peninsula Area Action Plan (AAP) has the opportunity to identify site specific projects such as playing fields, green links, allotments and other facilities which are fundamental to the local communities. We note, as above, that opportunities should also be sought to enhance local ecological networks through the restoration, enhancement, buffering and linking of sites of biodiversity value. We recommend that strong links are made to the outputs of the Haven Gateway Green Infrastructure Strategy. As recommended above, this could be used to generate advice for developers regarding green infrastructure and biodiversity measures targeted at the requirements of the Felixstowe peninsula. Map booklets to accompany Issues and Options Consultation on Site Allocations and Area Specific Policies Saxmundham Housing Market Area Aldeburgh The RSPB are concerned about the proposed allocation of a total of up to 118-185 houses on sites 608 and 982. The sites are in close proximity to the Alde-Ore Estuary SPA, SAC and Ramsar site. Site 608 would provide for 69-108 houses, and is approximately 305m from Alde-Ore Estuary SPA, SAC and Ramsar site. We note that the Sustainability Appraisal (SA) acknowledges that a potentially significant effect on the estuary may result from an increase in recreational pressure and that it indicates that tracks exist linking the site to the estuary

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6085 - 2839 - Woodbridge - None 6085 Comment Woodbridge Housing Market Area Woodbridge

(although there is no official Public Right of Way (PRoW)). The SA therefore notes that mitigation such as Suitable Alternative Natural Green Space (SANG) and/or access monitoring and management is likely to be required. Site 982 would provide for 49-77 houses and is approximately 345m from the Alde-Ore Estuary SPA, SAC and Ramsar site. The SA again acknowledges that a potentially significant effect on the estuary may result from increased recreational pressure and indicates that a PRoW does exist linking this site to the estuary. The SA notes that this development of this site would also require mitigation as above and cumulative assessment with the existing planning consent on an adjacent site. We also note that the site boundary indicated incorporates Aldeburgh Brick Pits geological SSSI, which should be protected. The RSPB are concerned that, as noted in the SA, the allocation of these sites may result in increased recreational pressure on the Alde-Ore Estuary SPA. These proposals will require HRA, with particular attention given to the assessment of the impacts of these sites in-combination with each other, and with other proposed and consented projects in the area. We agree that, should the HRA demonstrate that these sites can be brought forward without adverse effects on the European sites, mitigation is likely to be required to avoid and reduce potential impacts, through signage and interpretation, and in particular through the provision of SANG. We note that the Site Allocations document indicates that site 968 is considered unsuitable due to its proximity to European sites. As site 968 is adjacent to site 982 and near site 608, we query why the rationale for the proposed allocation or rejection of these sites appears inconsistent. We also note that Appendix N of the SHLAA does not identify the proximity of European sites as a constraint for sites 982 and 608 (despite including the Heritage Coast, AONB and CWS designations as constraints). We recommend that rationales and constraints within the Site Allocations document, the SA and the SHLAA are checked to ensure they consistently note proximity to SPAs, SACs or Ramsar sites as these sites benefit from legal protection under the Conservation of Habitats and Species Regulations 2010 (as amended), which is distinct from any protection afforded to other designations. Woodbridge Housing Market Area Para. 5.6 of the Site Allocations and Area Specific Policies document notes that further assessment of cumulative impacts of small scale developments will be required. We consider that sites in the Woodbridge area should be included in such assessments (as part of the HRA of the Site Allocations), due to the potential for these sites in total to result in increases in recreational pressure on the Sandlings SPA, Deben SPA and Ramsar site, Alde-Ore Estuary SPA, SAC and Ramsar site and Staverton Parks and the Thicks SAC. As noted above with regard the Felixstowe area, these assessments will also need to consider relevant sites from other Housing Market Areas, and any other relevant proposed or consented projects. Felixstowe Housing Market Area As noted above in our comments on the Felixstowe Area Action Plan Issues and Options document, we consider that HRA of the Site Allocations should include assessments of the total allocation in the Felixstowe area in order to assess the effects of any increase in recreational pressure on the Deben SPA and Ramsar site. Again, this should include consideration of relevant sites from other Housing Market Areas and any other relevant proposed or consented projects. East Ipswich Housing Market Area As above, we consider that sites in the East Ipswich area (particularly those in , Kesgrave, and Martlesham) should be assessed as part of the HRA of the Site Allocations, for their potential to result in increases in recreational pressure on the Sandlings SPA and Deben SPA and Ramsar site. As also noted above, these assessments will also need to consider relevant sites from other Housing Market Areas, and any other relevant proposed or consented projects, and any other relevant proposed or consented projects (such as those at Martlesham). Conclusion The RSPB recommend that HRA of the final site allocations should have a particular focus on potential impacts of increased recreational pressure on coastal, estuarine and heathland European sites. These impacts need to be assessed at the strategic level (as well as at the level of individual projects) to ensure that potential effects of the total new housing allocation (and those in-combination with other relevant plans or projects) are assessed. We recommend that potential mitigation should also be planned for at the strategic level, through the identification of areas suitable for the creation of new SANG, and of areas which may buffer or link sites of existing nature value (contributing to enhanced ecological networks). This could be pursued by building on and updating previous work from the Haven Gateway Green Infrastructure Strategy and the Green Infrastructure Strategy for the district. We trust that these comments are helpful. If you have any queries about the comments above, please do not hesitate to contact me. Summary: Para. 5.6 of the Site Allocations document notes that further assessment of cumulative impacts of small scale developments will be required. We consider that sites in the Woodbridge area should be included in such assessments, due to the potential for these sites in total to result in increases in recreational pressure on the Sandlings SPA, Deben SPA and Ramsar site, Alde-Ore Estuary SPA, SAC and Ramsar site and Staverton Parks and the Thicks SAC. These assessments will also need to consider relevant sites from other Housing Market Areas, and any other relevant proposed or consented projects.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments: RSPB response to site specific allocations consultation_Redacted.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6255 - 1710 - Woodbridge - None 6255 Comment Woodbridge Housing Market Area Woodbridge

Respondent: Woodbridge Town Council (Mrs Chris Walker) Agent: N/A [1710]

Full Text: Here is the Woodbridge comments on the Local Plan Issues & Options Consultation

* Page 6, paragraph 1.23 - we endorse. * Page 7, paragraph 1.26 - we endorse this and ask for Woodbridge Town Council to be kept informed. * Page 9, paragraph 2.4 - we endorse this and say that Woodbridge Town Council wish to be involved. * Policy AP241 - We wish to say "We know the old AP241 is rarely enforced but if we want it to be possible to take action against any new houseboats in future, we need to ensure that this protection for the River Deben is enshrined in the new Policy on whether new houseboats should not be allowed." * Q1 - Allocation of houses in Market Towns - Woodbridge Town Council agreed to approach 2 (to take a more considered approach) which would allow some discussion about how many houses the Town can reasonable accommodate. * Map booklet - Woodbridge has been allocated 220 - 335 houses table 7 page 23, but the penultimate page, table 2 says the residual requirement is 100 - 200 houses. Woodbridge Town Council wishes to say "we think in the PARISH of Woodbridge it would be difficult to fit in 100 - 200 extra homes without being contrary to Policy SP26 c. * Q5 (page 24) Woodbridge Town Council to respond saying Woodbridge Town Council believes there is a need for smaller properties to buy or rent either privately or through housing associations". * Policy AP28 - we endorse this and do not wish to see the areas protected from development reduced in any way. * 11 Martlesham Employment Sites - Woodbridge Town Council wishes to say "we endorse a Martlesham Heath Business Park but do not want it to be a retail park. We do not wish any further retail units as this will exacerbate the current parking problems". * New yacht harbours and marinas for Woodbridge - page 32 - Woodbridge Town Council is happy for this Policy to be deleted. * Tourism Q18 - Woodbridge Town Council wishes to see strong wording in this Policy to protect the natural environment and safeguard those areas of international significance. Summary: * Map booklet - Woodbridge has been allocated 220 - 335 houses table 7 page 23, but the penultimate page, table 2 says the residual requirement is 100 - 200 houses. Woodbridge Town Council wishes to say "we think in the PARISH of Woodbridge it would be difficult to fit in 100 - 200 extra homes without being contrary to Policy SP26 c.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6265 - 2963 - Woodbridge - None 6265 Comment Woodbridge Housing Market Area Woodbridge

Respondent: Suffolk Coastal District Council (SCDC Agent: N/A Environmental Protection) [2963]

Full Text: LOCAL PLAN ISSUES AND OPTIONS CONSULTATION FELIXSTOWE AREA ACTION PLAN ISSUES AND OPTIONS DOCUMENT AND SITE ALLOCATIONS AND AREA SPECIFIC POLICIES ISSUES AND OPTIONS DOCUMENT

Head of Environmental Services and Port Health - Environmental Protection Comments

Thank you for your consultation regarding the above.

Further to my Memorandum dated 18th February 2015, please find comments regarding air quality matters detailed below.

Due to time constraints I have focussed on those SHLAA sites identified as 'suitable' at this time. Any other sites which come into play in the future, or any 'suitable' sites where different information comes forward, will need further input from Environmental Protection regarding air quality.

For any areas where there are a number of smaller applications (where they are under 0.25ha) the cumulative impacts on traffic flows will need to be taken into account. This also applies to any areas where there are both larger 'suitable' developments and smaller applications in proximity.

I understand that at the next stage of your process, as sites are firmed up, Planning Policy could place a formal recognition on selected individual sites to advise that anyone looking to develop them would need to produce an air quality assessment to accompany any planning application. Air quality assessments should be undertaken using current guidance produced by Environmental Protection UK (EPUK) and the Institute of Air Quality Management (IAQM). I have identified some plots at this stage which would benefit from this, mentioned in the lists below, and would be looking at this in more detail during the next round of your Consultation. I am unsure whether there is also the possibility to place other requirements on certain sites (such as need to produce a green travel plan, to provide car sharing facilities, cycle racks, bus stops etc) in order to prevent worsening of air quality within AQMAs and at any other locations which may be in danger of breaching the air quality objectives in the future should traffic flows increase? I would like to explore this further with you for the next round of Consultation.

Felixstowe Peninsula Area Action Plan

There is an AQMA declared at the Dooley Inn PH, Ferry lane, Felixstowe - close to Dock Gate 2 roundabout. This AQMA has been declared for annual mean levels of nitrogen dioxide due to emissions from and associated with the port of Felixstowe, including traffic on local roads. Any additional traffic produced in the vicinity of Dock gate 2 roundabout and Ferry Lane is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA and this should be considered when determining planning applications.

The Plan discusses a Felixstowe Logistics Park, to be developed by the Port of Felixstowe on sites within the perimeter of the Port. Any sites to be developed by the Port as part of this would need an air quality assessment to determine any impact on nitrogen dioxide levels within the declared Air Quality Management Area (AQMA) at Ferry Lane. My recommendation would be for the Port to make use of Dock Gate 1 over Dock gate 2 for access as this would keep additional traffic away from the AQMA.

Paragraph 6.9 of the Felixstowe Peninsula Area Action Plan discusses the declared AQMA at Ferry Lane, Felixstowe. It states that '... through the continued monitoring of the AQMA, the Council has the ability to ensure that Air Quality within these areas is not to the detriment of the environment or public health.' The continued monitoring of nitrogen dioxide levels within the AQMA allows us to determine what the levels are and whether they are increasing, decreasing or static, it does not in itself actually enable us to ensure that air quality is not detrimental. This is tackled by the statutory Air Quality Action Plan which has been produced for the AQMA - the aim of which is to protect Public Health only. Air quality affecting 'the environment' itself is not covered or tackled by the Local Air Quality Management process but will obviously be positively impacted upon.

Felixstowe and Trimleys * 451g - this borders the A14 and an air quality assessment would be required if this site was developed. A buffer zone alongside the A14 and Candlet Road should be considered in order to protect housing in the new development from being exposed to poor air quality. * 936 - this borders the A14 and an air quality assessment would be required if this site was developed. A buffer zone alongside the A14 and Candlet Road should be considered in order to protect housing in the new development from being exposed to poor air quality. * Sites 936, 383a, 451b, 451c, 451d, 383b, 383f, 451f and 607 within the Trimleys will need to have cumulative traffic effects considered with regard to air quality. Traffic from these sites travelling into Felixstowe using the route via High Street Trimley and not the A14 needs to be calculated and air quality impacts at the junction of High Road West and Garrison Lane will need to be determined. This junction has in recent times become more congested along the Trimley High Road West arm at peak times.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6265 - 2963 - Woodbridge - None 6265 Comment Woodbridge Housing Market Area Woodbridge

* Un-numbered 'unsuitable site', Dock Gate 1/Haven exchange roundabout. I realise that this site is marked as 'unsuitable' anyway but I need to make a specific comment here as if this site were to have housing it could introduce receptors to an area likely to be above the Objectives and become an AQMA. This would be due to the closeness to a heavily trafficked area.

Site Allocations and Area Specific Policies

Q12 asks 'What do you consider to be the main issues which need to be addressed to ensure the Martlesham site remains successful in the future?'. This area, including the A12, has changed considerably in recent times in terms of traffic with the introduction of the retail outlets Next, Pets at Home and M&S Food. Any future decisions regarding sites in this area will need to take account of current traffic flows and provide information on air quality impacts. In recognition of the latest court decision regarding the application for the BT site at Adastral Park, previous comments submitted by the Environmental Protection Team continue to apply, and it is important that any air quality assessments undertaken historically for this application are updated accordingly.

Q29 asks 'should there be further reference to AQMAs ?' Yes I do, and I am happy to work with you to determine what exactly needs to be included. Some initial thoughts are:

* Advising that the spatial planning system has an important role to play in improving air quality and reducing exposure to air pollution, both through the development of local planning policy and the determination of individual planning applications. * Possibly reference to each of the 3 AQMAs in respect of which Towns/Parishes could impact negatively on them through traffic increases. * Declaration of an AQMA does not mean there will be a complete ban on development within or close to that area. Rather it means that greater weight must be given to the consideration of air quality impacts and their mitigation from any developments. * Information regarding the production of Action Plans for each of the AQMAs which have measures included to try and reduce the pollutant of concern. * Statement to the effect that the Area Action Plans and any Neighbourhood Plans produced should be working in conjunction with the official Action Plans for each AQMA.

East of Ipswich Housing Market Sub-Area

Martlesham * 900a and 703 - there appears to be a buffer between the A12 and the housing to the north of this site. Consideration should be given to a similar buffer on this site so that new houses are not exposed to poor air quality. An air assessment would be required if this site was developed with specific reference to impacts on the Woodbridge AQMA.

* Adastral Park - previous comments submitted by the Environmental Protection Team continue to apply. It is important, however, that any air quality assessments undertaken historically for this application are updated accordingly due to the recent changes in traffic flows in this area.

Framlingham Housing Market Sub-Area

Framlingham * As Framlingham is to produce a Neighbourhood Plan there is no detail regarding specific sites here. It will be necessary as part of that plan to ensure that there are no air quality implications from cumulative traffic related to developments in Framlingham.

Saxmundham Housing Market Sub-Area There is an AQMA declared at Long Row on the A12 in Stratford St Andrew. This AQMA has been declared for annual mean levels of nitrogen dioxide due to emissions from traffic on the A12. Any additional traffic produced from housing which would use this area of the A12 is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA and this should be considered when determining planning applications.

Stratford St Andrew * The suggested housing allocation is 0-10 but no SHLAA sites have been submitted or considered. Any sites for housing that would be exiting onto the A12 close to the declared AQMA (even if only for 1 or 2 houses) should consider air quality implications for the AQMA. This would not necessarily be in terms of numbers of vehicles but in terms of any traffic congestion they may cause in or near to the AQMA when entering/exiting onto the A12.

Saxmundham * 1006 and1009 - these sites are likely to use Church Street and its traffic lit junction with High Street, South Entrance and Chantry road. Traffic and congestion on Church Street and at this junction has increased in recent years due to the development of Waitrose, Tesco and other local retail outlets. These applications will need to have cumulative traffic effects considered and air quality impacts at the junction and on Church street will need to be determined.

Leiston

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6265 - 2963 - Woodbridge - None 6265 Comment Woodbridge Housing Market Area Woodbridge

* As Leiston is to produce a Neighbourhood Plan there is no detail regarding specific sites here. It will be necessary as part of that plan to ensure that there are no air quality implications from cumulative traffic related to developments in Leiston as the suggested allocation is 250-500. Any development will need to specifically include air quality impacts from cumulative effects of traffic generated by the construction of Sizewell C Power station once that application has been submitted.

Woodbridge Housing Market Sub-Area There is an AQMA declared within Woodbridge at the traffic lit junction of Lime Kiln Quay Road/Thoroughfare/St John's Street/Melton Hill. This AQMA has been declared for annual mean levels of nitrogen dioxide due to emissions from traffic using the junction. Woodbridge is the nearest shopping centre for a number of nearby Parishes (including those on the Peninsula), and the most likely route for traffic travelling from those parishes to the North and North-East into the shopping area is along the B1438 and through the declared AQMA. Any additional traffic produced by these parishes is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA in Woodbridge and this should be considered when determining planning applications.

Woodbridge * There are no 'suitable' sites for housing located within Woodbridge. There are a number of 'unsuitable sites' and smaller sites (less than0.25 ha) which could send additional traffic through the declared AQMA due to their location (459, 4169, 72361 and 5722). These will therefore have a negative impact on the AQMA and this should be considered. The same would apply for any windfall sites within Woodbridge which could put additional traffic through the AQMA.

Melton * As Melton is producing a Neighbourhood Plan there is no detail regarding specific sites here. Woodbridge is the nearest shopping centre to Melton, and the most likely route for traffic travelling from Melton into the shopping area is along the B1438 and through the declared AQMA. Any additional traffic produced by Melton parish is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA in Woodbridge and this should be considered.

Rendlesham * 350 (includes 676) and 754. Traffic accessing Woodbridge, one of the nearby shopping centres for Rendlesham, will do so along the B1438 and through the declared AQMA. Any additional traffic produced by Rendlesham parish is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA in Woodbridge and this should be considered. Summary: There are no 'suitable' sites for housing located within Woodbridge. There are a number of 'unsuitable sites' and smaller sites (less than0.25 ha) which could send additional traffic through the declared AQMA due to their location (459, 4169, 72361 and 5722). These will therefore have a negative impact on the AQMA and this should be considered. The same would apply for any windfall sites within Woodbridge which could put additional traffic through the AQMA.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6324 - 3384 - Woodbridge - None 6324 Support Woodbridge Housing Market Area Woodbridge

Respondent: The Seckford Foundation [3384] Agent: Rees Pryer Architects LLP (Chris Wilkie) [3386]

Full Text: Site Allocations and Area Specific Policies - Issues and Options Consultation.

On behalf of our Client, The Seckford Foundation, we wish to make representations in response to the Issues and Options Consultation currently in progress. The Seckford Foundation promotes and supports the education and care of the young and elderly members of our community, a role that helps strengthen that community of which we are all a part. The Foundation is responsible for the Queen's House, the Abbey and Woodbridge Schools and also the Seckford Almshouses within the town of Woodbridge. They are also responsible for the Seckford Foundation Free Schools Trust which has three schools. The Foundation owns three particular sites which lie to the south of Road and west of the A12 and these are identified on the attached plan (drawing number 1441 02) as sites A, B and C. These sites have not previously been submitted or included within the Strategic Housing Land Availability Assessment (SHLAA) process. However, together with further neighbouring sites shown within the accompanying 'Red Line' plan (drawing number 1441 01 rev B), the Foundation proposes that the area within the red line should be included within the current consultation process. The land identified within the Red Line plan lies mainly within the Parish of Woodbridge and would provide the only significant opportunity for controlled, residential expansion of Woodbridge west of the A12 with access provided off Grundisburgh Road not the main trunk road. Following the arrival of the new Headmaster a detailed review of education provision and organisation within the School group (Queen's House, The Abbey and Woodbridge School) is being undertaken. The consolidation of early-years provision at the Abbey site has been identified as potentially offering the most advantageous educational outcomes for children. This would allow the present educational use of Queen's House and site to be reallocated to residential, which is supported by the proximity of neighbouring domestic properties. Queen's House and associated land are identified as site D on the attached plan. The Foundation would need to be in a position to raise the funds to enable these educational developments to move forward from disposing of the some of its site. Site D lies within the proposed Woodbridge Neighbourhood Plan Area and this submission will be forwarded to the Woodbridge Town Council for its consideration within the preparation of the Woodbridge Neighbourhood Plan. We trust that this provides sufficient information at this stage for our Client to register an interest in these sites being considered but should you require anything further then please do not hesitate to contact us. Summary: The Foundation owns three particular sites which lie to the south of Grundisburgh Road and west of the A12 and these are identified on the attached plan (drawing 1441 02) as sites A, B and C. These sites have not previously been submitted or included within the Strategic Housing Land Availability Assessment (SHLAA) process. However, together with further neighbouring sites shown within the accompanying 'Red Line' plan (drawing 1441 01 rev B), the Foundation proposes that the area within the red line should be included within the current consultation process. Site D lies within the proposed Woodbridge Neighbourhood Plan Area.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments: 1441 01 Issues and Options Consultation Plan rev B.pdf 1441 02 Seckford Ownership Boundaries issues options plan.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6328 - 2980 - Woodbridge - None 6328 Support Woodbridge Housing Market Area Woodbridge

Respondent: Christchurch Property Company Limited [2980] Agent: Richard Brown MSc (Mr Richard Brown) [3387]

Full Text: SUBMISSIONS IN RESPONSE TO THE SITE ALLOCATIONS AND AREA SPECIFIC POLICIES (ISSUES AND OPTIONS CONSULTATION DOCUMENT)

ON BEHALF OF CHRISTCHURCH LAND & ESTATES LIMITED (HEREINAFTER REFERRED TO AS "CHRISTCHURCH")

IN RESPECT OF LAND NORTH OF WOODS LANE MELTON (SHLAA REFERENCE 750 & 750a)

1. INTRODUCTION

1.1 Christchurch Land & Estates Limited (hereinafter referred to as "Christchurch") are the promoters of the land North of Woods Lane Melton (SHLAA reference 750 & 750a) the land edged red shown on the plan attached as Annexure 1.

1.2 The Local Plan (July 2013) confirms that (4.74)

"Woodbridge is the largest of the market towns...... "

and (4.75)

"The town is an important retail, employment and service centre including the Suffolk Coastal District Council offices. The town also provides higher order leisure and education facilities and, therefore, provides an enhanced role to the surrounding area".

1.3 Strategic Policy SP26 - Woodbridge confirms

"Further significant expansion of Woodbridge and Melton will be sympathetically considered having regard to the local character and key physical thresholds".

Melton is also in close proximity to the site and is regarded as a Key Service Centre by the Local Plan (July 2013).

1.4 Christchurch consider that the Council, in the emerging Site Allocations and Area Specific Policies Document are not addressing the full objective assessment of housing need (FOAN) for the District, which contention is supported by the Pegasus Group Report (February 2015) as attached as Annexure 2, to these submissions.

In paragraph 3.2 of the Pegasus Report, they confirm

"The Inspector who carried out the examination into the Core Strategy crucially highlighted that the Forecasting Mode (EEFM) which informed the Council's Housing Topic Paper evidence base identified a need for 11,000 extra dwellings over the plan period. The Local Authority position is that this figure is the FOAN but that the core strategy (plan) should not provide for this scale of development at the stage of adoption. The Inspector agreed but endorsed the position to have an early review of the Core Strategy to achieve a fully plan-led approach to new development considering a FOAN of 11,000 dwellings 2010 to 2027".

1.5 These submissions contain a detailed response to the Strategic Housing Land Availability Assessment (SHLAA) and the consideration of site suitability in the emerging Plan.

1.6 The sustainability credentials of the site are fully considered by Turley Sustainability in their Report attached as Annexure 3.

1.7 The site is currently the subject of an appeal due to be heard by way of a Public Inquiry on 12th May later this year.

1.8 Christchurch consider that the site constitutes sustainable development being adjacent to the urban edge of Woodbridge and within walking distance of Melton. The development proposals for the site are fully explained in the Bradley Murphy Design Limited Design and Access Statement (November 2013) which supported the previous planning application contained in Annexure 4.

2. FULL OBJECTIVELY ASSESSED NEED

2.1 The NPPF requires that the full, objectively assessed need (FOAN) for market and affordable housing is met in the District. The housing provision set out in the Core Strategy needs to be urgently re-visited in light of more recent household projections and the future evidence base, particularly in light of the findings of the Inspector into the Core Strategy (June 2013).

2.2 In light of this, the Pegasus Report, attached as Annexure 2, has undertaken as assessment on the current FOAN for the District using the most up to date evidence available. The Inspector into the Core Strategy confirmed that, at the time of the examination, the FOAN for the District was actually 11,000 dwellings (688 per annum) over the plan period 2010 to 2027.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6328 - 2980 - Woodbridge - None 6328 Support Woodbridge Housing Market Area Woodbridge

2.3 The need for a higher requirement is supported by the Pegasus assessment of the current FOAN as set out in their Report. Furthermore the SHMA 2012 identified household growth of 14,200 (710 per annum) in the District and when converted to dwellings this gives a total growth of 15,379 (769 per annum). The SHMA, therefore, supports a much higher requirement than the Core Strategy.

2.4 In the light of these findings, there is a clear and compelling need to review the housing requirement commencing with the emerging Site Allocations and Area Specific Policies Issues and Options consultation.

2.5 Furthermore, the District cannot currently demonstrate a five year supply of housing land further emphasising the need for the Local Authority to identify additional sites to rectify this situation and meet the current needs of the District. The Local Authority claim a supply of 4.3 years as at 1st April 2015, however the Pegasus five year supply assessment shows the deficit in supply to be far greater at 1.7 years.

2.6 The Site Allocations and Area Specific Policies Issues and Options document (including the Felixstowe Peninsula AAP) currently makes provision for 4,250 dwellings based on the requirements of the Core Strategy. In light of the Inspectors recommendations into the Core Strategy, the findings of the SHMA, and the Pegasus FOAN assessment, there is a clear and compelling need for the Site Allocations and Area Specific Policies process to provide for a far greater number of dwellings over the same period, a very minimum of at least 6,800 dwellings against a requirement of 11,000.

2.7 It is therefore imperative that this requirement is met through the identification of additional sites such as Woods Lane Melton through the emerging Site Allocations process. In accordance with the settlement hierarchy as set out in the Core Strategy, major centres, market towns and Key Service Centres should be the primary focus for meeting these additional dwelling numbers.

2.8 If the strategy as set out in the Issues and Options is pursued then the emerging Site Allocations process will fail in its duty to deliver the amount of housing required over the plan period in light of the need for an early review of the Core Strategy. The FOAN for the District is much higher than the Core Strategy requirement justifying the urgent need for this review particularly in light of the NPPF guidance that there is a need to boost significantly the supply of housing and to ensure that the full, objectively assessed needs for the market and affordable housing are met in Suffolk Coastal District.

3. NEIGHBOURHOOD PLAN/SETTLEMENT BOUNDARIES

3.1 In principle, no objection is raised to the proposed inclusion of settlement boundaries within the emerging Site Allocation Plan (SAP), subject to any boundaries being drawn to include land allocations to facilitate the required level growth to accommodate the Council's objectively assessed need for housing and employment growth.

3.2 The identification of settlement boundaries should not be used as an arbitrary or artificial means to restrict or limit growth.

3.3 Objection is however raised about the scope of the SAP whereby the Council consider that where the preparation of a Neighbourhood Plan is progressing, the District Council will be led by the Neighbourhood Plan. Such an approach presupposes that the SAP and the Neighbourhood Plan will proceed in parallel. There are no guarantees that this will be the case.

3.4 The concerns about this situation relate to the fact that the Core Strategy does not meet the full and objectively assessed need for housing in the District. As such little weight can be afforded to the Core Strategy policies on this matter. Consequently, the SAP process does not have a proper context from which to make allocations i.e. if prepared in the context of the submitted Core Strategy, the SAP would be likely to significantly under-provide for housing. Also, in such circumstances, the Neighbourhood Plan process is constrained. As stated in paragraph 184 of the Framework,

"neighbourhood plans and orders should not promote less development than set out it the Local Plan or undermine its strategic policies".

3.5 At present therefore, a situation could arise whereby the Neighbourhood Plan is progressed which seeks to restrict development notwithstanding the required strategic policies of the Local Plan. The Council's SAP approach runs this risk which would result in a failed Local Plan strategy with no clear remedy to resolve the situation. The Core Strategy and SAP should lead the process of neighbourhood planning to ensure that strategic policies are properly implemented.

3.6 Having regard to the Council's proposed SAP process, there is a danger that the SAP would cover just those areas not covered by the Neighbourhood Plan Area Designation. This is potentially an unsatisfactory basis to deliver strategic planning policies in situations where Neighbourhood Plans do not plan positively in accordance with the Framework.

4. RESPONSE TO THE STRATEGIC HOUSING LAND AVAILABILITY ASSESSMENT ("SHLAA") REFERENCE 750 & 750a (SITE SUITABILITY)

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6328 - 2980 - Woodbridge - None 6328 Support Woodbridge Housing Market Area Woodbridge

4.1 Notwithstanding comments made in this representation regarding the settlement hierarchy and the relationship of Woodbridge and Melton, the following comments are made in respect of sites 750 and 750a and the Strategic Housing Land Availability Assessment

4.2 The NPPF directs local planning authorities to prepare Strategic Housing Land Availability Assessments (SHLAA) to establish

"realistic assumptions about the availability, suitability and likely economic viability of land to meet the identified need for housing over the plan period" (NPPF, paragraph 159).

4.3 The intention to prepare a Neighbourhood Plan for Melton does not negate the requirement set by national policy for Suffolk Coastal District Council to assess the availability of housing land for the district as a whole. The Local Plan 2013 specifies that there is a need to deliver growth in the Key Service Centres, of which Melton is one. It is therefore implicit that the SHLAA should include Melton sites, regardless of whether it will be for the Site Allocations and Area Specific Policies document or a Neighbourhood Plan to allocate development land.

4.4 Where SHLAA's discount potential sites as unsuitable for development, this should be made clear through evidenced and justified reasons (NPPG Paragraph: 028, Reference ID: 3-028-20140306). Without sight of individual site assessment forms the process of assessing individual sites carried out as part of the Suffolk Coastal SHLAA process is not transparent or accessible. This representation is made in the absence of site assessment information regarding SHAA site 938, other than the conclusions in Table 1 of Appendix D of the SHLAA.

4.5 The SHLAA identifies within Appendix D that the Local Planning Authority has assessed sites 750 and 750a at Woods Lane at Appendix D of the SHLAA concludes as unsuitable because they are

'poorly related to existing settlement'.

4.6 Woods Lane currently forms the northern settlement boundary of Woodbridge (A1152). The northern residential edge of Woodbridge is directly adjacent to sites 750 and 750a separated by Woods Lane. Development of sites 750 and 750a would extend the northern residential edge beyond Woods Lane, incorporating Woods Lane and creating a new physical settlement boundary formed by the A12 bypass on the western boundary of the site and existing substantial woodland vegetation to the north of the site. Although displaying a number of key characteristics of the LCA, the site's close proximity to the northern residential edge of Woodbridge, Woods Lane, and the A12 Bypass impinges and dilutes the rural setting. A masterplan showing how the site can be sensitively developed is presently subject to a planning appeal (application ref. DC/14/0991/OUT) and expert landscape evidence on behalf of Christchurch supports the position that the site can be sustainably developed.

4.7 The development of the site can address the currently weak urban edge associated with the northern settlement boundary, creating a designed interface between the existing settlement and new proposals on Woods Lane. Development could also provide a new rural interface and settlement edge to the north and west, utilising existing physical boundaries. Built form within the sites could positively address this new settlement edge, facing out towards the wider rural setting and supplemented with new green infrastructure across the development, in keeping with the wider landscape characteristics and enhancing the landscape and biodiversity value of the site.

4.8 The site is a sustainable location for residential development with access to schools and facilities located in Melton to the east and Woodbridge to the south, making walking and cycling a convenient and sustainable way of accessing local facilities. Further assessment of the sustainability of the site is considered elsewhere in this representation.

4.9 As discussed elsewhere in this representation, no physical limitation exist that would prevent the sites from being suitable for residential development and the impacts of the development have been assessed by the applicant as part of planning application DC/14/0991/OUT and subsequent pending appeal. There is confidence that there are no legal or ownership problems, thus the sites are available. We therefore consider that, were the sites to have to considered as part of the Site Allocations document, then they should have been assessed to be suitable sites.

5. THE SUSTAINABILITY OF THE SITE

5.1 Christchurch have commissioned Turley Sustainability to carry out a detailed Sustainability Appraisal of the land north of North of Woods Lane Melton (February 2015). The Report is attached as Annexure 3.

5.2 The Sustainability Appraisal clearly confirms that this location is a highly sustainable location for residential development, abutting the main area of Woodbridge and in close proximity to Melton.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6328 - 2980 - Woodbridge - None 6328 Support Woodbridge Housing Market Area Woodbridge

6. CONCLUSIONS

6.1 It is considered by Christchurch for the reasons outlined in this submission that the land North of Woods Lane Melton should be allocated in the emerging Plan, as it constitutes sustainable development in accordance with paragraph 14 of the National Planning Policy Framework.

6.2 By omitting the site, it is considered that the Emerging Plan fails to significantly boost housing supply and fails to meet the objectively assessed housing needs of the District (paragraphs 14 and 47 of the National Planning Policy Framework).

6.3 It is submitted, therefore, that the site should be a preferred option for housing being an appropriate urban extension to Woodbridge, that the site is a sustainable and appropriate growth option for the town.

Annexures

1. Site plan

2. Pegasus Group Report relating to the Council Full Objectively Assessed Need and Housing Land Strategy (February 2015)

3. Turley Sustainability Appraisal (February 2015)

4. Bradley Murphy Design Limited Design and Access Statement (November 2013) Summary: 750 & 750a:The land North of Woods Lane Melton should be allocated in the emerging Plan, as it constitutes sustainable development in accordance with paragraph 14 of the National Planning Policy Framework.

By omitting the site, it is considered that the Emerging Plan fails to significantly boost housing supply and fails to meet the objectively assessed housing needs of the District (paragraphs 14 and 47 of the National Planning Policy Framework).

The site should be a preferred option for housing being an appropriate urban extension to Woodbridge, that the site is a sustainable and appropriate growth option for the town.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments: BMD.213.RP.001A DAS_low.pdf BMD.DAS_p12 Woods Lane Site Location.pdf BIR 4293 OANPaper ISSUE 260215.pdf Representations to Proposed Site Allocations, Land off Woods Lane Melton....pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6329 - 2980 - Woodbridge - None 6329 Support Woodbridge Housing Market Area Woodbridge

Respondent: Christchurch Property Company Limited [2980] Agent: Richard Brown MSc (Mr Richard Brown) [3387]

Full Text: SUBMISSIONS IN RESPONSE TO THE SITE ALLOCATIONS AND AREA SPECIFIC POLICIES (ISSUES AND OPTIONS CONSULTATION DOCUMENT)

ON BEHALF OF CHRISTCHURCH LAND & ESTATES LIMITED (HEREINAFTER REFERRED TO AS "CHRISTCHURCH")

IN RESPECT OF LAND AT YARMOUTH ROAD MELTON

27TH FEBRUARY 2015

1. INTRODUCTION

1.1 Christchurch Land & Estates Limited (hereinafter referred to as "Christchurch") are the promoters of the land at Yarmouth Road Melton the land edged red shown on the plan attached as Annexure 1.

1.2 The Adopted Local Plan (July 2013) confirms that Melton is a Key Service Centre.

1.3 Strategic Policy SP27 - Key and Local Service Centres confirms

"(d) Enable organic development to occur in respect of settlements where opportunities within defined physical limits are severely limited.....".

1.4 Christchurch consider that the Council, in the emerging Site Allocations and Area Specific Policies Document are not addressing the full objective assessment of housing need (FOAN) for the District, which contention is supported by the Pegasus Group Report (February 2015) as attached as Annexure 3, to these submissions.

In paragraph 3.2 of the Pegasus Report, they confirm

"The Inspector who carried out the examination into the Core Strategy crucially highlighted that the East of England Forecasting Mode (EEFM) which informed the Council's Housing Topic Paper evidence base identified a need for 11,000 extra dwellings over the plan period. The Local Authority position is that this figure is the FOAN but that the core strategy (plan) should not provide for this scale of development at the stage of adoption. The Inspector agreed but endorsed the position to have an early review of the Core Strategy to achieve a fully plan-led approach to new development considering a FOAN of 11,000 dwellings 2010 to 2027".

1.5 The sustainability credentials of the site are fully considered by Turley Sustainability in their Report attached as Annexure 4.

1.6 Christchurch consider that the site constitutes sustainable development.

2. FULL OBJECTIVELY ASSESSED NEED

2.1 The NPPF requires that the full, objectively assessed need (FOAN) for market and affordable housing is met in the District. The housing provision set out in the Core Strategy needs to be urgently re-visited in light of more recent household projections and the future evidence base, particularly in light of the findings of the Inspector into the Core Strategy (June 2013).

2.2 In light of this, the Pegasus Report, attached as Annexure 3, has undertaken as assessment on the current FOAN for the District using the most up to date evidence available. The Inspector into the Core Strategy confirmed that, at the time of the examination, the FOAN for the District was actually 11,000 dwellings (688 per annum) over the plan period 2010 to 2027.

2.3 The need for a higher requirement is supported by the Pegasus assessment of the current FOAN as set out in their Report. Furthermore the SHMA 2012 identified household growth of 14,200 (710 per annum) in the District and when converted to dwellings this gives a total growth of 15,379 (769 per annum). The SHMA, therefore, supports a much higher requirement than the Core Strategy.

2.4 In the light of these findings, there is a clear and compelling need to review the housing requirement commencing with the emerging Site Allocations and Area Specific Policies Issues and Options consultation.

2.5 Furthermore, the District cannot currently demonstrate a five year supply of housing land further emphasising the need for the Local Authority to identify additional sites to rectify this situation and meet the current needs of the District. The Local Authority claim a supply of 4.3 years as at 1st April 2015, however the Pegasus five year supply assessment

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6329 - 2980 - Woodbridge - None 6329 Support Woodbridge Housing Market Area Woodbridge

shows the deficit in supply to be far greater at 1.7 years.

2.6 The Site Allocations and Area Specific Policies Issues and Options document (including the Felixstowe Peninsula AAP) currently makes provision for 4,250 dwellings based on the requirements of the Core Strategy. In light of the Inspectors recommendations into the Core Strategy, the findings of the SHMA, and the Pegasus FOAN assessment, there is a clear and compelling need for the Site Allocations and Area Specific Policies process to provide for a far greater number of dwellings over the same period, a very minimum of at least 6,800 dwellings against a requirement of 11,000.

2.7 It is therefore imperative that this requirement is met through the identification of additional sites such as Yarmouth Road Melton through the emerging Site Allocations process. In accordance with the settlement hierarchy as set out in the Core Strategy, major centres and market towns should be the primary focus for meeting these additional dwelling numbers.

2.8 If the strategy as set out in the Issues and Options is pursued then the emerging Site Allocations process will fail in its duty to deliver the amount of housing required over the plan period in light of the need for an early review of the Core Strategy. The FOAN for the District is much higher than the Core Strategy requirement justifying the urgent need for this review particularly in light of the NPPF guidance that there is a need to boost significantly the supply of housing and to ensure that the full, objectively assessed needs for the market and affordable housing are met in Suffolk Coastal District.

3. NEIGHBOURHOOD PLAN/SETTLEMENT BOUNDARIES

3.1 In principle, no objection is raised to the proposed inclusion of settlement boundaries within the Site Allocation Plan (SAP), subject to any boundaries being drawn to include land allocations to facilitate the required level growth to accommodate the Council's objectively assessed need for housing and employment growth.

3.2 The identification of settlement boundaries should not be used as an arbitrary or artificial means to restrict or limit growth.

3.3 Objection is however raised about the scope of the SAP whereby the Council consider that where the preparation of a Neighbourhood Plan is progressing, the District Council will be led by the Neighbourhood Plan. Such an approach presupposes that the SAP and Neighbourhood Plans proceed in parallel. There are no guarantees that this will be the case.

3.4 The concerns about this situation relate to the fact that the Local Plan 2013 does not meet the full and objectively assessed need for housing in the District. As such little weight can be afforded to the Local Plan policies on this matter. Consequently, the SAP process does not have a proper context from which to make allocations i.e. if prepared in the context of the Local Plan, the SAP would be likely to significantly under-provide for housing. Also, in such circumstances, the Neighbourhood Plan process is constrained. As stated in paragraph 184 of the Framework,

"neighbourhood plans and orders should not promote less development than set out it the Local Plan or undermine its strategic policies".

3.5 At present therefore, a situation could arise whereby a Neighbourhood Plan is progressed which seeks to restrict development notwithstanding the required strategic policies of the Local Plan. The Council's SAP approach runs this risk which would result in a failed Local Plan strategy with no clear remedy to resolve the situation. The Local Plan and SAP should lead the process of neighbourhood planning to ensure that strategic policies are properly implemented.

3.6 Having regard to the Council's proposed SAP process, there is a danger that the SAP would cover just those areas not covered by Neighbourhood Plan Area Designations. This is potentially an unsatisfactory basis to deliver strategic planning policies in situations where Neighbourhood Plans do not plan positively in accordance with the Framework.

4. RESPONSE TO THE STRATEGIC HOUSING LAND AVAILABILITY ASSESSMENT ("SHLAA") (SITE SUITABILITY)

4.1 Christchurch submit the land at Yarmouth Road, Melton for consideration as a strategic location for housing growth. A site location plan showing the land is attached as Annexure 1. The site is not currently identified in the SHLAA.

4.2 Notwithstanding comments made in this representation regarding the allocation of sites through the Neighbourhood Plan process, it is our view that this site should be allocated for residential use as it constitutes sustainable development as defined by paragraph 14 of the National Planning Policy Framework. The site, in our opinion, provides the following Opportunities:

* Provide housing in an attractive landscape setting (reference the illustrative masterplan attached as Annexure 2); * Create a new community, which is well related to existing residential clusters; * Enhance the integration of adjacent land uses;

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6329 - 2980 - Woodbridge - None 6329 Support Woodbridge Housing Market Area Woodbridge

* Enhance the existing vegetation pattern by retaining and reinforcing existing boundary trees and hedges

4.3 Christchurch will shortly submit a planning application for development as shown on the illustrative masterplan. The planning application will be supported by a Transport Assessment prepared by WYG who, in their Summary and Conclusions (set out below), demonstrate that the site clearly constitutes sustainable development and should be allocated in the emerging Plan.

"8.1 WYG Transport has been appointed by the Christchurch Land & Estates Ltd (the 'Applicant') to prepare a Transport Assessment (TA) to support an outline planning application for the proposed development of land at Yarmouth Road in Melton, Suffolk (the 'Site'). 8.2 The Site is located north of the village of Melton, west of the B1438 Yarmouth Road and east of the A12 Grove Road. Furthermore, the Site is situated at approximately 17km to the north-east of Ipswich in the Suffolk Coastal District of the county.

8.3 The applicant proposed a development of 138 residential units, 50 assisted living units and a 60 bed care home, together with associated works to the site access and surrounding environs. The proposed development will also incorporate modifications to the pedestrian network with a new uncontrolled pedestrian crossing on Yarmouth Road.

8.4 Opportunities for non car based travel to and from the site, by bus, train, bicycle or on foot has been considered. The surrounding area of the Site is served by public transport with a regular frequency of buses servicing the locality. New bus stops will be located at the site access on Yarmouth Road to minimise walking distances to public transport.

8.5 In addition, it is proposed to provide new sections of footway and an uncontrolled pedestrian crossing facility that link into existing footways on Yarmouth Road. This will enable pedestrians from the development to walk into Melton and the numerous services that are available there. Melton Railway Station is located 1.2km south of the Site and can be reached on foot in approximately 15 minutes. Covered cycle parking is also available at the Station.

8.6 Car and cycle parking provision for the site will be broadly in line with Policy DM19 of SCDC's Development Management Policies.

8.7 Car parking provision for the Site will be broadly in line with the SCC 'Suffolk Guidance for Parking 2014' Supplementary Planning Guidance (SPG) (November 2014), which provides policy advice to those considering planning applications for new developments and sets out 'advisory levels of parking' for particularly types of developments. 8.8 The TRICS database was used to quantify the additional generated trips. The calculated traffic arising from the proposed development is considered to represent a robust assessment.

8.9 The local highway junction capacity has been considered for the following scenarios providing an assessment of both with development and without development related traffic. This has enabled a comparison to be made between the impacts of the development:

* Existing surveyed (2014) Traffic Flows; * Total Forecast Base (2020) Traffic Flows (without development traffic); and * Total Forecast (2020) Traffic Flows (with development traffic).

8.10 The capacity analysis results illustrate the proposed impact the development will have on the surrounding network, in junction capacity terms and queuing capacity, respectively. The impact on the development has been shown to be very minor. The capacity analysis concluded that all junctions tested currently operate well within capacity with minor queuing, and will continue to do so with the Total Forecast (2020) Traffic Flows with development traffic.

8.11 Through the course of the preparation of the Transport Assessment, WYG has demonstrated that the proposed development at Yarmouth Road is consistent with sustainable objectives of national transport planning policy guidance and with those of Suffolk Coastal's Core Strategy.

8.12 Numerous facilities are located within walking distance of the Site and further facilities are located via the regular bus service running adjacent to the Site.

8.13 No highway capacity issues have been raised in this report and a robust assessment has demonstrated that development traffic will have very little impact on existing junctions in the vicinity of the Site.

8.14 It is concluded that the proposed development at Yarmouth Road will present no material impact on the local highway network, and is therefore acceptable on highways and transport terms".

5. THE SUSTAINABILITY OF THE SITE

5.1 Christchurch have commissioned Turley Sustainability to carry out a Sustainability Appraisal of the land at Yarmouth Road Melton (February 2015). The Report is attached as Annexure 4.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6329 - 2980 - Woodbridge - None 6329 Support Woodbridge Housing Market Area Woodbridge

5.2 The Sustainability Appraisal clearly confirms that this location is a sustainable location for residential development.

5.3 Table 3.2 from the WYG Transport Assessment is reproduced below and highlights the accessibility of the site to the local services and facilities.

Table 3.2 Accessible Public Services and Facilities

Service / Facility Within 800m of the Site Within 2km of the Site Accessible by Public Transport Community Buildings (e.g. Woodbridge Police Station) No Yes Yes Education and Library Services Primary School (Woodbridge Primary) No Yes Yes Secondary School (Farlingaye High School) No No Yes Library Services (Woodbridge Library) No No Yes Leisure and Sports Facilities (Ufford Park Golf Club) Yes Yes Yes Health and Social Care Services GP Services (Dr Taylor and Partners) No Yes Yes Pharmacy (Boots) No Yes Yes Dentist (ADP Woodbridge) No Yes Yes Food and Fresh Groceries (Country Fayre) Yes Yes Yes Nursery / Crèche Facilities (Melton Day Nursery ) Yes Yes Yes Communication Services (Woodbridge Post Office) No No Yes Bank and Cash Machines (ATM, The Street, Melton) Yes Yes Yes Public House (The Coach and Horses) Yes Yes Yes Places of Worship (Saint Andrews, Melton) Yes Yes Yes

6. CONCLUSIONS

6.1 It is considered by Christchurch for the reasons outlined in this submission that the land at Yarmouth Road Melton should be allocated in the emerging Plan, as it constitutes sustainable development in accordance with paragraph 14 of the National Planning Policy Framework.

6.2 By omitting the site, it is considered that the emerging Plan fails to significantly boost housing supply and fails to meet the objectively assessed housing needs of the District (paragraphs 14 and 47 of the National Planning Policy Framework).

6.3 It is submitted, therefore, that the site should be a preferred option for housing being a sustainable and appropriate option for the village of Melton, which is constrained by Conservation Area designations and so on.

Annexures

1. Site plan

2. Illustrative masterplan

3. Pegasus Group Report relating to the Council Full Objectively Assessed Need and Housing Land Strategy (February 2015)

4. Turley Sustainability Appraisal (February 2015) Summary: The land at Yarmouth Road Melton should be allocated in the emerging Plan, as it constitutes sustainable development in accordance with paragraph 14 of the National Planning Policy Framework.

By omitting the site, it is considered that the emerging Plan fails to significantly boost housing supply and fails to meet the objectively assessed housing needs of the District (paragraphs 14 and 47 of the National Planning Policy Framework).

It is submitted that the site should be a preferred option for housing being a sustainable and appropriate option for the village of Melton, which is constrained by Conservation Area designations etc.

Change to Plan N/A

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified N/A

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

S - 6329 - 2980 - Woodbridge - None 6329 Support Woodbridge Housing Market Area Woodbridge

YOR.2251.001 Fig 1 Yarmouth Road Site Location Plan 170714 - sfs.pdf BIR 4293 OANPaper ISSUE 260215.pdf Representations to Site Allocations - Land at Yarmouth RoadFINAL.PDF YOR.2251.014.revB Fig 2 Illustrative Masterplan 030914.pdf

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6393 - 2655 - Woodbridge - None 6393 Comment Woodbridge Housing Market Area Woodbridge

Respondent: Member of Parliament (MP) (Rt. Hon Therese Agent: N/A Coffey MP) [2655]

Full Text: Thank you for the opportunity to comment on the site allocations and area specific policies for the local plan. I think it is a welcome step to encourage all the public to participate in this early stage of the process. I only usually intervene on strategic issues and policies on planning.

While I have detailed my comments on some individual areas below, I have three particular issues to discuss - i) the imbalance of housing allocations around the area with the vast amount of development inserted east of the A12, the side of Suffolk that has the AONB and nearly all the SSSls; iii) the absence of nominated sites in Framlingham and Leiston; iii) building on main roads and the absence of infrastructure, particularly roads, for major and cumulative developments with the risk of significant congestion and longer journey times as well as community facilities.

Allocation of housing across the district

The vast majority of the proposed housing lies east of the A12 and to the south of the district. This continues to move the centre of gravity south east which runs the risk of excluding significant parts of our area of new housing for local people and also the lack of infrastructure (either new or upgraded). There appears to be a surprising disparity between settlements on where is deemed appropriate for further development and where is not. For example, no further housing is recommended for Wickham Market while Wenhaston, lower down the settlement hierarchy, has been recommended for more housing despite having just had an application for 26 new homes approved (higher than the Local Plan allocation of 5-15). Separately, Saxmundham has been recommended for further housing after a significant amount already built and under construction. I do not object specifically to that but will make the point later about infrastructure. There is little difference between Wickham Market, Saxmundham and Framlingham apart from the railway station. It has been suggested that Wickham Market has already had some housing so need not have any more and Framlingham has been allocated a small amount. That is in contrast to Leiston which has been allocated up to 500 houses, though with no additional infrastructure. The experience elsewhere does not bear that out. While it makes sense to allow for housing in villages and parishes as well as market towns but in a sensible proportion that does not dwarf existing villages. Therefore, I suggest that villages that have already had housing approved in the last two years should not have further sites specifically designated but allow for windfall, within the existing village envelope and not on main roads (like the A12 in Yoxford or A1120 in Peasenhall or the High Road in the Trimleys or the A144). It also should be on the same side of the main road as the local facilities - which would rule out nominated sites specifically in Yoxford and Woodbridge. We should not repeat the mistakes of the past. Another guiding principle should be that new housing is as close as possible to existing facilities. There is development planned on the opposite side of the main road to key facilities in some areas, which would significantly shift the centre of gravity and mean people having to cross busy roads to get to the centre. Shifting the centre of gravity of further development away from shops and facilities in towns, as may be the case in Saxmundham, is a retrograde step for enhancing the sense of community. The council must counter the risk of our small market towns becoming car-based, seeking shopping, leisure and sporting activities away from the town.

I strongly support the protection of green gaps, acting as strategic barriers between settlements.

There is an absence of nominated sites in Leiston and Framlingham. It has been suggested that this is due to emerging town plans but they should not have been absented from this consultation.

Finally, the absence of infrastructure. There is already huge pressure on various parts of the A12 and there is no indication of what infrastructure additions or upgrades are being proposed to accommodate such significant increases. In more specific terms,

i) Martlesham area with 2000 houses, adding to the increasing retail presence on the Martlesham Heath industrial estate. The latter is already leading to significant increases in traffic, coupled with further housing already under construction in Martlesham. Significant improvements need to be made to the A12 at several junctions. ii) Woods Lane roundabout and the A1152. There are already at least 15,000 traffic movements per day at the Melton railway crossing (sourced from Network Rail three years ago). Without substantial improvements to roads here, the additional housing suggested in Melton, Eyke and Rendlesham will bring even greater traffic movement pressure on the round about, the railway crossing and the traffic lights on the junction of the A1152/B1438. iii) Given the council's full support for the 4 villages bypass, it is surprising that no housing has been considered for this area as bypasses usually lead to significant increases in housing. Meanwhile, up to 500 houses are being proposed for Leisten but with no road improvements and no support for the potential D2 route being suggested in conjunction with Sizewell C. iv) In Saxmundham, a substantial number of new housing has already been built. While there has been minor modification of the traffic lights in the centre of the town, there has been no improvements planned to help traffic in and through the town. v) Woodbridge site at the football ground -addressing the congestion and the replacement of sporting facilities within the town area. vi) Local community infrastructure will need significant improvement - pace Rendlesham, Saxmundham, Leisten, the Trimleys and the new development at Martlesham. On local sites, I have commented by exception and no comment is not a sign of endorsement.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6393 - 2655 - Woodbridge - None 6393 Comment Woodbridge Housing Market Area Woodbridge

Woodbridge Housing Area

Campsea Ashe Site 557 is a very unusual place to add more housing especially if there is going to be work on the track for Sizewell C. I agree with 745 and 990 being unsuitable SHLAA sites. They are far too large and inappropriate. Eyke Agree that 991 and OPP7 are unsuitable sites. 991 looks to double size of village whereas Opp7 suggests substantial new housing along A-road which is unsuitable. Hollesley Agree that 825 is unsuitable - losing a significant amount of green field opposite school. Orford Agree that 494/484 & 976 is unsuitable. Surprised some sites proposed with sea levels. Tunstall Disagree that 786, 597 and 730 would all be suitable as a whole as seems to double the size of the village which is unnecessary over-development. Wickham Market Would support 7761 and 776i as it is a significant market town. Woodbridge Agree that sites 937 and 453 are unsuitable due to being west of the A12. 839,750,750a, 974 unsuitable due to pressure on roundabout.

Framlingham Housing Area

Bramfield Agree that 493 is unsuitable as it is too far away from the centre. Peasenhall Agree with 832 being unsuitable as outside the envelope and inappropriate. Wenhaston The village has already had a significant amount of development therefore I don't see the need for any further sites to be added. Strongly oppose any greenfield sites. Yoxford Strongly oppose accepted SHLAA sites 642b and 794. They are both opposite or adjacent to existing housing but involves crossing a main road to get to existing village facilities.

Saxmundham Housing Area

Aldeburgh Agree with unsuitable SHLAA sites in first map. Should continue to look for windfall sites. Strongly agree that 768 shouldn't be brought forward. Benhall Agree that 411b and 411c should not be brought forward. They would dwarf the village and would constitute overdevelopment. Blythburgh Disagree with 4UCB being brought forward as junction already very difficult and wouldn't cope. Darsham Agree that 378 and 967 are unsuitable as are considerably out of the village. Strongly disagree with 794 as it is too close to the main road and a strategic error. Dunwich Agree that 713 is unsuitable as is too far away from the village centre. Knodishall Agree that 506 which would dwarf the village, 579 which would significantly reduce the gap to Aldringham and 971 which would bring an unwarranted urban feel to that side of the village are unsuitable. Little Glemham 625 would put particular pressure on A12 which would require substantial highway change if it were to go ahead. Saxmundham Strongly agree that the non-hatched sites are unsuitable. Of the sites that have been endorsed 1006 and 1009, there is a risk of this development being too far away from the high street shift the centre of gravity. If this was to go ahead then there should be consideration for a relief road from the North entrance to the B1119. Snape Agree that 758 is unsuitable as too far out of the centre of the village. Westleton Agree with unsuitability of sites. Strongly oppose any development on 327 and 935.

Felixstowe Housing Area/Area Action Plan

Waldrlngfield Support 961 being a SHLAA unsuitable site. We need to protect this as a local gap. Bucklesham Most sites are too big and too far away from village centre. Kirton It is my understanding the Falkenham Road site has been backed in a local consultation session run by the Parish Council. Concerned about over development if all the other sites were approved. Trimley St Martin Agree that 920 and 889 are completely unsuitable. Trimley St Mary Concern that the current road network could cope with significant development on 383F. Agree with unsuitability of 383,c,d,e & 451e as too far away from centre. Summary: Woodbridge Agree that sites 937 and 453 are unsuitable due to being west of the A12. 839,750,750a, 974 unsuitable due to pressure on roundabout.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6549 - 2581 - Woodbridge - None 6549 Comment Woodbridge Housing Market Area Woodbridge

Respondent: Suffolk County Council (Mr Robert Feakes) [2581] Agent: N/A

Full Text: Site Allocations Document - Issues and Options Consultation Suffolk County Council Response

1. Introduction

1.1 Thank you for consulting Suffolk County Council on the above document. This response aims to set out the issues which our two authorities will need to resolve as this document is brought forwards towards adoption, rather than seeking to resolve issues now. Comments are set out in relation to Suffolk County Council service responsibilities and policy objectives; matters on which our authorities need to cooperate.

2. Air Quality and Noise Assessment

2.1 There are a number of locations within Martlesham that are adjacent to the A12, which include 710, 479, 721, 644, 693, 517, 430. The bunding adjacent to the A12 at sites 517/430, provided initially to protect Martlesham Heath residents from mineral working noise, should be retained as it has been designed (it is high enough) to provide a good level of protection from road traffic noise for any new dwellings behind it.

2.2 Developments adjacent to the A1214 through Kesgrave, eg. 774a and also the A1156 Felixstowe Road would all be subject to traffic noise as these routes carry significant volumes of traffic. Also locations at Ufford adjacent to the A12 to include 586, 838a and 838b and at Woodbridge for plots 937, 900a and 703. There a number of IAs along the A12 at Martlesham Heath and Woodbridge and should additional residential receptors be built adjacent to the route, these would be extended, potentially requiring this authority to fund mitigation provision. Similarly for other locations adjacent the A12 at Darsham, Kelsale, Little Glemham, Saxmundham and Yoxford.

2.3 There is an Air Quality Management Area (AQMA) in Woodbridge at the Lime Kiln Quay Road/Melton Hill junction. This should be viewed as a constraint and taken into account looking at the impacts of traffic growth through Woodbridge.

3. Archaeology

3.1 It is suggested that an informative section is considered which highlights the archaeology of the area and its management in the development process. The following is provided as an initial suggestion:

Suffolk Coastal has a rich, diverse and dense archaeological landscape with the river valleys, in particular, topographically favourable for early occupation of all periods. The distinctive character of the historic environment in the District includes upstanding coastal archaeology of all dates, prehistoric burial tumuli on the open heathlands around the eastern margins of Ipswich and on the Felixstowe peninsula, the remains of Roman small towns at Felixstowe and Wenhaston, the internationally important Anglo-Saxon burial ground at Sutton Hoo, numerous medieval historic towns and villages with both above and below ground heritage assets, for example Woodbridge and Aldeburgh, and the strategically placed, Napoleonic Martello towers. These are among over 7,300 sites of archaeological interest currently recorded in the Suffolk Historic Environment Record for Suffolk Coastal. Suffolk County Council Archaeological Service routinely advises that there should be early consultation of the Historic Environment Record and assessment of the archaeological potential of proposed sites at an appropriate stage in the design of new developments, in order that the requirements of the NPPF are met with regards to designated and non-designated heritage assets.

3.2 Suffolk County Council's archaeologists would be pleased to liaise with the District Council on wording, and provide more detailed information on archaeology on the area if required. To briefly clarify two points within the documents, heritage assets include Scheduled Monuments (paragraph 5.17) and non-designated heritage assets also include archaeological sites (paragraph 5.19).

3.3 For those sites which have not previously been commented on through the Strategic Housing Land Availability Assessment process, comments on likely archaeological assessment requirements are set out as an appendix to this letter.

4. Education (including Early Years)

4.1 In order to meet the requirements of Paragraph 72 of the National Planning Policy Framework, and to support community wellbeing (as described in paragraph 3.15 of the Core Strategy), this plan must ensure the delivery of sufficient education places to meet demand arising from housing growth. Government policy is that new provision made necessary as a result of demand arising from new housing should be funded from developer contributions; the County Council can only access funding to provide new places made necessary as a result of population growth arising from the existing housing stock.

4.2 In respect of the statutory requirement to provide 15 hours per week of early education for 3 - 4 year olds (and eligible 2 year olds), there is clearly a variation in levels of existing capacity across the District, which will impact on what additional provision is needed. For many of the parishes, the allocations indicated will not necessitate the provision of new Early Years settings, but contributions are still likely to be sought in many instances.

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6549 - 2581 - Woodbridge - None 6549 Comment Woodbridge Housing Market Area Woodbridge

4.3 Those settlements with more significant development (Leiston, Saxmundham, Woodbridge, Aldeburgh and Framlingham) are more likely to require contributions towards additional provision. The County Council does not normally seek allocations of land for additional provision, given that provision is largely made through the private, voluntary and independent sector providers. However, should any new primary schools be required, it is expected that early education provision will be co-located with the new primary schools.

4.4 In terms of primary education, the distribution of housing is a key determining factor as regards what additional provision is needed. Our authorities also need to consider the long term resilience of the primary school system, and consider the likelihood that the forthcoming review of the Suffolk Core Strategy will result in the allocation of additional dwellings to the rural areas.

4.5 For much of the District, specifically in the rural areas, existing schools are likely to be able to absorb the low levels of growth proposed. However, this capacity cannot be considered as 'available' to absorb growth proposed in the market towns. Paragraph 38 of the NPPF emphasises the priority which should be given to locating key facilities in close proximity to housing. Assuming that children can attend schools a long distance from their homes will increase the need to travel, reduce the proportion of journeys undertaken by sustainable modes and place an ongoing cost on the public purse for home to school transport.

4.6 It appears that the level of growth proposed in Framlingham (75-150 dwellings) and Leiston (250-500 dwellings) can be accommodated in local schools on their existing sites, though developer contributions will be required in Framlingham at primary level and may be required in Leiston if development is at the larger end of the scale.

4.7 It also appears that the level of growth proposed in Saxmundham can be accommodated at local schools, albeit in a limited capacity. However, if further iterations of this document bring forward additional allocations in Saxmundham, it is unlikely that this growth could be accommodated at Saxmundham Primary School. Equally, the 'neighbouring' schools cannot accept further pupils from growth in Saxmundham (beyond that already agreed). Therefore, any further growth at Saxmundham will need to be accompanied with detailed consideration of how growth can be managed at primary school level. It may necessitate the development of a new primary school, which will necessarily be funded through Section 106 agreements.

4.8 Existing schools cannot accept growth indefinitely. If there is significant growth at Framlingham and Saxmundham, beyond that envisaged by this document, it is likely to be appropriate for the Local Plan to identify new school sites in these towns. This will help to minimise the risk of sending children to schools outside their own communities.

4.9 In regard to Woodbridge, it is important to better understand exactly where the housing is going to be. In considering current forecasts it appears that spaces would be available at Kyson and Melton in particular which, according to the SHLAA sites map, would be the local schools for the majority of the proposed housing. Significant housing growth within the catchments of St Marys and Woodbridge Primaries may prove problematic.

4.10 Development of 75-150 dwellings in Aldeburgh is expected to generate between 19 and 38 additional pupils (based on 25 pupils per 100 dwellings). Aldeburgh Primary School is consistently at capacity for the forecast period, and the school cannot be expanded on its current site. Whilst there is capacity at Leiston and Coldfair Green Primary Schools, sending pupils from Aldeburgh to these schools is undesirable and would need to be considered alongside growth in these parishes. If the District Council does intend to allocate housing at Aldeburgh, this will need to be the subject of early discussion.

4.11 Rendlesham Primary School has recently been expanded to 315 - places. Further expansion; which may be necessary to cope with 75-100 dwellings (19-25 pupils); would be challenging.

4.12 At secondary level, the allocations envisaged by this consultation document are likely to create additional demand at:

- Thomas Mills High School, - Saxmundham Free School, - Stradbroke High School - Debenham High School - Halesworth High School - Bungay High School - Alde Valley School - Farlingaye High School - Kesgrave High School

4.13 The scale of development proposed is not envisaged as being problematic at secondary level, with the exception of growth within the Farlingaye catchment. It appears that allocated growth within the Farlingaye catchment could be around 345 dwellings (or be fewer), meaning up to 62 pupils aged 11-16 and 14 pupils aged 16+. Farlingaye High School is already consistently over capacity, and it is not possible to expand the school on its current site. Should Adastral Park come forward in the near future, this creates an opportunity for delivering additional secondary school capacity, to take pressure off Farlingaye. However, our authorities need to discuss contingencies for managing this

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6549 - 2581 - Woodbridge - None 6549 Comment Woodbridge Housing Market Area Woodbridge

growth.

5. Health and Wellbeing

5.1 The County Council is keen to discuss the extent to which this document can promote the objective of the Suffolk Health and Wellbeing Strategy. Particular issues are access to the countryside and green space via the public rights of way network, and consideration of whether allocations for supported housing are necessary.

6. Libraries

6.1 In order to ensure deliverability of the Plan, it will need to be demonstrated that provision can be made to increase library service levels through developer contributions. The County Council is currently developing a more detailed plan for how library service provision will be developed in order to meet the demands of planned growth, in order to inform discussions on CIL spending.

7. Minerals and Waste Plans

7.1 At present, the County Council has no comments as the Minerals and Waste planning authority, but our authorities will need to work to ensure consistency between Plans. Our authorities should consider how we might encourage the sustainable use of minerals in situ, in advance of development, in order to reduce the need for extraction elsewhere and to reduce the highway impacts of construction.

8. Natural Environment

8.1 The County Council is interested in the ways in which this DPD can support the objectives of Suffolk's Nature Strategy, and would be pleased to work with the District Council to consider how this DPD could promote natural environment objectives, such as developing ecological networks. This is relevant in the context of the health and wellbeing strategy (as referred to elsewhere in this response), and the availability of accessible green space is important for mitigating impacts on European designated sites.

9. Public Rights of Way

9.1 The NPPF refers to a need for the planning system to protect and promote the public rights of way network. The Suffolk Health and Wellbeing Strategy includes 'access to a healthy environment' as a key objective. The Plan should consider how it will meet those challenges.

9.2 There is an opportunity to give detailed thought as to how the Plan can encourage healthy and sustainable travel, improve access to the countryside and open space, and to improve leisure and recreation opportunities. Officers from the County Council would be pleased to support the development of the plan in respect of these opportunities.

10. Surface Water Management

10.1 The County Council would be pleased to provide surface water flood records, to help consider the deliverability of sites and whether or not any specific policy measures will be required. SuDS principles should be applied as appropriate, in accordance with national standards, to enhance recharge of underground aquifers as well as provide surface water management and environmental features.

11. Transport

11.1 The County Council has previously provided comments on potential highway impacts arising from each site individually. It is not envisaged that these allocations will require a cumulative assessment of transport impacts.

12. Waste Provision

12.1 Suffolk Coastal, outside of the Felixstowe AAP area, is served by Household Waste Recycling Centres at Leiston, Felixstowe and Foxhall.

12.2 Whilst there are no proposals under consideration at the current time to change the service provided at the Leiston site, or indeed to move it, there is a recognition that the site does suffer from congestion at peak times. It is likely that the impact of development in the local area will increase pressure on the site and the County Council will be seeking developer contributions to fund improvements in the current site or to fund a replacement, should an alternative site come forward.

12.3 The Foxhall site will require a modification and change to existing planning permissions beyond 2021, if it is to remain on site it will need a partial rebuild for certain and, possibly, modifications to the vehicular access arrangements. If this is not possible a new site will need to be found in the area and before 2020 at the latest. CIL funding may be sought to support these projects.

13. Water Management, Flood and Coastal Defences

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6549 - 2581 - Woodbridge - None 6549 Comment Woodbridge Housing Market Area Woodbridge

13.1 Water resources are critical in the east of Suffolk, as recognised in Anglian Water's recently updated Water Resources Management Plan. Any measures that can be incorporated in new developments to capture/reuse/recycle water should be encouraged.

13.2 The recently finalised Deben Estuary Plan (and forthcoming Alde/Ore Estuary Plan) should be considered in relation to the development of this Plan - in the same way as the Suffolk Shoreline Management Plan. These plans rely upon a willingness to embrace the principle of an integrated system - recognising the need to reconcile the continued wellbeing of the river systems, the interests of the communities and the ecological integrity of unique estuarine environments.

13.3 The concept within these estuary plans, of 'enabling development', proposed as one possible mechanism for funding local flood defences, should be encouraged where proper infrastructure can also be provided.

13.4 Where appropriate development funding should be directed towards flood and coastal defences. Without local contributions of this type, many of our existing settlements will be at risk in the future.

Appendix: Likely Archaeological Assessment Requirements

East Ipswich Plan Area

Martlesham 900a. This site was covered under advice in 2008 for 703. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham 893. This site is close to areas of prehistoric activity (County Historic Environment Record MRM 154, MRM 027). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Westerfield 939. This site is close to the medieval core of the settlement, and within the findspot of Roman, Saxon and Iron Age objects. There is high potential for the development to impact on archaeological remains of these periods. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Martlesham EMP1 694 - previous recommendation for early archaeological assessment (sites 721/694/644).

Ransomes EMP2 - This large area (15ha) lies adjacent to a series of burnt pits (County Historic Environment Record PFM 009) and cropmark features of a pre-historic/Roman trackway and associated features to the east (PFM 085). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Framlingham

Wenhaston 938a. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Wenhaston 938b. This site is in an area of high archaeological potential overlooking the Blyth Valley and in an area topographically favourable for early occupation. Wenhaston has Roman and Anglo-Saxon origins. The development also has a frontage onto one of the historic streets of the late Saxon and medieval settlement. Given the size of the development area and the potential of the site, it should be subject to archaeological assessment at an appropriate stage in the the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Yoxford 794. No objection in principle but it would any application should include an desk-based assessment and appraisal of structures currently existing on the site. Depending on the results of desk-based assessment, the site may require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham

Aldringham 5668. Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work. Development should be sensitive to the particular historic character of the built environment.

Benhall 969. This site is in a topographically favourable location for early activity overlooking the River Fromus. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6549 - 2581 - Woodbridge - None 6549 Comment Woodbridge Housing Market Area Woodbridge

work.

Blythburgh 4UCB. This site is in an area of very high archaeological potential within the historic core of Saxon and Medieval Blythburgh. The development fronts historic streets of the settlement. It has remained undeveloped in more recent periods (e.g. as shown on historic OS maps) and there is good potential for preservation of earlier archaeological remains. There could be complex remains surviving. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Blythburgh 3UCB Development on this site should be sympathetic to the historic farmstead, and development proposals should include assessments of historic buildings which are to be altered by the development so that informed decisions can be made. The site has archaeological potential, close to the existing 16th century building and within the historic core of Blythburgh. It would require a planning condition under the NPPF to secure a programme of archaeological work.

Kelsale cum Carleton 884 This site has not been systematically investigated for archaeological remains. It is in a topographically favourable valley side location, and should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Knodishall OPP5 This site lies within the historic settlement core, on the green edge, and development has the potential to impact upon early settlement remains. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Middleton 779 This site lies within the historic settlement core. A prehistoric ring ditch is recorded to the west (County Historic Environment Record MDD 004). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Saxmundham 1006 This site is in an area of high archaeological potential overlooking the valley of the River Fromus. Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Saxmundham 1009 This site has been partially evaluated for archaeological remains (geophysical survey and some archaeological trial trenching). There are no grounds to object to development, but development will require a planning condition under the NPPF to secure a programme of archaeological work. This should include record of farm buildings, and further evaluation in the first instance. The results of evaluation will inform the overall archaeological investigation strategy.

Woodbridge

Aldeburgh 982 This large site is in an area of high archaeological potential, on a south facing slope overlooking the estuary and Aldeburgh marshes. Medieval archaeological remains are recorded to the north (County Historic Environment Record ADB 004), and Bronze Age to the west (ADB 002). Given the size of the development area and the topographic potential of the site, it should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Much of the site is within the area of brickworkings associated with the former Read's Brickworks. Desk- based assessment and geophysical survey in the first instance would establish the impacts of this previous landuse. There would be potential for promotion of the heritage of the area.

Hollesley 829 This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the southwest (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work.

Hollesley 9UCH This site lies in a topographically favourable valley location with potential for early activity, and recorded sites in the vicinity are evidence of scattered prehistoric activity. Bronze Age urns were recorded to the northeast (HLY 003). No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Information on buildings on the site should be submitted with any application, should they be impacted on by proposed development.

Hollesley 8UCH. This site lies within the historic core of Hollesley, opposite the church and with a street frontage that has high potential for archaeological remains relating to early settlement. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Early evaluation of the street frontage would be advisable so that archaeological investigation can be factored in to project designs. Evaluation has been carried out towards the rear of the site and did not reveal significant remains.

Orford OPP4 This site is close to a possible mound site (County Historic Environment Record ORF 023), and the site of a windmill depicted on a plan of c1600 (ORF 019). It should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable). Woodbridge Housing Market Area Maps

C - 6549 - 2581 - Woodbridge - None 6549 Comment Woodbridge Housing Market Area Woodbridge

investigation strategies. Geophysical survey would be appropriate in the first instance.

Shottisham 812b Map location not provided, but the site is within the historic core of the settlement and would most likely require a planning condition under the NPPF to secure a programme of archaeological work.

Shottisham 812d Exact map location not provided, but the site is within the Anglo-Saxon and Medieval core of the settlement (County Historic Environment Record STT 059), close to the church. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Development should respect the historic character of the built environment.

Tunstall 786 - This site lies within and on the edge of the historic settlement core. No objection in principle but it would require a planning condition under the NPPF to secure a programme of archaeological work. Any application should also include an assessment of buildings that are to be affected by development.

Woodbridge 900a - This site lies within an area of archaeological potential, and Neolithic pits and Iron Age features were excavated to the south (County Historic Environment Record MRM 030). The site should be subject to archaeological assessment at an appropriate stage in the design of new development to establish the impacts of past land-use, and ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Summary: Woodbridge 900a - This site lies within an area of archaeological potential, and Neolithic pits and Iron Age features were excavated to the south (County Historic Environment Record MRM 030). The site should be subject to archaeological assessment at an appropriate stage in the design of new development to establish the impacts of past land-use, and ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Change to Plan

Appear at exam? Legal? Sound? Duty to Cooperate? Soundness Tests Not Specified Not Specified Not Specified Not Specified None

Attachments:

Note: The composite reference number in the box at the top of the page is made up of the following information:Object/Support - Representation Number - Respondent Number - Plan Reference - Soundness Tests (if applicable).