Housing Distribution Updated Preferred Option 7/09
Public comments received and the Council’s response to issues raised
May 2010
Housing Distribution Updated Preferred Option 7/09 The Council’s Response to issues raised
Suffolk Coastal’s Cabinet agreed in July 2009 to consult with the community about the updated housing distribution contained in the latest version of the Local Development Framework’s (LDF) Core Strategy.
Following the Core Strategy Preferred Options public consultation earlier in the year, and also taking account of the changing economic circumstances, the updated Core Strategy proposed to the LDF Task Group and then recommended by it to Cabinet involved a significant change in the distribution of housing, most notably in Felixstowe and Martlesham.
We wanted to give everyone the opportunity to understand and comment upon the changes to the distribution of housing so we consulted with the public from 23 September 2009 until 18 November 2009.
The consultation was very focused, concentrating on the updated housing distribution, and:
• whether or not people thought that the reasons behind the changes are justified; • if they thought the broad strategy, which has achieved a large measure of agreement, will be better met as a result of these changes.
Viewing responses
Below are the public’s comments received in response to this consultation. The box after each comment refers to the Council’s response to the various issues raised. These responses are all shown at the end of the document. Please find your comments by using the search facility for your name or your respondent ID from the online consultation system. Clicking the red box will automatically take you to the Council’s responses at the end of the document where you are able to read those related to your own comments as well as all the other issues raised.
Please note: only the text put directly into the consultation document is shown here. Any attachments are referred to but not included. The responses given refer to the full attachments which are available to view via the online consultation pages.
IPSWICH POLICY AREA
Respondent Name: A and R Clements [402] Submission Agent Respondent ID: 402 ID: 402 ID: SUBMISSION We moved into Waldringfield from London last year. Can you imagine the feeling, finding a bungalow in such a lovely part of the country, and one we could afford. We can't believe how you can consider building 2000 houses in the remote and wild life area.
You must realise how crowded the A12. A14 and even the Kesgrave road is in rush hour, and as most young families have more than one car it will cause mayhem on the roads.
If you go ahead with this plan, I think people will find they are cut off from the rest of the world because the Infrastructure won't be able to cope.
SCDC Response: 13, 17, 19, 20
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: A Georgiou [173] Submission Agent Respondent ID: 173 ID: 173 ID: SUBMISSION Where Martlesham Heath is concerned I am shocked that again you are focusing on road transport. This is contrary to high profile climate control and vital green initiatives. Why are we not focusing on developing our areas that have the significant benefit of existing railway stations and improving this network to support a mobile green workforce who do not need to use cars? Adastral New Town will have a massive detrimental impact on Woodbridge and a significant impact on Felixstowe. The opening of a Tesco Superstore impacted immensely on Woodbridge Town centre so what will a new neighbouring town do??
SCDC Response: 11
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT?
Respondent Name: A Georgiou [173] Submission Agent Respondent ID: 173 ID: 173 ID: SUBMISSION This is grossly misleading and contradictory. Martlesham Heath is not a 'larger settlement'...'where most people already live and work and services are concentrated..' It is a village, has limited choice of shopping facilities, limited public transport and facilities. For instance Woodbridge and Felixstowe have the significant existing benefit of railway links to help minimise carbon emmisions and support our green policy (if indeed the council has one?). Not to mention their established town centres offering choice. Both towns centres were suffering before the recession. What makes you think another neighbouring town without even a rail connection will solve the problem?
SCDC Response: 11
3 BACKGROUND
Respondent Name: A Georgiou [173] Submission Agent Respondent ID: 173 ID: 173 ID: SUBMISSION I would like to know how many unoccupied properties we already have?? Our county has a higher level of older and retired people. You even highlight this. It is self evident this group are least likely to add further children to our population and longer term housing demands. If the number of elderly utilising care home places has declined,then please confirm the number of care home places say 5 years ago and the number now? Government housing needs were also based on an open door immigration policy that has now changed - what allowance has been made for this?
SCDC Response: 3 Council tax records show there are 1969 empty properties. This figure does not include holiday homes but it does include properties that are unoccupied under "special" circumstances e.g. a property where the owner is deceased.
2 THE CONSULTATION IN BRIEF
Respondent Name: A Georgiou [173] Submission Agent Respondent ID: 173 ID: 173 ID: SUBMISSION Ipswich town is an eyesore. It is punctuated by unoccupied residential developments, plus un-utilised brownfield sites. Developers and landlords still cannot sell or get occupation of existing housing stock/commercial units. Speculative developments without the population to live in them, without a significant local employment increase, without first becoming more vibrant and welcoming, without a transport infrastructure. As evidenced do you really want to continue repeating this tangibly speculative haphazard planning nightmare in Martlesham Heath? You will repeat your mistake if you continue playing a housing numbers game creating an urban cancerous sprawl without regard for what is really needed.
SCDC Response: 12, 13, 16
8 YOUR COMMENTS
Respondent Name: A Georgiou [173] Submission Agent Respondent ID: 173 ID: 173 ID: SUBMISSION STRATEGY - Has the council obtained a commitment from BT to remain at Adastral Park. Are we sure this is not an exit strategy for BT. The usual strategy in these circumstances would be for a high tech company in an outdated building to sell off the existing site currently occupied in order to fund a new modern green bespoke building next door or elsewhere?? Lets face facts it must be overdue. If it is part of a BT exit strategy, then all this housing and so called tech park etc will be an enormous white elephant. Done up like a kipper??
SCDC Response: 7, 21
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: A Georgiou [173] Submission Agent Respondent ID: 173 ID: 173 ID: SUBMISSION TELECOMMUNICATIONS - By stating that you will give 'priority to employers' confirms there will be insufficient capacity to support the domestic community. Currently Martlesham Heath obtain a maximum ADSL broadband speed of 1Mbit/s. It is already unlikely to meet the government target of 2Mbit/s by 2012. This is yet another area that fails to meet basic modern planning needs. We are hardly going to support green initiatives such as working from home if we have no plan to guarantee an improved broadband service. Somewhat ironic given it is BT at the root of this disastrous planning fiasco.
SCDC Response: 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: A Georgiou [173] Submission Agent Respondent ID: 173 ID: 173 ID: SUBMISSION ELECTRICITY - Yet again for a vital service that will not be able to support such a hugh development you plan on relying for funding on ' other mechanisms'. Please be so kind as to explain to us all precisely what 'other mechanisms' is. Quite simply I suspect it is just jargon for we do not have the money, we do not know where the money will come from, but we will just go ahead anyway without any plan, and complete disregard for the community and the finacial burdon it will create.
SCDC Response: 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: A Georgiou [173] Submission Agent Respondent ID: 173 ID: 173 ID: SUBMISSION POLICE - You clearly state, and it is logical, that such a significant increase in the local population will increase crime. The only financial 'plan' you have, and yes you've guessed it, is a 'developers contribution'. Yet again a short term sweetner to support a vital and essential public service. This is integral to the well being and safety of any community. You are treating it as such a very low priority that it borders on contempt for our community and what will be an overstretched police force. Shame on the planners.
SCDC Response: 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: A Georgiou [173] Submission Agent Respondent ID: 173 ID: 173 ID: SUBMISSION HEALTH- This is diabolical and you have no plan. Even if there is a new GP surgery this will be little use if you do not have a hospital to support the population. The recent national survey on hospitals showed how poorly Ipswich Hospital is performing in various catagories, and yet you want to further burden it. It will be a disaster. You clearly state 2 significant financial phrases 'limited capacity' and 'funding is likely to be extremely limited'. This alone should stop the development in its tracks. If we cannot maintain existing health, then what are you thinking.
SCDC Response: 15, 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: A Georgiou [173] Submission Agent Respondent ID: 173 ID: 173 ID: SUBMISSION Education-Kesgrave School is already overscribed. It has been proven that an entirely new senior school will be underscribed and finacially unstainable. You speak of funding yet again from 'other mechanisms' but at no stage do we get tangible evidence of exactly what this is?? A 'developers contribution' as we all know will be a short term sweetner and has no sustainable long term financial merit. Education is paramount to the future of a community and as we all know is extremely expensive. Quite simply you do not have short to medium term funding in place let alone long term.
SCDC Response: 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: A W Fane Farms [492] Submission Agent Respondent ID: 492 ID: 492 ID: Mr John Fletcher SUBMISSION Dear Sirs
I act on behalf of A W Fane Farms,and confirm that representations have been made to your LDF process under the above reference.
This further representation is made on behalf of A W Fane Farms,in response to your current consultation process.
Much is being made locally of the availability of a large area of land at Adastral Park,Martlesham. May I stress the strategic importance of encouraging some residential development within the more dynamic villages,so as to ensure their continuing success,and in particular, the provision of services,which are often difficult to justify unless on a reasonable scale.
Too much concentration of development in one,large conurbation at the expense of smaller scale development in selected villages is to be avoided for the long term good of the region,and so I hope you can reassure me that proper recognition will be given to the areas owned by my client as your policy unfolds.
SCDC Response: 4, 21
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS A. Thompson and H. Phillips Respondent Name: [299] Submission Agent Respondent ID: 299 ID: 299 ID: SUBMISSION Objection to planning at Adastral Park Martlesham.
We moved to Martlesham Heath 3 years ago. The reason we bought our property was purely location. Martlesham Heath is a unique village with lots of space, greenery and wildlife. If we had wanted to live in a town then we would have done so.
We feel very strongly against the prospect of 2000 houses being built just across the A12, plus a footbridge connecting Martlesham Heath to the site. The impact on our local environment is unthinkable. Already the A12 is unable to cope with the traffic and especially rush hour traffic is a nightmare. We do not need the houses, we do not need commercial units, we do not need a hotel and Martlesham Heath does not need or want to be joined by a footbridge. What we need is to keep our lovely neighbourhood and not to be urbanised.
Please do not pass this planning application as it would be a huge mistake.
SCDC Response: 13, 17
1 INTRODUCTION AD&P Ltd (Mr Brian Morgan) Respondent Name: [584] Submission Agent Respondent ID: 584 ID: 584 ID: SUBMISSION LDF Updated Preferred Options 07/09: Consultation response on behalf of Mersea Homes Ltd.
On behalf of our clients we attach our consultation response made in respect of the above mentioned consultation. Our documents consists of this covering letter, the completed and signed consultation form, a report entitled 'Core Strategy and Development Management Policies, Housing Distribution Update Reg 25 Consultation response' (with appendices) and a CD of the documentation.
Our client believes this Core Strategy document is a departure from the adopted East of England Plan and Planning Policy Statement 12 and is unsound on grounds of legal requirements and justification. Accordingly it will be necessary to replace the current LDF document prior to its submission under regulation 27 to ensure it is not rejected at Examination in Public on grounds of soundness.
Details of our case are set out in detail in the accompanying report along with our recommendations.
We are objecting on the basis that both documents have to be withdrawn and replaced with a Core Strategy based on the report to the Task Group Committee dated 4th August 2008 (with amended housing numbers). The basis for our objection is set out in the attached consultation response document.
1. Executive summary 1.1. This consultation response identifies a policy shift away from treating Felixstowe correctly as a Haven Gateway Growth Point and replacing it by a policy of development restraint. This change has not been substantiated by evidence and is a departure from the provisions of the East of England Plan.
1.2. The housing distribution now proposed would create an imbalance between housing allocations in the Ipswich Policy Area compared with the 'rest of the district'.
1.3. The Council has underestimated housing need within their district up until 2016. This is in part due to an incorrect method of calculating the 15 year period and partly by not allowing for a contingency figure to address unforeseen circumstances. This has meant that for the District as a whole there will be a shortfall of 1612 dwellings for the period 2011 - 2026. It should be noted the Council have allowed a contingency housing figure in the Ipswich Policy Area, but have not done so in the figures for the rest of the district.
1.4. The Council has not published an up to date SHLAA which makes informed consultation response on its housing distribution strategy impossible. The locations for proposed growth in the 'rest of the district' have changed through the various consultations and, even at this late stage in the LDF process, remain unclear.
2. Introduction 2.1. Without yet reaching the Core Strategy Submission Draft LDF stage the Council has undertaken five consultations. For Felixstowe this has meant a journey from an original vision for a future based on growth, regeneration, prosperity and sustainable communities. It has now arrived at a proposal for which the top priority is to keep development in Felixstowe to an absolute minimum. The Council describes this policy shift as an 'evolution'; our conclusion is that since the 4th of August 2008 policy development has drifted away from the correct approach.
2.2. The process began with the Council's evidence showing a poor 'health check' for Felixstowe and a determination to make changes to ensure a better and fairer future for all. It has ended with lobby group pressure overriding acknowledged wider community issues. The Council's early LDF work took the new planning system to its heart offering informed choices based on evidence. However, since the 4th of August 2008 the LDF planning process has had little similarity with that set out in PPS 12 and other government guidance. It gives the appearance of a series of unplanned and uninformed decisions with no continuity or 'paper trail' showing how they have been logically made. A simple illustration is how each of the Sustainability Assessments has reached different conclusions, their only common ground being that they did not inform decisions, but were simply prepared to justify them afterwards. The result of this unconnected decision making is there is no recognisable strategic growth location for Felixstowe. Whilst there were options set out in the Further Issues and Options Consultation, they were subsequently abandoned in favour of an unspecified 'organic dispersal' approach. The lack of any information as to where development will take place has meant the two consultant companies (employed to assist with the production of supporting evidence based on a Council's brief) have both had to make an informed guess. Firstly Entec was charged to identify sustainable but dispersed growth locations. They arrived at conclusions which similar to the Council's proposals put forward on the 4th of August 2008 (Options 3 & 4 set out in Appendix 2)). Entec's findings were presented for public consultation (see presentation in Appendix 3). Entec's report has never seen the light of day, nor has it been formally rejected (at the time of writing the Council's explanation is that the Entec report is 'work in hand'). We must assume their findings were privately dismissed by the Council, but this has not been done in a transparent or fair manner. Roger Tym & Partners published their final Felixstowe Infrastructure Study in September 2009. However, they too had problems in assessing the Council's strategy for growth in Felixstowe on the basis that nobody knew the actual development locations. In paragraph 3.3 of their report (under the section heading scale and broad locations of growth) the consultants offered this caveat to their findings: "...It should be noted that the Council's published documents do state a general area for growth post 2020. They merely state that development options should be revisited in the light of a review against objectives for Felixstowe. However, from the point of assessing infrastructure requirements and consulting with service providers it is very helpful to have rough areas to discuss. RTP therefore interpreted the locational principles of accommodating growth within or immediately abutting main urban areas on the north side of Felixstowe. This was only for the purpose of assessing the infrastructure implications of growth of 1000 dwellings in and around Felixstowe."
Both Entec and Roger Tym & Partners are expert consultants and used by Councils all over the UK. They both make the same conclusion regarding the best sustainable location for growth in Felixstowe which also accords with the Council's original Options 3 & 4 in the report put to the Task Group on August 4th 2008. The combined weight of the consultant's and the Council's own original work has never been questioned, challenged or refuted by the Council. It has simply been ignored.
2.3. The trail of these events is set out in Appendix 1 in a table format which links the consultations and evidence base with what actually happened in the decision making process. In summary we can see a starting point was established based on the East of England Plan and the Haven Gateway Strategy giving Felixstowe Growth Point Status. The town was identified as one of the region's key economic drivers which should have been a focus for housing growth and economic development. The Council's 2006 Vision and Objectives document set out a stark 'wake-up call' for Felixstowe based on evidence which showed: * A need for as much as 10% more housing added to the existing stock. * The widening affordability gap between house prices and income. * An increasing population age gap imbalance. * Young people having to leave the town to find work and a home. * An employment imbalance creating significant in-commuting by port workers unable to find local housing. * A decline in the traditional tourist industry.
2.4. The Council's 'evolutionary' strategy to address these issues has effectively rejected the Town's Growth Point Status by reducing its housing allocation which was originally calculated as being essential to meet the Regional Plan's strategy. The council's original vision for the town made in response to identified problems, has been lost and is now only mentioned as a token gesture. A good example of this is contained in the Council's answer to the Preferred Option consultation response (issue 1: page 9 of the current consultation document). Whilst acknowledging the issues facing Felixstowe which were identified in the David Lock Report (A Local Strategy for Felixstowe Peninsula - April 2006) the Council concludes "a reduction in housing numbers could therefore be considered, particularly during phase 1 & 2 without seriously compromising the overriding objective of securing regeneration". This is a surprising statement as it apparently supports a reduction of housing numbers even though the regeneration of Felixstowe is, to an extent, compromised. This demonstrates how the key planning objective for Felixstowe had been changed from regeneration to growth reduction, in contrast the approach advocated in PPS 12 paragraph 4.36 which states "Core Strategies must be justifiable: they must be founded on a credible evidence base and the most appropriate strategy when considered against the reasonable alternatives". The overriding question here is if the Council are seeking to regenerate Felixstowe why the housing allocation (which was previously thought appropriate) should be reduced, even if the Council realise it will compromise its stated objective?
2.5. The current Housing Distribution consultation was initially not thought necessary by the Council. It has now been put to the community in isolation from the Council's vision, Regional Strategy and consideration in relation to all reasonable alternatives. The principal vision has changed from the need provide decent homes where they are most needed, delivering sustainable communities and underpinning future prosperity for Felixstowe. The 'vision' is now become one of reducing growth to the absolute minimum. At the same time the available evidence, such as the Felixstowe Northern Fringe Landscape & Visual Appraisal 2008 and the Ipswich Eastern Fringe & Felixstowe/Trimleys Transport Studies August 2008 were each based on the previous proposal for 1660 Greenfield housing units and all supported that level of growth in Felixstowe.
3. Conformity to the East of England Plan 3.1. The Haven Gateway Sub Region consists of Tendring District, The boroughs of Colchester and Ipswich and parts of Babergh, Mid Suffolk and Suffolk Coastal Districts. Paragraph 13.27 of the East Of England Plan (Adopted 2008) confirms: "The Haven Gateway is focussed on the key centres for development and change of Colchester and Ipswich, the towns of Clacton Felixstowe and Harwich and the major ports of Felixstowe and Harwich. The sub- region has substantial potential to develop further as a major focus of economic development and growth, which is recognised in its identification by the government as a new growth point". 3.2. The Plan makes further reference to Felixstowe: 3.2.1. Policy HG2 - "Local Development documents should provide an enabling context for not less than 50,000 additional jobs distributed as in Policy E1" [30,000 jobs for the Haven Gateway]. Bullet point 3 confirms "providing appropriate sites, premises and infrastructure to attract a diverse range of employment to Ipswich Colchester, Harwich, Felixstowe and Clacton".
3.2.2. Policy H1 - "Local planning authorities should plan for delivery of housing for at least 15 years from the date of adoption of the relevant development plan documents. In doing so they should assume that the average annual rate of provision after 2021 will be the same as the rates in this policy for 2006 to 2021 or 2001 to 2021, whichever is the higher". The table attached to Policy H1 confirms "the allocation for Suffolk Coastal as 10,200 including about 3200 on the edge of Ipswich as part of the Ipswich Policy Area".
3.3. The identification of Felixstowe as a Growth Point is a fundamental objective of the Haven Gateway strategy and the East of England Plan. Both the Port and the town of Felixstowe are individually identified in the context of significant sub-regional growth and development. The Regional Plan confirms the role of specific local planning authorities as 'providing the context' to attract a wide range of employment opportunities. Felixstowe's role within the Haven Gateway is to regenerate itself by attracting growth by virtue of its role as an existing key economic driver, but also by attracting new employment opportunities.
3.4. The Council's Core Strategy Preferred Options and subsequent Housing Distribution update will have to be judged in the context of the East of England Plan's vision for this sub-region. The issues are firstly how much growth is required and secondly where should it go? Up until the 4th of August 2008 the Council's LDF documents addressed its responsibilities. Since that time we have seen a continued policy drift away from the Regional Plan described as an 'evolving strategy'. We say it is not the role of individual district planning authorities to amend the Regional Plan as doing so would inevitably undermine the Plan itself. Felixstowe must play its full part because of its importance as a key economic driver within the sub-region.
3.5. The question of the quantum of housing has not been properly addressed by the Council. Whilst acknowledging its figures are a minimum and not a target, each LDF document continues to treat them as targets only. The Issues and Options document (pre-4th August 2008) identified significant local housing shortfalls in Felixstowe, and in particular the affordability gap between income and house prices. In response the Council initially calculated housing trajectories which met RSS requirements, then for Felixstowe this was cut by approximately 600 dwellings from the Regional Plan's figure for 'the rest of the District' i.e. outside the IPA.
3.6. The Regional Plan's recommendation for the IPA is 'about 3200'. If the Council belatedly consider an additional allocation of 1000 houses is necessary to underline the sustainability development at Martlesham, their correct pathway should have been to increase the Regional Plan's figure for the IPA. It is now incorrect to deduct this figure from the 'rest of the District' allocation as that extent of growth is identified in the Regional Plan as being necessary to support Felixstowe's role as a Growth Point. If the Council wish to increase the allocation in the IPA area by 1000 dwellings over and above the RSS proposal, this figure would need to be added to the overall total allocation for the Suffolk Coastal Area. For these reasons of insufficient economic growth and housing in the district generally, and removing Felixstowe's Growth Point status in particular, the Council's Core Strategy proposals do not conform to the East of England Plan.
4. Housing Trajectories and Delivery 4.1. The current total 15 year housing number requirement as calculated by the Council is not correct for two reasons. Firstly, the actual 15 year supply from the adoption of the Core Strategy must be based on a full 15 years (i.e. from the year end in the year of adoption). In this case if, as programmed the Core Strategy it is adopted after March in 2010 the 15 year period will start in the following April in 2011 and run the end of March 2026. Based on the RSS annual housing completions for Suffolk Coastal District Council of 510 this will mean a minimum of 25 x 510 = 12,750 houses between 2001 and 2026. This figure would then be subdivided between the Ipswich Policy Area (3970) and rest of the district (8,780). However, it has not been possible to comment fully on the Council's land supply figures as there is no up to date SHLAA available within the Council's evidence base.
4.2. Secondly, and more importantly, whilst recognising the requirement to meet minimum RSS figures the Council have not implemented any strategy to ensure this is the case. There are many threats to housing delivery, for example a site may not come forward as anticipated due to infrastructure delays. Furthermore, in the current economic climate schemes may be unviable and therefore alternative (non residential) uses may be preferable. For all these reasons it would be unsound not to have the flexibility contained in a contingency housing figure. In paragraph 4.46 of PPS 12 a Planning Authority's obligations to ensure delivery are clear: "A strategy is unlikely to be effective if it cannot deal with changing circumstances Core Strategies should look over a long time frame - 15 years usually but more if necessary. In the arena of the built and natural environment many issues may change over this time. Plans should be able to show how they will be able to handle contingencies: it may not always be possible to have maximum certainty about deliverability of the strategy. In these cases the Core Strategy should show what alternative strategies have been prepared to handle this uncertainty and what should trigger their use. Authorities should not necessarily rely on a review of the plan as a means of handling uncertainty". The Council appear to be making the assumption that if the minimum numbers of houses are allocated then this has discharged their responsibility to the Regional Plan. Indeed their strategy at Felixstowe has ended up as one of building the least number of houses possible aided by a strategy of exporting its housing allocation to the Ipswich Policy area. In the absence of any housing delivery contingency plan within the Core Strategy the Council must allow a contingency of numbers. There is a range of unforeseen circumstances capable of reducing the anticipated yield from a particular site; for example economic viability, unforeseen environmental constraints, archaeological remains etc. As noted above PPS 12 says a plan should be able to deal with changing circumstances, but currently this is not the case. In the current significant economic uncertainties contingency of between 10% and 5% would be a prudent measure. This would take the correct 2011- 2026 15 year housing figure from 8106 to 9322. The Council's figure of 7710 will therefore create a shortfall of 1612 dwellings. It will be necessary to accommodate this housing in Felixstowe; this is because the IPA area is acknowledged by the Council to be at capacity with the additional 2000 houses now proposed. 4.3. The correct housing figures will be necessary to allow the development industry increased flexibility to achieve the 510 dwelling per year build rate by maximising the number of available sites to increase sales opportunities. The latest RSS AMR shows a projected housing trajectory gap (on its page 70), which anticipates the post recessionary house building rates for the region as a whole. The graph shown below identifies a housing trajectory gap which will appear after 2010 if individual councils depend on policies which were drawn up in what we now understand was a boom housing period up to 2007. A recession based strategy will require both a contingency of housing numbers and the complete elimination of phasing. This will encourage housing starts and help to avoid the trajectory gap. The Council will also need to revisit its strategy of increasing its allocation at Martlesham at the expense of Felixstowe. This is because it would create an imbalance of development opportunity and lack the flexibility needed to meet the housing trajectory in difficult economic circumstances. In addition the Martlesham land is on mineral workings at Waldingfield Quarry. This is a potential constraint insofar as it depends on the prior removal of the minerals. This task may now prove difficult in the light of the current recession and the widely projected slow path to recovery where mineral demand will not be as previously expected.
5. Recommendations 5.1. The timeline of events (see appendix 1) shows a continued change of direction with decisions being announced without having been consulted. The Council should re-consider its position in the light of paragraph 4.20 of PPS 12 which says: "4.20 The production of core strategies should follow the Government's principles for community engagement in planning. Involvement should be: * appropriate to the level of planning; * from the outset - leading to a sense of ownership of local policy decisions; * continuous - part of ongoing programme, not a one-off event, with clearly articulated opportunities for continuing involvement; * transparent and accessible - using methods appropriate to the communities concerned; and * planned - as an integral part of the process for making plans.
5.2. Until the 4th of August 2008 the Council was supportive of the aims and objectives of the Regional Plan. Since that time there has been a gradual reversal of this approach resulting in them wishing Felixstowe to be downgraded from its Haven Gateway Growth Point status to an area of restraint. This new strategy does not conform to the East of England Plan and will need to be revised accordingly.
5.3. If the Council's current Core Strategy proposals are submitted under Regulation 27 for examination they will be challenged on the following grounds of soundness: * Legal requirements by virtue of o Not being prepared in accordance with the Statement of Community Involvement. o Decisions have not been informed by sustainability appraisal o Failure to conform to the Regional Spatial strategy * Not justified on the grounds of: o The decision making process over the 5 consultations has not been founded on a robust and credible evidence base. o No proper comparison with all reasonable alternatives is now made. o The Core Strategy would not be effective as it is not flexible and has not been demonstrated to be deliverable.
5.4. For these reasons we recommend the Council withdraws its Preferred Options Core Strategy (as amended by the recent Housing Distribution consultation) to be replaced with a Core Strategy based on the report presented to the Task Group on August 4th 2008. However, this proposal will also need to contain amended housing figures to reflect shortfalls in the Council's calculations explained in section 3 above The substance of those recommendations was set out in its executive summary (see appendix 2) but summerised as follows: Felixstowe is selected for new housing because of: * its role as an employment and commercial centre; and * the need to address negative aspects of the town as identified in a recent study, including an ageing population, threats to the continuation of services such as schools, the need for affordable housing and the need to regenerate the economy
Existing planning permissions and 'brownfield' sites will not be enough. 'Greenfield' land is needed - for about 2612 new houses (calculated as the existing 1000 plus the calculated shortfall from paragraph 4.2 above). The Preferred Option Given all of the above the preferred option is: Option 3 - land between Walton and Trimley St Mary and Option 4 - land north of Candlet Road.
Together these can form a package to create a mixture of uses to be developed to the benefit of the long term interests of the town. Such uses would include housing (including affordable housing), employment, community facilities and recreation".
Further documents submitted with these comments including minutes from meetings of the LDF Taskgroup & AD&P comments and submissions from earlier consultations are available to be viewed at SCDC Council Offices in Woodbridge.
SCDC Response: 4, 6, 22
8 YOUR COMMENTS
Respondent Name: Adam Dunn [360] Submission Agent Respondent ID: 360 ID: 360 ID: SUBMISSION Vehicle & noise pollution & traffic will increase substantially.
Wildlife, this area is close to several areas of SSSI and this impact is severe.
Schools provision is inadequate. Existing secondary schools are full, whilst there is talk of a potential new secondary school, the scale of development doesn't warrant a new secondary school
Employment There is no evidence that any employment created by incoming companies will result in jobs for local people and also any persons relocating will want to buy a house in this area.
"Temporary Open Spaces" is an attempt to hide the fact that there would be future further development.
SCDC Response: 7, 17, 19, 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Adam Wickens [24] Submission Agent Respondent ID: 24 ID: 24 ID: SUBMISSION Future Secondary School Provision: Alternative Sites Assessment Ipswich Policy Area - June 2009
If the rationale to increase the housing on the BT site is:
"by allocating an appropriate amount of new housing east of the A12 at Martlesham, to create a self- contained and sustainable community to include community, leisure, education and health facilities as well as employment"
Then this same principle should be applied and a secondary school also built on the BT site.
SCDC Response: Noted
THE OVERALL STRATEGY
Respondent Name: Adam Wickens [24] Submission Agent Respondent ID: 24 ID: 24 ID: SUBMISSION Whilst I object to the overall concept of building so many homes in Martlesham, from my perspective a development at the BT site is the least worst option. I'm not surprised that there is now the request to build additional housing. Logically if 1050 houses were built on the BT site, then a future LDF would identify this same site as the sensible location to accommodate further housing, so the current proposal is only bringing this acknowledgement forward.
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Alison Vernon-Smith [308] Submission Agent Respondent ID: 308 ID: 308 ID: SUBMISSION I am a frequent visitor to Waldringfield I want to register an objection to the LDF housing changes The proposal is inconsistent with national and international policies on affordable housing, biodiversity, traffic and RAMSAR, AONB, SSSI and SSS sites. There is no evidence that there is a connection between local residency and local employment; BT is shedding 15,000 jobs this year and only 3% of BT employees live in Martlesham.Moreover this development will swamp local amenities, character and quality of life.
SCDC Response: 7, 17
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES Allsop Verill (Simon Roberts) Respondent Name: [577] Submission Agent Respondent ID: 577 ID: 577 ID: SUBMISSION REPRESENTATIONS ON CORE STRATEGY HOUSING DISTRIBUTION UPDATE SEPTEMBER 2009
Although the total number of new houses proposed in Suffolk Coastal District remains the same as in the Core Strategy Preferred Options December 2008, the Housing Distribution Update September 2009 sets out a number of changes to the distribution strategy (paragraph 2.05:
* Reducing the amount of housing proposed for the Felixstowe/Walton and Trimley villages;
* A substantial increase in the amount of new housing within the Ipswich Policy Area2 east of the A12 at Martlesham;
* A modest increase in provision at the market towns; and
* A reduction in the number of new homes that could be expected to come forward as small 'windfall sites'
The number of homes on newly allocated sites in Felixstowe/Walton/Trimleys has been reduced from 1660 to around 1,000 homes. The 660 new homes has been relocated mostly to Martlesham, with a small increase in the market towns.
The concentrated development option promoted in the Preferred Options December 2008 was rejected in Felixstowe in favour of 'organic and evolutionary growth' (paragraph 5.19). The justification of this is:
* to reduce the impact of one or two single large developments on any single community or the road network; to protect the setting of Felixstowe;
* to provide a more dispersed pattern of traffic movement; to avoid where possible building on prime agricultural land;
* to make more use of brownfield sites; and
* to allow for a slower rate of growth linked to new jobs without being so wholly reliant on the port.
We consider that the move away from concentrated growth towards a dispersed strategy is inconsistent with the following parts of the Vision and Objectives for the District, as set out in the Core Strategy Preferred Options December 2008:
* The provision of housing, jobs and infrastructure in Felixstowe as part of a regeneration initiative (paragraph 2.05);
* Achieving an increased use of public transport and reduced use of personal transport (paragraph 2.09);
* A sustainable pattern of land use, movement, activity and development (Objective 1, paragraph 2.11);
* Focussing growth in Felixstowe and providing houses for workers who are forced to commute (Objective 2, paragraph 2.15);
* Regeneration and diversification of employment within Felixstowe (Objective 4, paragraph 2.22);
* Provision of appropriate infrastructure at an appropriate time to address current deficiencies and meet the needs of new development (Objective 12, paragraph 2.48);
* To improve access to housing, employment, services and facilities (Objective 13, paragraph 2.52).
The approach is also inconsistent with Policy SP1 in the Core Strategy Preferred Options December 2008, which seeks to:
(a) Relate new housing development to services, employment, transport and infrastructure. To achieve this a defined Settlement Hierarchy itself based on sustainability principles has been created and applied; (b) Reduce the overall need to travel; (c) Give priority to re-using previously developed land and buildings; (d) Promote the use of sustainable methods of construction, including materials, energy efficiency, water recycling, aspect etc; (e) Achieve a local balance between housing growth and employment opportunities; (f) Enable a healthy economy, notably in the town centres and rural areas, taking advantage of regeneration opportunities where appropriate; (g) Enhance accessibility to services and create an integrated and sustainable transport system; (h) Conserve and enhance the natural and built environment; (i) Mitigate against the effects of climate change; (j) Maintain and enhance a sense of place; (k) Create and promote inclusive communities in both urban and rural locations; and (l) Provide the appropriate infrastructure in order to support existing and proposed communities.
We wish to emphasise the importance of providing necessary infrastructure improvements, including accessibility, services and facilities, for the residents of the new housing. The Council recognises (at paragraph 5.19) that a dispersed strategy makes this more difficult. We consider that a concentrated approach to housing growth would be more consistent with the Vision and Objective for the District set out in the Core Strategy Preferred Options December 2008. In particular, more housing growth allocated to Felixstowe would better address the problems identified in the David Lock Study.
SCDC Response: 20, 22
8 YOUR COMMENTS Andrew Fisher (Mr Andrew Respondent Name: Fisher) [256] Submission Agent Respondent ID: 256 ID: 256 ID: SUBMISSION The Regional Spatial Strategy (RSS) proposed an additional 10,200 homes for Suffolk Coastal and an indicative jobs target of some 8,000. In addition, the RSS also identifies the importance of the Haven Gateway sub region identifying the following priorities of relevance.
*Develop the diverse economy of the sub-region, including provision for the needs of an expanding tourism sector, support for the establishment and expansion of ICT clusters and recognition of the potential and need for employment growth in the smaller towns; *Regenerate the sub-region to address unemployment, deprivation and social issues; *Provide for major housing growth at the key centres of Colchester and Ipswich; *Promote the centres of Ipswich and Colchester as major centres of employment: *Provide an appropriate range of sites, premises and infrastructure to attract a diverse range of employment to Ipswich, Colchester, Harwich, Felixstowe and Clacton. *Support the maintenance an appropriate expansion of the ports, maritime and related activities recognising the role they play in making the sub-region a major economic growth point.
In relation to the Regional Economic Strategy (RES), the Borough is located within the Haven Gateway Engine of Growth. As such, Suffolk Coastal District is expected to contribute to driving growth, given the importance of agglomeration and the concentration of assets. The following strategic ambitions are identified within the Regional Economic Strategy. *Development of a next generation science based business park at Martlesham *Expand the international port functions of the Haven Gateway *Improve capacity and address constraints on strategic road and rail routes connecting the Haven Gateway to national markets, including the Felixstowe-Nuneaton rail route, Great Eastern main line, A12, A120 and A14 *Preserve and enhance the sub-region's landscape and biodiversity
In addition, EEDA have worked closely with partners in the Haven Gateway to develop the Integrated Development Programme (IDP). This identifies a number of thematic and spatial packages of intervention in the sub-region, with the following being most pertinent to this development plan document. *Ipswich Policy Area - East, including Innovation Martlesham at Adastral Park *Coastal Towns
Comments
EEDA welcomes the approach being proposed through the updated preferred option. RES Goal 8 the Spatial Economy recognises the importance of balancing the approach to the provision of homes and jobs to support economic growth and regeneration. Sufficient high quality, affordable and accessible homes are required in the right places to support the region's labour force. The region's key centres naturally take a key role in this.
The principles in your preferred options document accord with the RES approach of sustainable place making. The application of the settlements hierarchy in the first instance followed by more detailed individual strategies should result in a positive approach to housing distribution that builds on the capacity and needs of places.
Care needs to be taken, however, that the more general approach to development at key and local service centres does not compromise the ability to respond to the needs of the rural economy in Suffolk Coastal District.
EEDA supports the updated distribution with the emphasis remaining on the main urban areas as the recipients of the majority of the housing growth. The balance between Ipswich East and the Felixstowe/Walton and Trimley Villages seems sensible in creating sufficient critical mass in the former to create a genuinely sustainable community, and a phased approach to the latter that effectively supports the regeneration agenda.
Given the scale of the opportunity at Ipswich East, EEDA would support the development of appropriate further guidance as being essential to deliver the wider aspirations for this location. The proposed Area Action Plan appears a logical first step, however, the Council may wish to consider the development of further design guidance utilising regional resources such as Inspire East.
Finally, EEDA would seek to ensure that the transport principles and priorities outlined in the Regional Economic Strategy are reflected. The key transport priorities in the RES are: *Priority 1: A resilient transport system that is used effectively and efficiently *Priority 2: Investment in transport to maximise economic growth *Priority 3: Increased economic benefit to the East of England from major international gateways *Priority 4: Reducing the environmental impact of moving goods and people
In addition, the IDP identifies a number of priorities for transport, including: *Improved capacity on the A12/A14 *Town centre improvements
It is essential that consideration of these issues is embedded in the response to housing growth and the appropriate and sustainable delivery of the preferred option.
By addressing these key elements of the RES, the Core Strategy will provide the context needed to maintain the prosperity of the East of England, enhancing its regional competitiveness and giving support to business growth.
SCDC Response: 4 Other comments noted
8 YOUR COMMENTS
Respondent Name: Angela Humphreys [325] Submission Agent Respondent ID: 325 ID: 325 ID: SUBMISSION Whilst not being against a housing development in principle I believe this is too large. The traffic is already a problem and the council documents do not tackle the sheer weight of traffic due to increase because of the new build and the Port at Felixstowe. There are plans to build a crossing over the A12 on to Village land. This land is owned by the residents and is maintained by them at their own cost and is part of the original plan of the village, to have open spaces between hamlets. This is not acceptable.
SCDC Response: 12, 13, 16, 19
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Angela Humphreys [325] Submission Agent Respondent ID: 325 ID: 325 ID: SUBMISSION Martlesham Heath Village only comprises 1,400 homes and is self contained (with primary/pre-school provision, shops within the village and nearby Tesco etc, high school within cycling distance, bus service, open spaces, doctor, chemist, clubs for all age groups, church, outdoor activities like football and cricket). I do not see why a new community has to be at least 2000 in order to be viable. I come from a council estate of 2000 houses with very few shops, vandalism, little open space and much dissatisfaction with the area by residents.
SCDC Response: 16, 20
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Angela Humphreys [325] Submission Agent Respondent ID: 325 ID: 325 ID: SUBMISSION Saying that the A14 cannot cope with the pressure of traffic at the present and therefore building should not go ahead at Felixstowe does not make sense. The A12 is already used by lorries making there way on to the A14 and this is set to increase if the northern bypass is built. This will bring all the traffic past the proposed development area of 2000 houses and the present village on an already congested road. The lives of those living near to this road will be unbearable. There will be gridlock.
SCDC Response: 12, 13, 19
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY?
Respondent Name: Angela Humphreys [325] Submission Agent Respondent ID: 325 ID: 325 ID: SUBMISSION The provision of jobs in the area is in doubt. At present BT (the largest employer in the area) is cutting back drastically and making redundancies. They have commented that they need the money from the sale of land to update their facilities. This does not sound like a company likely to take on large number of employees. In the area generally there is unemployment due to the recession. Many people on the Heath have not been able to find work since leaving university in June 2009.
SCDC Response: 7
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Angela Humphreys [325] Submission Agent Respondent ID: 325 ID: 325 ID: SUBMISSION 5.10 mentions the ability to build where roads/rail etc can accommodate it and to integrate new housing with existing housing without changing the character of individual settlements. Martlesham Village will be one half to one third the size of the eventual new build. There is a high level of satisfaction and low crime rates on the Village at the moment. The only major frustration is with getting in and out of the village due to peak time traffic. This will get much worse with the new build as will possible vandalism.
SCDC Response: 11, 13, 17, 18
2 THE CONSULTATION IN BRIEF
Respondent Name: Angela Humphreys [325] Submission Agent Respondent ID: 325 ID: 325 ID: SUBMISSION I note that you say that space for 4080 homes will eventually be needed. At present Martlesham has been earmarked for 3,000 by 2030. This is 74% of the total need, which seems an extremely unfair weighting of the distribution, which should be dispersed throughout the region, not just at Martlesham. You say in your publicity that you "respect and maintain the character of individual settlements". This amount of homes will impact on the award winning Martlesham Heath village in terms of traffic, pollution, pressure on community facilities like schools.
SCDC Response: 4, 20
IPSWICH POLICY AREA Respondent Name: Angela Mace [445] Submission Agent Respondent ID: 445 ID: 445 ID: SUBMISSION The proposed changes are not justified and do not comply with your stated strategy objectives of respecting the quality of the local environment, maintaining the character of individual settlements and protecting wildlife and the landscape.
Previous planning strategies have protected the countryside east of the A12 from large housing developments and have avoided large developments on greenfield sites. You should not allow a large housing development to be built on land to the south and east of Adastral Park. it is far too near the AONB, the village of Waldringfield and the River Deben and would have very detrimental effects on them.
Do not allow any large housing developments east of the A12, in this area.
To preserve the rural character of the area, ensure that any new housing allocated east of the A12 is in small groups scattered throughout the area.
2000 new homes located to the south and east of Adastral park would be a disaster for the village of Waldringfield which is a peaceful rural village within the AONB and includes an importnat part of the River Deben.
Waldringfield is one of the few places on the shores of the Deben which can be accessed by vehicles and boat-trailers. Many of the residents of an Adastral new town would want to drive down to the popular sheltered beach, sailing club and riverside path. Cliff Road would often be jammed with traffic and parked cars which would be an obstruction to emergency service vehicles and to the residents accessing their properties in The Quay, Deben lane and Cliff Road. The peace of the village would be destroyed by the extra traffic and the river would suffer from an excess of motor boats etc. Short of erecting a barrier at the cross roads, complete with check point, you would not be able to protect Waldringfield from a large influx of visitors, with which it could not cope.
The proposed changes are not justified and do not comply with your stated objectives of respecting the quality of the local environment, maintaining the character of local settlements and protecting wildlife and the landscape.
Do not allow any large housing developments so near to Waldringfield and the River Deben. Maintain your previous strategy of not allowing large concentrations of new housing east of the A12 in this area.
SCDC Response: 4, 9, 17, 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Angie Vale [37] Submission Agent Respondent ID: 37 ID: 37 ID: SUBMISSION SCDC need to build 2000+ homes, BT need to raise capital by selling off land surplus to requirements due to advances in technology - job done! The inconvenient truth is that local residents don't want it because it will ruin the countryside, destroy wildlife, increase light & traffic pollution, increase crime and increase pressure on local services. We need to protect our open spaces and quality of life rather that just satisifying some Govenment target.
SCDC Response: 16, 17, 19, 20
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Angie Vale [37] Submission Agent Respondent ID: 37 ID: 37 ID: SUBMISSION The reason this area is the preferred option is because BT want it to be and they are a big company with lots of money who are employing people specifically to push this through. It is therefore an easy option for the SCDC.
SCDC Response: Noted
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Angie Vale [37] Submission Agent Respondent ID: 37 ID: 37 ID: SUBMISSION A new development of 2000+ houses would dramatically alter the whole character & feel of the surrounding communities in a negative way by removing the open countryside and creating a massive urban sprawl from Ipswich to the River Deben. It is naive to assume that the people who would live in this new area would work within easy public transport distance, the truth is that there will be a huge increase in traffic up and down the already congested A12.
SCDC Response: 11,13, 17, 19
THE OVERALL STRATEGY
Respondent Name: Angie Vale [37] Submission Agent Respondent ID: 37 ID: 37 ID: SUBMISSION The increase in proposed housing numbers east of A12 has been justified by the proposal of building supporting infrastructure which will result in even more traffic & destruction of surrounding countryside.
SCDC Response: 17, 19
STEP 1-THE SETTLEMENT HIERARCHY
Respondent Name: Angie Vale [37] Submission Agent Respondent ID: 37 ID: 37 ID: SUBMISSION
5.03 The most important "places" which the Core Strategy addresses are the 100+ individual settlements large and small across the district, because these provide the location for homes, jobs, services etc. Their character and location provide other historic and cultural links between individual communities, and their built and natural environments. - if this was so important why are they proposing to ruin these individual communities with a massive housing development?
SCDC Response: 17, 18
3 BACKGROUND
Respondent Name: Angie Vale [37] Submission Agent Respondent ID: 37 ID: 37 ID: SUBMISSION The employment opportunities are the Port of Felixstowe & BT have been greatly reduced with the economic downturn & the current infrastructure can hardly cope with the surge of people travelling to BT, Tesco & the along the A12.
SCDC Response: 7, 13
2 THE CONSULTATION IN BRIEF
Respondent Name: Angie Vale [37] Submission Agent Respondent ID: 37 ID: 37 ID: SUBMISSION I object to the proposed increase in new housing East of Martlesham as it would have a negative impact on the surrounding environment in terms of loss of open space, increase in traffic congestion, threat to the nearby European site, Deben Estuary, loss of identity to surrounding villages.
SCDC Response: 9, 17, 18, 19
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Angie Vale [37] Submission Agent Respondent ID: 37 ID: 37 ID: SUBMISSION The assumptions that the SCDC make in order to validate the proposed 'preferred site' at Martlesham are: people living in these new houses will hardly use their cars & will walk, cycle or use public transport they will work nearby & therefore not use their cars to commute (plenty of people drive to BT from Martlesham Heath now) they will not use nearby SPA/SPC sites because they are more than 1km away, but rather they will use the designated 'green areas' provided It will not be a self-contained area people will spread out & will have an impact on the surrounding environment.
SCDC Response: 9, 11, 17, 18 Other comments noted
APPENDIX 4 - BREAKDOWN OF UPDATED DISTRIBUTION STRATEGY
Respondent Name: Anglian Water (Sue Bull) [483] Submission Agent Respondent ID: 483 ID: 483 ID: SUBMISSION Thank you for the opportunity to comment on this document. WATER To supply the most of the sites with potable water will require off-site infrastructure inprovements and the construction of a new treatment works. Appendix 1 Ipswich Eastern Fringe Infrastructure Study - September 2009 states : 'Water Supply. All growth options almost certainly have sufficient capacity to supply the required potable water supply'. NOT CORRECT - MOST OPTIONS WILL REQUIRE OFF-SITE INFRASTRUCTURE IMPROVEMENTS. WASTEWATER We have previously advised that we have capacity to treat the discharge from the proposed total number of 1000 dwellings. The sewerage network has limited capacity and improvements would be required. Appendix 1 states that Felixstowe WwTW would require expansion - this is not correct. Appendix 4. Table 1 - The growth numbers for the Ipswich Policy Area are split between Woodbridge WwTW and Cliff Quay WwTW catchments. As previously stated, the network infrastructure for all of these sites would require significant infrastructure investment to accommodate this growth. A strategic solution and investment is required for the proposed growth whether it be 1050 or a revised figure of 2000.
SCDC Response: Noted
IPSWICH POLICY AREA
Respondent Name: Anne Parkinson [413] Submission Agent Respondent ID: 413 ID: 413 ID: SUBMISSION Dear Sir I am particularly concerned about the updated preferred option 7/09 for the development of B T's l;and at Martlesham. The suggested increase in the proposed development of a minimum of 2,000 houses will mean a devastating impact of the continual worsening traffic congestion. The proposed seven lanes of traffic to take people to and from the 'new town' will cause bottlenecks on an already congested area : Foxhall Road,A1214 and A14 roads will become gridlocked. The areas rural character will be swamped by the sheer size and scale of the development and will result in suburbia, extending from the town of Ipswich to Waldringfield Heath. The suggestion is outrageous and should be withdrawn. This plan should not be accepted.
SCDC Response: 11, 12, 13, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Anne Greathead [263] Submission Agent Respondent ID: 263 ID: 263 ID: SUBMISSION The proposal is flawed: 1. It'll destroy character and quality of life. 2. Traffic is already unbearable at times. Creating 7-lane junctions only make it worse. 3. It all depends on securing developer funding for the necessary infrastructure, and of course it's BT stoking the engines and steering the ship and hoping we all ignore the icebergs. Who needs all these high- rise apartments and business park edifices? As for integrating with existing communities - well who's fooling who? 4. Extra schools, bigger waste facilities, new power substations, lots of dog tracks ?? Who's devising all this rubbish ? For goodness sake let's quash this.
SCDC Response: 11, 13, 17, 18, 20
IPSWICH POLICY AREA
Respondent Name: Anne Parkinson [396] Submission Agent Respondent ID: 396 ID: 396 ID: SUBMISSION I am particularly concerned about the updated Preferred Option 7/09 for the development of BT's land at Martlesham.
The suggested increase of a minimum of 2,000 houses will mean a devastating impact of the continual worsening traffic congestion in that area. The proposed 7 lanes to take traffic to and from the 'new town' will cause bottlenecks in an already congested area:- Foxhall Road, A1214 and A14 roads will be grid- locked.
The area's rural character will be swamped by the sheer size and scale of the development and will result in suburbia extending from the town of Ipswich to Waldringfield Heath.
The suggestion is outrageous and should be stopped.
SCDC Response: 11, 13, 16, 17, 18, 19
IPSWICH POLICY AREA
Respondent Name: Anne Parkinson [396] Submission Agent Respondent ID: 396 ID: 396 ID: SUBMISSION As a worried resident of Martlesham heath I strongly object to the proposals for a new town (2,500 houses +) for the following reasons:- Not enough research into the proposed infrastructure and realistic solutions Existing roads are saturated with traffic already, especially at peak times - My own experience is one of increased traffic noise especially over the last five years. No examination of nearby rail links Insufficient analysis of the environmental impact on Martlesham heath AND nearby settlements such as Waldringfield, Newbourne etc...
SCDC Response: 11, 12, 13, 17, 18, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Annie Cawthorn [245] Submission Agent Respondent ID: 245 ID: 245 ID: SUBMISSION Dear Sir, I wish to express my deep concern at the proposed development at Adastral Park. As a resident of Waldringfield, and living on the main road into Waldringfield, I am only too aware of the significant, and almost unsustainable, rise in traffic over the past few years. As the road comes to a dead end by The Maybush pub and the river, there is already a crisis in terms of traffic flow during the summer months especially. Parking causes huge problems and the road is very unsafe for pedestrians already. I would urge a reconsideration of this planning application. It will have a devastating effect on this area and on Waldringfield in particular.
SCDC Response: 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Auriol McElhinney [523] Submission Agent Respondent ID: 523 ID: 523 ID: SUBMISSION My objection to the building proposals :
1,050 becomes 2,000 each figure changing the area to its detriment. Saturation of traffic.
Getting on and off the A12 especially in rush hours will be even worse. Chaos will prevail.
A beautiful area now that so much building will destroy. Massive destruction of animal habitat. Woodbridge/ Waldringfield/ Martlesham/Martlesham Heath; adversely affected by too many people living here. This development will be a town in itself; enormous for such a rural area, spoiling it forever.
Where will these people work? Not all at BT, so mayhem on the A12, A14, Foxhall and Main Roads as cars will be used.
Thank you
SCDC Response: 7, 12, 13, 17, 18
THE OVERALL STRATEGY Bacton Gospel Hall Trust (Mr Respondent Name: Alistair Bush) [418] Submission Agent Respondent ID: 418 ID: 418 ID: SUBMISSION Objection to lack of acknowledgement for associated community service sites to be allocated in tandem with housing growth areas. These comments are made on behalf of Bacton Gospel Hall Trust, but are equally relevant to all Brethren Gospel Hall Trusts around Ipswich within the Suffolk Coastal District Council area. Bacton GHT has been actively engaged in the LDF process with SCDC and specifically promotes the delivery of Places of Worship, Meeting Halls, Faith Schools and Burial Grounds as essential elements of the community service infrastructure provision. Please find attached my letter of representation dated 17th October 2006. In reply to this, Mr S Brown (ref SB/BMM/10.5, also attached) acknowledged the relevance of such provision, and that the current Local Plan states that such will be supported, subject to conformity with other policies of the plan. The Trust accepts that whilst there can be no discrimination in terms of specific religions and denominations, the key point is that if specific allocations are not made within the LDF framework, these facilities will find it very hard to compete for site acquisitions in terms of land value. If the 2000 proposed houses were to be taken forward as a single land use allocation, the whole site will fetch land values far in excess of community service facilities which operate mostly as charities. There needs to be a requirement to deliver a defined element of land use for such mix of uses. It is not practical 'on the ground' to just provide a positive tone when mentioning community services. The RSS already does this to a certain extent, so the LDF should translate that down to delivery at the local level. This is not happening at present, and most Gospel Hall Trusts following the need for a new site or building are taking in excess of five years to navigate the planning process. It is accepted that in terms of general location, the facilities should be constructed within a town or village. However, most settlement boundaries are drawn so tightly to existing buildings, that few sites are available, and being within the settlement boundary means most landowners will similarly expect residential land values as redevelopment for housing is thus accepted in principle by PPS3 and local policies usually as brown field residential developments. The problem with the current approach of non-site allocation, is that it provides nothing between settlement and outside, as referred to in the previous letter - "Anything outside must be considered as an exception to local and national policy, for the countryside is to be protected for its own sake". This approach provides no real support or certainty for example where sites are immediately adjacent to settlement boundaries or in urban fringe areas rather than remote locations. A site immediately adjacent an existing settlement boundary can be delivered with the following positive benefits: * The absence of policy support for housing creates a more reasonable land value for a church, school or hall to proceed * The site is well located to the housing catchment area * There will be access by walking, and by public transport links in and out of the settlement * Creates the opportunity for complimentary enhancements to visual appearance and landscaping on the approach to existing settlements
It is therefore suggested that a policy is considered that provides support and opportunity for these types of site to come forward without having to cross all the exceptional hurdles of the current position. To explain and highlight these comments, it is fair and reasonable to foretell a vacuum occurring in the LDF in relation to Ipswich, east of the A12. The Trust has identified a need here for the past five years but no settlement sites have become either available, or been viable. This means that many pre-application enquiries are not supported because of the exception to local and national policy. If 2000 houses are proposed as an expansion of Martlesham there will be an increase in the need for community facilities, including meeting halls, places of worship, faith schools, and burial grounds which will not be able to compete with residential land values. However, suitable fringe sites are available and these need more positive policy support to be delivered. Site 479 in the SHLAA for example is immediately between the existing village settlement and the A12. It is Greenfield, but also forms part of a buffer to the edge of the village. A gospel hall is characterised by a single building and car park within a well landscaped area, in contrast to housing which delivers increased density of buildings and hard surfacing. The Trust would therefore request that a marker is set down for this site to be allocated for community use in the forthcoming allocations work, which will be complementary to the growth at Martlesham which we do support in principle. The landowner is amenable to a non-residential zoning, and would not be resistant to this happening. The growth of housing does require a range of facilities and indeed the location of a gospel hall tends to foster its own congregation, whereby families can specifically move into the area, and thereby become within walking distance of such facilities. Attached is a concept plan prepared for site 479, but we note that there is no encouragement within the current policy framework for these types of site. It is anticipated that these comments will be carried forward as being well founded, and that you will seriously consider: a) the allocation of specific community sites, and b) a criteria based policy that supports edge of settlement sites as opposed to remote sites. If you feel that a discussion meeting would be useful we would be more than happy to meet with your officers.
SCDC Response: 20 Comments on site specific issues noted
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES Bacton Gospel Hall Trust (Mr Respondent Name: Alistair Bush) [563] Submission Agent Respondent ID: 563 ID: 563 ID: SUBMISSION These comments are made on behalf of Bacton Gospel Hall Trust, but are equally relevant to all Brethren Gospel Hall Trusts around Ipswich within the Suffolk Coastal District Council area. Bacton GHT has been actively engaged in the LDF process with SCDC and specifically promotes the delivery of Places Of Worship, Meeting Halls, Faith Schools and Burial Grounds as essential elements of the community service infrastructure provision. Please find attached my letter of representation dated 17th October 2006. In reply to this, Mr S Brown (ref SB/BMM/10.5, also attached) acknowledged the relevance of such provision, and that the current local Plan states that such will be supported, subject to conformity with other policies of the plan. The Trust accepts that whilst there can be no discrimination in terms of specific religions and denominations, the key point is that if specific allocations are not made within the LDF framework, these facilities will find it very hard to compete for site acquisitions in terms of land value. If the 2000 proposed houses were to be taken forward as a single land use allocation, the whole site will fetch land values far in excess of community service facilities which operate mostly as charities. There needs to be a requirement to deliver a defined element of land use for such mix of uses. It is not practical 'on the ground ' to just provide a positive tone when mentioning community services. The RSS already does this to a certain extent, so the LDF should translate that down to delivery at the local level. Cont'd Page 2 This is not happening at present, and most Gospel Hall Trusts following the need for a new site or building are taking in excess of five years to navigate the planning process. It is accepted that in terms of general location, the facilities should be constructed within a town or village. However, most settlement boundaries are drawn so tightly to existing buildings, that few sites are available, and being within the settlement boundary means most landowners will similarly expect residential land values as redevelopment for housing is thus accepted in principle by PPS3 and local policies usually as brown field residential developments. The problem with the current approach of non-site allocation, is that it provides nothing between settlement and outside, as referred to in the previous letter - "Anything outside must be considered as an exception to local and national policy, for the countryside is to be protected for its own sake." This approach provides no real support or certainty for example where sites are immediately adjacent to settlement boundaries or in urban fringe areas rather than remote locations. A site immediately adjacent an existing settlement boundary can be delivered with the following positive benefits: * The absence of policy support for housing creates a more reasonable land value for a church, school or hall to proceed * The site is well located to the housing catchment area * There will be access by walking, and by public transport links in and out of the settlement * Creates the opportunity for complimentary enhancements to visual appearance and landscaping on the approach to existing settlements It is therefore suggested that a policy is considered that provides support and opportunity for these types of site to come forward without having to cross all the exceptional hurdles of the current position. To explain and highlight these comments, it is fair and reasonable to foretell a vacuum occurring in the LDF in relation to Ipswich, east of the A12. The Trust has identified a need here for the past five years but no settlement sites have become either available, or been viable. This means that many pre-application enquiries are not supported because of the exception to local and national policy. If 2000 houses are proposed as an expansion of Martlesham there will be an increase in the need for community facilities, including meeting halls, places of worship, faith schools and burial grounds which will not be able to compete with residential land values. However, suitable fringe sites are available and these need more positive policy support to be delivered. Site 479 in the SHLAA for example is immediately between the existing village settlement and the A12. It is green field, but also forms part of a buffer to the edge of the village. Cont'd
Page 3 A gospel hall is characterized by a single building and car park within a well landscaped area, in contrast to housing which delivers increased density of buildings and hard surfacing. The Trust would therefore request that a marker is set down for this site to be allocated for community use in the forthcoming allocations work, which will be complementary to the growth at Martlesham which we do support in principle. The landowner is amenable to a non-residential zoning, and would not be resistant to this happening. The growth of housing does require a range of facilities and indeed the location of a gospel hall tends to foster its own congregation, whereby families can specifically move into the area, and thereby become within walking distance of such facilities. Attached is a concept plan prepared for site 479, but we note that there is no encouragement within the current policy framework for these types of site. It is anticipated that these comments will be carried forward as being well founded, and that you will seriously consider: a) the allocation of specific community sites, and b) a criteria based policy that supports edge of settlement sites as opposed to remote sites. If you feel that a discussion meeting would be useful we would be more than happy to meet with your officers.
SCDC Response: 20 Comments on site specific issues noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Bernard and Christine Plant Respondent Name: [549] Submission Agent Respondent ID: 549 ID: 549 ID: SUBMISSION Dear Sirs, We wish to object most strongly to the proposed Ipswich Eastern Fringe (Martlesham Heath) development as outlined in the LDF evidence based study (Appendix 1). The level of evidence in the report seems woefully inadequate, it being mainly based upon a combination of hope and guesswork. Generally we feel that the scale of the development would totally swamp our area and ruin what is a pleasant place to live at the moment. Of the total need for housing stock estimated at 7700 units before 2025 , almost one third is proposed for a relatively small site east of the A12. We note with concern that no mention is made of the affect on the A12 which is already full to capacity at certain times of the day, and carries a heavy load of traffic at all times. If, as proposed, 2000 units are built with the basic level of one car per household, this will add further strain to the already overloaded road structure, and that is without considering the resultant pollution and environmental consequences.
To place our comments/objections in the same order as the headings in the document I would make the following comments:- Education: The numbers are hopelessly vague and funding seems to be expected from the developer and 'through other mechanisms' without giving the reader any clear idea that the matter has been seriously considered and thought through.
Police: the document speaks ominously of an increase in crime - we have previously enjoyed a relatively crime free area here in Martlesham Heath but we are expected to accept these high density units and 'an anticipated increase in crime' into our locality with, apparently, 'no specific investment'. Again the developer seems to be responsible for funding any investment which is eventually deemed necessary.
Health: This begins 'there is very limited capacity to existing healthcare surgeries' but follows with the need generated by this explosion of new housing would be met by 'expansion of existing facilities'. Have the local healthcare facilities agreed to this expansion or is that a wish list like so much of this document? You may be aware that Ipswich Hospital runs at something near capacity most of the time so an influx of this size would put further strain on facilities to the detriment of the existing population.
Fire service: No increase in the existing set up - is this believable considering there are an extra 2000 housing units - have the Fire Service agreed that this additional burden can be undertaken?
Telecommunications: We would refute absolutely that the existing infrastructure is sufficient to deliver current demand. What exactly does it mean that 'if issues of priority arise with regard to hi-speed internet access priority should be given to employment areas' - does this mean that the residential population in the area will be disadvantaged? Hi speed internet is already a problem in the area and unless you intend to provide booster facilities the provision for the present and proposed population will be unworkable.
General: In addition to all this, under 5.17 you state that the development will provide 'a stand alone community well related to a range of employment uses' or variously described as 'well related to existing and new jobs'. This seems to indicate that the proposers of this scheme imagine that a surfeit of jobs exist in this area. This is not so. The big employer - BT - is not expanding at the moment, quite the reverse and there are no other significant employers in the vicinity. If people are expected to travel longer distances to work this increases the traffic flow significantly putting strain on the roads as mentioned above. You apparently consider that the increased housing numbers proposed (raised from 1050 to 2000) will 'provide the opportunity to introduce wider community benefits' - how precisely this is achieved when the schools and facilities proposed are designed only to accommodate the population which will move into these housing units is difficult to understand. Highways can apparently be created 'without causing unacceptable disturbance to the area - yet I understand the A12 would need redevelopment to take the increased traffic flow and other infrastructure could hardly be provided without excessive disturbance to a quiet residential area as it is at present. I also understand a bridge is proposed across the A12 into what is now Martlesham Heath and if this is the case how does the 'stand alone' principal of the newly proposed development exist? The open spaces on Martlesham Heath were carefully and considerately planned to benefit the existing community, any further burden on them would cause over-trafficking and environmental damage. We wish our objections to this ill-advised scheme to be taken into consideration and if these comments need to be received in an alternative format please let us know.
SCDC Response: 7, 13, 16, 17, 19, 20
THE OVERALL STRATEGY
Respondent Name: Betsy Reid [569] Submission Agent Respondent ID: 569 ID: 569 ID: SUBMISSION Response on Updated Preferred Option 07.09 - objection and general comment. Also some comment on Sustainability Appraisal and Appropriate Assessment.
Summary The revised housing numbers, as the original 1050, lead to the wrong kind of development in the wrong place. This semi-rural location buffering the OANB ought to be either farm-land or low-land heath. Housing would result in insupportable pressure on the surrounding villages, the honey-pots recreational facilities of Newbourne, Waldringfield and Woodbridge, schooling especially secondary, traffic and policing. The necessary development (harmful in terms of its global warming potential) and 'mitigation' - said to be financed by the developer but only viable for that increased number - would be un-necessary if there was dispersed allocation of the RSS minimum of 1050.
Detail of objection * The revised housing figures are for 2,000 new homes at Martlesham. If I maintained, as in my letters of protest against the former figure, that 1050 houses in this position was wrong for a variety or reasons detailed below, then 2000 must by definition be nearly twice as harmful. * Any possibility of making Martlesham an integrated village with these new houses comes up against the insuperable obstacles of the physical barriers: the A 12 and the retail site around Tescos. * A variety of extra services would need to be provided: e.g police and waste treatment - it seems that developer contributions might be sought to fund these, but it looks unlikely if BT is the developer that, even with the profits from the development, BT will be in a position to fund all the infrastructure needed, given the currently parlous state of its finances. * The Council seems to be inconsistent in promoting a strategy of development east of the A12 at Martlesham in a single location forming a new community, but adopting a dispersed strategy for development in Felixstowe/Walton/Trimley (Section 5.17) This is not in accordance with the responses to the previous consultation - which consultations were anyway unclear, given that one option was withdrawn in the second consultation. (see NANT web-site about Section 5.12) * It should surely be possible to meet the RSS required minimum of 1,050 homes by dispersing them in villages as above. This would ensure that those villages which have already seen considerable investment (often by SCDC) in their facilities e.g. village halls and schools (Waldringfield school has an expensive new wing added just last year) remain viable, and possibly smaller villages become more so. The Housing Distribution document points out that the previously the Council thought 1390 house sites in dispersed locations would be available (NB from a large number of villages). This has been reduced by 540: the 780 needed go a good way to filling the 950 extra houses at the Martlesham site. And see below for related thoughts on the Sustainability Appraisal. * Even the RSS figures may be subject to amendment in April 2010 when the revised figures, taking into account the houses actually built since the previous figures in 2007, and those for which planning permission has been granted are published. * You maintain that the 2000 houses proposed would be of sufficient size to provide a relatively self contained community including a measure of health, primary education and a district centre type facility, with in time, a good sense of place. At the same time you seem to imply that the new community would grow together with Martlesham: these two things cannot both be true. A new development here would swamp Martlesham which has taken twenty years or more to learn to be an integrated community comprising Old Martlesham and Martlesham Heath - thus showing the difficulties of integration across a major road. * Of course more houses need 'a significantly improved range of community facilities': I can see that the argument you are trying to make is one of economies of scale. However the benefits of additional housing and the services they would bring with them would outweigh the disbenefits for example in relation to traffic impacts, further sapping of facilities from surrounding local villages etc of the larger allocation - indeed as previously argued, any allocation at all. It is the size of the settlement which creates the problems which you then need the developer money to solve. Please look at the recent government report which concludes that regeneration of dwindling villages IS sustainable - by keeping village facilities intact and building on the 'sense of place' which is a function of real and useful social and economic links between people and thereby reducing the need to drive everywhere. Life in villages is also likely to provide less liklihood for crime (see above on unclear funding for extra policing and creating problems that you then need extra money to solve) and to be more sustainable. Today's Independent front-page on the liklihood of 6 degree warming should make you think hard about the kinds of settlements you foster: re-localisation as more people work directly in food production on the land, rather than in processing, transport and retail of so-called value-added foodstuffs makes enhancing the vitality of existing villages crucial. * You quote the provision of an additional secondary school in particular as one of the parts of additional infrastructure. Forgive my skepticism: there is already pressure on the secondary schools (Kesgrave, for instance is too full to accommodate as before all the children from Waldringfield). This needs to be addressed now, rather than waiting until 2015 or thereabouts and as the number of houses is too small to provide all the children for a secondary school (I believe that needs 3,500 housese) there is likely to be considerable delay if we wait for it to be provided on a BT site. (And here let me add that please do not think I would therefore be in favour of the extra housing it is thought BT would apply for if this current application goes through!) * On the need to 'mitigate potential impact of visitors and residents on the neighbouring countryside and estuary' - provision of the RSS housing in dispersed villages would obviate that need. Living in Waldringfield I know that pressure on our river fore-shore is already greater than desirable - no mitigation measures can say a footfall is not a footfall to the plants or a figure on a footpath is not a figure on a footpath to a nesting bird. Please look again at the excellent letter from the Waldringfield Wildlife Group, of which I am one of the founder members. And also at the Church Field letter - I am also a member of the Church Field Trust. * You imply that the lie of the land and its landscape value is so little as to be able to be discounted. This ignores the subtle beauty of this open landscape and the vital function of this particular land as a buffer to the AONB. You also point out that mineral extraction will continue - true, but the land is to be restored to its prior condition on completion - ie either lowland heath or improved farm-land - both vitally important as biodiversity / agricultural area and carbon sink. * You say that 'doubling the numbers of new houses at Martlesham provides the impetus/opportunity to create a stand-alone community which is of a scale to trigger the need for wider community benefits.... and improved public transport provision'. The plan put forward by BT (and the fit between the BT plan, and the timing of the consultations and submissions for planning permission etc make it look very likely that this is what you have in mind - especially (Section 7.02) as the area specified for development is exactly the area owned by BT) is certainly not one that is promoting less car-use - it has huge boulevards and endless car- parking space. * You say that the larger number of houses will also 'increase the amount of developer contribution available to pay for necessary infrastructure'. Part of the necessary infrastructure would be very considerable amendments and augmentations to the road system. I believe impacts on the traffic across the Orwell Bridge have not been sufficiently considered - but also see below: * You imply that employment will be found around the area - at the BT site or in the Martlesham retail area: given how few people who live locally now work locally this cannot be taken as given: it is not any more likely than people in dispersed villages finding employment locally. A significant number of people will, of course, find work within the community, servicing it - but surely it is better that they work within smaller more local communities where they live, running shops, schools, Post Offices, and small businesses there? Currently one of the things that makes rural villages feel left behind and unviable is that there are few businesses there. Also we are just at the point, after twenty years of predicting it, that home working is really starting to take off - fewer people should need to live right beside their work. Both these factors point to dispersed housing with less need to provide enhanced infrastructure - which would surely be sensible both in view of the current and likely continuing financial insecurity and, most cogently, of the need to reduce building activity because of its impact on the global climate. * The number of houses for the site necessitates some very urban looking buildings - five or six storey apartments. While concentrating housing in this way on a reduced footprint is in environmental terms a good thing, its impact in terms of visual intrusion and light pollution would be extremely negative in this semi-rural location. Please look again at the CPRE 'tranquility map' for how rare areas which are both quiet and dark are in the South East - we should not further erode any that have these qualities. * A new settlement 70% the size of Woodbridge could not but adversely affect the 'sense of place' of this charming market town - it would be both swamped and sapped by such local competition for and of provision. As a member of Transition Woodbridge, working with others (and indeed recently the beneficiary of Transition training paid for by SCDC!) to enhance and foster local resilience in the face of the twin challenges of climate change and peak oil, I would like to point out that Woodbridge would survive much better with just its allocation of the necessary housing. * I am concerned about the social housing: I understand that it is often difficult to persuade villages to accept more social housing - but the new development does not specify how much there would be - the implication is not very much. And if a lot then concentrating it in one settlement is likely to bring problems too. * Section 2.4 Why is there no mention of the East of Ipswich area being near an OANB when in the very next paragraph is it mentioned with regard to Felixtowe? * Sustainability Assessment: I am interested that nowhere in this document's Objectives does 'to safeguard, enhance and re-build carbon sinks' get a look-in. Surely you are sadly behind the times? (see 'the Carbon Fields' by Graham Harvey as a recent popular - in the sense of for the lay-man - contribution to this thinking.) * Sustainability assessment 'Building on a number of sites has the advantage of allowing individual communities to grow at a rate which is more readily into the existing social fabric' - Policy SP21 - if this is true for Felixtowe, why is it not true for Martlesham - especially as the desirability of this policy was expressed in the two previous consultations. Similarly 'disperses the potential negative effect of major new build thus limiting the impact' on single community in the same paragraph; as also ' Incremental development is more likely to retain the setting of the town in the countryside' - a major development so close to Woodbridge would drown it in traffic noise - hardly a country setting! In conclusion I do not consider the revised figures to be either justified or to better meet the broad strategy for development in the district. I am grateful for the work done by our Parish Council (please see their excellent response) and by NANT: the latter has been most helpful in summarizing many of your documents
SCDC Response: 4, 5, 7, 8, 9, 12, 13, 15, 16, 17, 20
LOCAL SERVICE CENTRES Bredfield Parish Council (Mr Respondent Name: G.H. Hurst) [71] Submission Agent Respondent ID: 71 ID: 71 ID: SUBMISSION Dear Sirs,
(REG 25) CONSULTATION ON SUFFOLK COASTAL LOCAL DEVELOPMENT FRAMEWORK (LDF): CORE STRATEGY: PROPOSED CHANGES TO HOUSING DISTRIBUTION.
I refer to your letter of 23 September 2009 regarding the above matter. I wish to comment on the proposals under this document with particular reference to the village of Bredfield and the items designated 521, 780a, 780b, 780c, 780d, 780e, 804 & 931. Under current and previous plans, these areas are outside the Physical Limits Boundary of the village and are protected from development under Policy AP8, Countryside Protection. There have been numerous attempts in the past to circumvent this and previous policies which have been declined, even on appeal. It would be incongruous and inconsistent to include these areas for development now, since the criteria for previous refusals has not changed. Bredfield is a village which already suffers from excess traffic particularly HGV traffic. I have complained to you on a number of occasions about this traffic along the U3415 Ufford Road, which is oppressive, damaging and positively dangerous. To add to this with construction traffic, increased residential and service traffic and the traffic associated with Holiday Homes would be ridiculous not to say irresponsible. Two of the areas under the proposal, namely 521 and 804, abut or straddle Byng brook. These areas are, therefore, low lying and are prone to become waterlogged for significant periods of the year. My own garden, which is not as low lying as these areas, becomes waterlogged trying to drain above and over them. Byng brook has flooded its banks into these areas on a number of occasions in recent years with damaging affect to adjacent properties. Development on these areas would not only be detrimental to the developments themselves but would exacerbate the already poor drainage in the village. This has been a bone of contention over a hundred years. Given the current range of developments and the likely course of activity in the Suffolk Coastal District Council area, there can be no possible requirement for development in Bredfield, outside the present Physical Limits Boundary, under the current or future policy strategy or any exception criteria. With respect to the proposal under item 804, the proposer of this development has recently purchased another piece of land in Ufford Road, opposite his current proposal and also abutting Byng brook. The price paid for this land was out of all proportion to its value as either agricultural or accommodation land. It can only have been priced with development potential in mind. The purchaser is a property developer and chairman of a local political association. The party of this association has a preponderance of members on Suffolk Coastal District Council planning committee.
SCDC Response: Noted
OTHER VILLAGES AND THE COUNTRYSIDE Bromeswell Parish Council (Mrs Respondent Name: Margaret Cutts) [55] Submission Agent Respondent ID: 55 ID: 55 ID: SUBMISSION 1) Ref area East of A12 (BT site):- An irrevocable and detailed commitment must be made for the following (i) new secondary school (Kesgrave High is full) (ii) new primary (iii) sports centre (iv) Detailed and advanced enhancement to the environmental buffer zone with SPECIAL COMMITMENT on funding. 2) Woodbridge. Para 7.05 of "Housing Distribution - update preferred option 7/09" indicates an intention to allocate some greenfield land for housing. Comments (i):- The Secondary School at Woodbridge is bursting at the seams on capacity - therefore any increase in housing needs to be accompanied by a detailed specific and generous commitment to extra secondary school funding. (ii) Residential land in Woodbridge area is at a premium. Very large financial gains would be available to property developers and associated individuals if greenfield residential development took place. Such allocation is not a need but a commercial pot of gold. Therefore any such policy should be subjected to detailed and transparent scrutiny. 3) Bromeswell:- Settlement Hierarchy remains rightly located in the "Other Villages" category. There is no need or local desire for either infilling or Sire Specific Allocation. See para (2) (i) + (ii) above in relation to Woodbridge.
SCDC Response: 17, 20, 27
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Bucklesham Parish Council (Mrs Respondent Name: Cindy Hilton) [427] Submission Agent Respondent ID: 427 ID: 427 ID: SUBMISSION Consultation on Suffolk Coastal Local Development Framework and Core Stratergy: Proposed Changes to Housing Distribution.
On behalf of Bucklesham Parish Council I write to express the residents concerns over the proposed changes. The changes proposed reflect a reallocation in the main from Felixstowe to Martlesham, the impact on our community therefore remains the same!!!! The volume of dwellings in total surrounding our Parish is still in excess of what we believe to be acceptable.
We are concerned about Education Utilities Medical facilities Environmental Pressure Light Pollution, etc.
We have major concerns over Traffic Congestion at the Seven Hills Interchange, The Orwell Bridge, and the old Martlesham to Felixstowe Road through Brightwell. It is our belief that the proposed volume of dwellings will damage our Rural Environment and will eventually erode the boundaries between Kirton-Bucklesham- Martlesham and Purdis making our village a small part of a huge urban conobation not dissimilar to Kesgrave. We need your absolute assurances that above factors have been carefully considered and would welcome your feedback accordingly. We would furthermore wish to comment on the "Settlement Hierachy", making the point that Bucklesham be reappraised and changed to the level of "Other Villages" we have:
No Post Office No Shops No Employment opportunities As such we are a community /settlement with "Few or Minimal Facilities"
We look forward to your response with interest.
SCDC Response: 12, 13, 18, 19, 20
IPSWICH POLICY AREA Bucklesham Road Area Residents Asssociatione (Mr Respondent Name: Graham Balfe) [353] Submission Agent Respondent ID: 353 ID: 353 ID: SUBMISSION To ensure that a new community is development with all necessary infrastructure which is not available elsewhere
SCDC Response: Noted
LOCAL SERVICE CENTRES Byways Bicycles (Mrs Suzanne Respondent Name: Bloomfield) [62] Submission Agent Respondent ID: 62 ID: 62 ID: SUBMISSION We understand that the Council is reconsidering the location of its future housing allocations and also exploring the possibilities of promoting some villages from Local Service Centres to Key Service Centres. Therefore we are taking this opportunity to request that Darsham be up graded to a Key Service Centre.
Darsham - Situated on the A12 - Has very good local facilities.
* Well established successful and sustainable businesses. These include a grocery provision store and newsagent, two farm shops, a garage, restaurants, a pub, several tourist enterprises, a nursing home, haulage companies, storage facilities, tile and bathroom centre, cycle centre, pottery, garden centre to name just a few. This in turn has led to:-
* Increased employment opportunities for local people.
Other facilities include:-
* Public transport to local market towns and beyond i.e. Ipswich and London There is good provision either by train from Darsham Station where trains for Lowestoft and London via Ipswich pass through Darsham during the day at about two hourly intervals. The bus service is frequent to various local destinations and pick up points are spread around the village.
Primary School Yoxford Primary School is the local catchment school. Transport is already in place to take children to the school. This arrangement has been in place for over 35 years well before the days of local plans. Places are available at the school. Educational needs are being met.
* Community Centre Darsham Village Hall has been recently refurbished however the wooden structure requires considerable on going maintenance. The Village Hall Committee are at present in discussion with land owners with the view to relocating this facility and rebuilding a new hall to meet the needs of the community. As you will see from previous correspondence we have offered land for this purpose.
* Post Office Darsham is well served by Post Offices both at Westlton and Yoxford. Larger Post Offices at Leiston and Saxmundham are reached by regular public transport. With the closure of rural post offices during the last few years it is unlikely that Darham would be allowed a Post Office today with such good facilities so close.
* Medical Services Several highly trained first aiders are resident in the village. They are part of local emergency Responders Team and are notified by the emergency services in the event of an emergency. The local church has a Parish Nurse who is available to help any Darsham resident with welfare issues particularly during illness and infirmity. Three local G.P Surgeries from Leiston, Saxmundham and Halesworth cover Darsham. All are accessible by public transport. Halesworth and Aldeburgh Hospitals offer respite care and emergency first aid facilities as well as physiotherapy X rays and visits from consultants plus many other services.
People want to live in Darsham.
Affordable property coming onto the market in the village has sold quickly during the last few months. This indicates a strong market potential for new properties of the right quality and price. Property East of the A12 is always in demand due to its close proximity to the Heritage Coast. In fact demand outstrips supply across all types of accommodation.
Darsham has earned the right to be promoted to a Key Service Centre
Darsham has evolved into a Key Service Centre. The official upgrading of our village to acknowledge this fact would ensure Darsham's development potential was not compromised or unfairly restricted in future.
We hope the Council will give this request very serious consideration. We look forward to hearing from you in due course.
SCDC Response: 27
2 THE CONSULTATION IN BRIEF
Respondent Name: C Cushing [454] Submission Agent Respondent ID: 454 ID: 454 ID: SUBMISSION I object to the core strategy in its entirity as it affects Felixstowe, Walton and the Trimleys. Apart from a small number of affordable homes for local needs, the rest should be distributed across the district to minimise infrastructure costs and maximise sustainability of smaller communities. 2009.
SCDC Response: 4, 22
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Candy Johnson [198] Submission Agent Respondent ID: 198 ID: 198 ID: SUBMISSION Dear Sirs
I feel very strongly against building "Adastral Town" where there currently grow crops. We face a rapidly expanding population and long term planning should urgently address the ability of our country to be self sufficient in food. I am aware that there are many reasons of sustainability on which to object to this proposal but I will leave it to others to comment on the inadequacy of the planned changes to local infrastructure to cope with the influx of population. I am desperately sad that the legacy left for our children by poorly conceived planning will be not of open fields and peace and quiet but traffic jams, pollution and noise. By allowing development like this you are destroying the very reason why people want to live in the area. Housing needs are best met by allowing small villages to have an extra couple of houses, making village schools and bus routs viable. Run down areas could benefit from redevelopment. If housing is so desperately short surely the issue of second home ownership should be addressed before allowing the rape of the countryside.
SCDC Response: 4, 15, 16
THE MARKET TOWNS Capital Associates Respondent Name: (Development) Ltd [171] Submission Agent Mr Brendan Respondent ID: 171 ID: 171 ID: Hodges SUBMISSION We support in principle the increase in the number of dwellings proposed for the market towns. We consider that substantial new allocations will need to be made in the market towns (including Saxmundham) to accommodate existing needs, and the new needs arising from nuclear development at Sizewell. Part of the Council's justification relates to the requirement for new housing for workers involved in the construction of new nuclear reactors at Sizewell. We understand from discussions with British Energy/EDF and Suffolk Coastal District Council Officers that construction of new reactors is anticipated to commence in 2012 - 13, with employment for up to 10,000 workers (5,000 per reactor), a large proportion of whom will not already be living locally and will need to be housed in the district. Therefore, in order that accommodation for workers can be ready for the commencement of construction at Sizewell, allocations for Leiston and Saxmundham will need to be capable of delivery within the first five years (2010-2015) or before, rather than in the third phase (2020-2025). Substantial allocations shall be made in Saxmundham and other market towns as necessary (including greenfield) to meet both the existing needs and the needs arising from nuclear development at Sizewell within the first five years (2010-2015).
SCDC Response: Noted
HOUSING DISTRIBUTION FELIXSTOWE/WALTON AND TRIMLEY VILLAGES
Respondent Name: Captain Nigel Palmer [33] Submission Agent Respondent ID: 33 ID: 33 ID: SUBMISSION Although an improvement on the original proposal the Felixstowe Peninsular is still being asked to accommodate too many houses for local needs. Felixstowe Dock will require less labour as it automates in the future, not more. Plans to diversify local employment are laudable, but are high risk as the town's location makes it difficult other than in the leisure area. Ipswich is the more logical location for business development. Some of the smaller outlying villages need to expand to remain viable. This would make more sense if housing does prove to be needed. Building on greenfield areas around Felixstowe will destroy what is left of its unique character. SCDC has a very poor record on protecting Felixstowe's character and infrastructure - apparantly preferring to protect the Market Towns. Rather than destroy the town further you should be looking to upgrade transport links between Felixstowe and Ipswich so that job development can take place on the large brownfield sites that still exist within Ipswich.
SCDC Response: 4, 12, 22, 24, 26
3 BACKGROUND
Respondent Name: Captain Nigel Palmer [33] Submission Agent Respondent ID: 33 ID: 33 ID: SUBMISSION You should be challenging the housing numbers imposed on SCDC as unrealistic and unecessary. This government seems to wish to concrete over large areas of the SE of England based on future growth projections that are not in the best interests of the area.
SCDC Response: 3
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES Cedarwood Primary School (Dr Respondent Name: M Rowe) [561] Submission Agent Respondent ID: 561 ID: 561 ID: SUBMISSION I am writing this submission on behalf of Cedarwood Primary School, Kesgrave, IP5 2ES.
Our concerns with relation to the suggested development under LDF is to seek assurance that the impact of such development throughout this area of SCDC is minimized and that planning is in place focusing upon the medium term where residential nos. haved not yet reached the trigger point for building of the new primary or secondary schools. Given the severe pressure our local schools are currently under in the Martlesham & Kesgrave how can the current capacity be seen as being able to cater of additional pupils derived from the any new site as houses become occupied but before a new school building project is initiated?
We would have additional concerns re: the increased traffic levels and the consequential impact of impeded flow along A1214 / A12 and off Grange Farm. Ultimately this could affect safety of pupils crossing Grange Farm to school.
SCDC Response: 13, 20
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Christine Fisher [431] Submission Agent Respondent ID: 431 ID: 431 ID: SUBMISSION Re: Proposed housing development of 2000 homes South and East of Adastral Park at Martlesham
I have lived and worked in the area as a landscape architect for 20 years and am Tree Warden for the Parish of Waldringfield.
Updated Preferred Option - OBJECT
Summary
The scale of this development is far too large for this area of small scattered villages and is completely alien to its landscape character (rolling estate sandlands). The A12 will inevitably divide the proposed housing from the existing community at Martlesham Heath. Once the special environment is lost there will be nothing to protect any longer and further development cannot be refused. More appropriate with high blocks of flats to peripheral London, it begs the question, what is the point of the SCDC landscape character report if there will be no notice taken of it as a planning guide?
The report makes the following statements: * The road, rail and other public transport networks should be capable of accommodating the traffic and journey requirements that new housing inevitably brings with it;
The report does not show how this might be done. Widening the A12 will make it more of a polluting barrier than at present (noise, lights, fumes) and the loss of the present banks of gorse would be inevitable. Traffic lights would make the road a disaster at peak times leading to rat -run behaviour along Newbourne Road which already happens, eroding the edges of the lanes and killing wildlife.
* New housing should allow integration with existing communities but at the same time should respect and maintain the character of individual settlements and communities;
It will be separated from Martlesham by the A14 and will swamp Waldringfield Heath which under the previous local plan was a hamlet safeguarded by no development being allowed at all.
The addition of 2000 houses partly within the existing parish boundary of the small village of Waldringfield (about 250 dwellings) can only change it irrevocably. Light pollution will destroy the valued dark skies which visitors always comment on. The road into Waldringfield finishes beside the river Deben and is a bottleneck frequently congested in the summer as many visitors are attracted to visit the pub, walk the coastal footpaths, and sail or swim from the beach. Although subject to dangerous tidal flow it is the only place between Woodbridge and Felixstowe where there is a small public launching pad and swimming is possible. The additional pressure on the small roads of the village and the disturbance to the rural environment by the arrival of larger numbers of cars, lights, dogwalkers and all the impacts of a small town would quite plainly urbanise the area so its rural character would be lost.
Waldringfield Heath situated on Newbourne Road proposal would become an edge of the new housing scheme. This hamlet has been protected by planning policy up until recent times from any development including infill housing . All the houses are on wells or bore holes, the water table being 20m below ground level.
* In deciding where new development should go, it should respect the quality of the local environment;
Instead of the quarry being returned to farmland or to heathland appropriate to the landscape character of the area, it will be turned into an urban development but isolated from any town, nothing like anything in the area or even in Woodbridge which is the nearest town. It will have a population two thirds the size of Woodbridge but without the abundance of facilities available there.
* Protection should be given to wildlife and to the landscape, particularly those areas that are designated as being of national and international importance
This is plainly not going to happen, see the Appropriate Assessment.
Appropriate Assessment - OBJECT
Summary
The appropriate assessment attempts to show that there will be insignificant effects on the international sites close to the proposed development. It does this by reference to inappropriate figures as regards population, the incorrect and selective extrapolation of data from survey work done by others for other purposes and by using contradictory and incorrect statements regarding the footpaths and parking places in the village of Waldringfield and its surroundings.
This document is seriously flawed. It makes assumptions based on inappropriate data. Quote: 5.3.7 Suffolk County Council has published an updated population projection based on the Regional Spatial Strategy allocations being built6. It suggests that for 9,400 new households in the period 2001 - 2021 that the population will rise by 8,500 people, which is a net increase of 0.9 people per new house. This reflects the currently ageing population (older people tend tolive singly or in pairs, rather than as families with children present) and an increase in secondhomes / holiday homes. The decline in the number of people per household is an important factor to take into account.
This document goes on to make predictions on the number of people who will occupy the 2000 houses based on 0.9 per person. However the above study does not apply to new purpose built housing a more reasonable figure, based on the actual planning application for the 2000 houses would be 2.4 per house. This gives a figure of about 4800 people in the 2000 houses. The appropriate assessment, by using 0.9 per house as a base for all its projections of visitor numbers, cannot in any way reach a credible conclusion. EERA figures are about 2.2 per house.
The following figures are extracted from table 3:
The estimated numerical increase in population for new housing. Kesgrave and Martlesham wards houses people 2,640 2376
2640 made up as follows: SCDC Core strategy - 420 outstanding planning permissions at 2008, 220 dwellings urban potential, 2000 new allocations to 2025
Therefore nearly 300 of the houses are predicted to be empty!
Existing population of the area (Ipswich policy area in Suffolk Coastal) 20,014 people
An additional 2376 people if the figure above is correct gives an increase in population of 11.9% BUT if the true figure is 4800 people, plus only 1 per household for the others, this gives 5440 new people or a population increase of 27% in the policy area.
This shows that the attempt of this document to quantify the population increase and make meaningful comments is a complete failure.
The document next uses a 'snapshot study' of visitor numbers over the whole of the Suffolk Coasts and Heaths AONB to achieve a prediction based on the above erroneous figures, of an extra 2.48% visitors being likely to visit although it does point out that this will vary - more of them visiting the Deben Estuary perhaps than a random field without any particular attraction?
The predicted general increase of visitors to European sites across the area is not necessarily a uniform increase to all sites. It is likely that European sites close to new development (i.e. within walking distance or a short cycle ride, bus trip or drive away) is likely to be used as local greenspace, with activities such as recreational dog walking or play undertaken
6.2.34 It therefore cannot be ascertained that an allocation of 2000 new dwellings at Martlesham will have no adverse affect upon the integrity of Deben Estuary SPA near Martlesham, given the current level of detail available within the Core Strategy and Development Management Policies.
The document goes on to quote a single piece of 'evidence' to support the opposite conclusion, that there will be no significant impact. This evidence comes from a study carried out in East Dorset. However an examination of this study shows that it does not in fact show anything of the sort.
The Dorset Study (reported May 2009)
A study was carried out by Footprint Ecology for East Dorset District Council. The following are taken from it:
'....previous studies had shown a clear link between the development of new housing and the increased use of heathland open spaces for recreation by residents. The effect has been shown to be significant for housing developments up to 5km. distant from the heaths. The cumulative impact of small developments is seen as being significant as well as the individual impact of larger developments.
...on the basis of these findings, it was concluded that where the heathlands were protected under the Habitats Regulations these would require that new housing developments within the 5km. distance would need to be subject to an Appropriate Assessment. This would be likely to conclude that the development could not be allowed unless adequate measures to neutralise the impact on the heathlands were provided.
...The planning authorities,jointly commissioned a further study to investigate the use of greenspace by residents and to help in making proposals for new greenspaces which would mitigate the impact on heathlands. ....The study took the form of a household survey carried out by Footprint Ecology, a firm of consultants who have specialised knowledge of heathland issues and the Dorset Heaths in particular.
'The most critical conclusion is that there appears to be only a slender relationship between the amount of existing alternative greenspace nearby and the amount of heathland visits.' end of quote.
This undermines the concept of mitigating for pressure on the important wildlife site by providing alternative green space. It appears that the attraction of the heathland perceived as a wild open place where dogs could be let off leads compensated for the distance people had to travel to get there. The study also showed that people living nearer to the coast tended to use the Heathland less. This merely underlines the attractiveness of the coast, which in our case at Waldringfield means the estuary. People will put up with walking a bit farther and having difficulty parking in order to access the coast and other wild places. The importance that the Appropriate Assessment places on findings that most visitors to the Heath had come less than one kilometre, or 8 km if they came by car, is undermined by the comparison of the different scenarios. We do not know what proportion of the visitors had other green spaces, or the coast, to compete with the Heath. We do know that at Waldringfield the Deben Estuary is the most popular place for a walk - it is where we always take our visitors!
Appropriate Assessment: 'At the present state of knowledge it is not possible to be certain that the increase of visitors would not result in an increase of disturbance or trampling damage to qualifying features on estuarine / coastal sites.'
The above is certainly true and the 'Dorset Study' does nothing to show that there not be severe disturbance as a result of a huge increase in population.
Car parking: The report seems divided within itself on whether there is car parking at Waldringfield as such, but comes to the cheerful conclusion that because there isn't any, the 4800 people up the road (or 1900 in their interpretation) will not visit the popular beach and pub, walk along the river with their dogs or launch their jet skis from the slipway. In fact there are a number of spots with limited parking opportunities which can anticipate being stretched to breaking point.
Mitigation Quote: 7.3.1 It is considered that, if the mitigation in sections 7.1 and 7.2 is implemented to suitable standards, the impacts of additional housing provisions in Policy SP2 and related policies, alone or in combination with provision in the Ipswich Borough Core Strategy and Policies, will be reduced to an insignificant level. It is ascertained that, with the proposed mitigation, Policy SP2 and related housing policies will have no adverse effect upon the integrity of any European site.
Mitigation in this document takes two forms: increased wardening and the provision of alternative green space in a country park.The Foxhall Tip is due to close 2019 with country park, if permitted finished by 2021. But will it compete significantly with the Deben Estuary as a recreational venue? No study quoted shows anything positive on this . The wardening of SSSI sites might be helpful in some areas but people cannot be restricted from using public footpaths. Do the writers of the report think there is anything approaching wardening of the Deben Estuary at present? The public footpaths are there for all to use The Appropriate Assessment contradicts itself quite a lot. Having made statements that there is insufficient information, state of knowledge, need more data etc. , it finishes by saying there will be insignificant or no detrimental effects on the SPA as though it had proved something, which it hasn't. This is plainly an insufficient basis on which to base a strategy for development.In fact it is a tragic betrayal of our national heritage.
SCDC Response: 9, 13, 16, 17, 18, 19
IPSWICH POLICY AREA
Respondent Name: Clare Parkinson [411] Submission Agent Respondent ID: 411 ID: 411 ID: SUBMISSION I am writing in regards to the proposed planning application by British Telecom (BT) on the outskirts of Waldringfield Heath. I understand that BT are intending to get permission for 2000 houses on an area of land which is in very close proximity to the Wetland site of the Deben Estuary Special Protection Area. Having been a lifelong occupant of Waldringfield I am very sad to hear that Suffolk County Council are considering this proposal which will devastate local wildlife and change the local landscape forever. I fully understand that more houses are needed, especially in an area such as Suffolk which is underpopulated in contrast with other areas in Britain. However, I do not feel that new houses should be built at the expense of a protected landscape, as well as an existing community. This settlement will require more schools, new roads and a new infrastructure, changing the landscape for ever, never being able to return to the area of rare beauty which will be sorely missed in years to come. Although steps I'm sure will be taken in order to preserve the wildlife and natural habitat, there is an extremely sensitive balance for the wildlife in this area which is very unlikely to survive this radical influx of people, roads, cars etc that is proposed. I hope that you will take into account the long term effects of this proposed building scheme on the surrounding countryside on balance with the short term benefits.
SCDC Response: 16, 17, 20
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Colin Maunder [115] Submission Agent Respondent ID: 115 ID: 115 ID: SUBMISSION In 5.10, you say: "New housing should allow integration with existing communities but at the same time should respect and maintain the character of individual settlements and communities".
It is unclear how the number of homes to be built adjacent to Adastral Park can be achieved if the objective is to maintain the character of existing settlements and communities. The Martlesham Heath development, which attracted considerable national acclaim, is a new take on a traditional Suffolk village. To fit 2000+ homes into the space next to Adastral Park, a much more urban development will be required.
SCDC Response: 16
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Colin Maunder [115] Submission Agent Respondent ID: 115 ID: 115 ID: SUBMISSION Under Telecommunications, you say: "Existing infrastructure is sufficient to deliver current demand."
Broadband access speeds at Martlesham Heath are significantly below the maximum possible, largely because of the distances to the nearest exchange (in Kesgrave). The government has specified that everyone should be able to receive broadband at at least 2mbps by 2012 - a target that will only be met at Martlesham Heath if services are significantly upgraded. On this basis, the above statement is clearly false.
SCDC Response: 20
THE OVERALL STRATEGY
Respondent Name: Colin Maunder [115] Submission Agent Respondent ID: 115 ID: 115 ID: SUBMISSION The impact of the decision by NHS East of England to move treatment of victims of severe heart attacks from Ipswich to Basildon, Cambridge and Norwich is not mentioned or considered.
Made after housing allocations were handed down to local authorities, this suggests that the allocations should be reconsidered.
If emergency services are to be provided only in those locations, the 'joined up' answer must surely be to encourage people to live close to them, not somewhere sufficiently remote from the treatment centres that people's chances of survival are put at risk.
SCDC Response: 20
THE OVERALL STRATEGY
Respondent Name: Colin Maunder [115] Submission Agent Respondent ID: 115 ID: 115 ID: SUBMISSION You say: "New housing in the Ipswich Policy Area - East of the A12 to be increased in order to create a large development there with an emphasis on it being a community with sufficient supporting infrastructure. The location for such a community remains at Martlesham although the location is specified as to south and east of Adastral Park."
The specification of a location is a significant change, especially as it aligns the LDF with BT's proposals for development on the land it owns adjacent to its Adastral Park campus. The change excludes the construction of houses on land surrounded by existing developments - the field between Tesco and the Black Tiles, for example.
The consequences of such a large development - one much larger than that at Martlesham Heath and significant relative to the size of Woodbridge - appear from the text not to have been considered. The Route 66 bus service is good, for example, but takes over half an hour to get into Ipswich from Martlesham Heath. Drivers using Foxall Road and the A1214 experience long delays at peak periods - delays that cannot easily be cut. There are few, if any, options to widen the roads along their entire route; the number of intersections that has to be crossed cannot easily be reduced; and Suffolk County Council has proposed closing the main route to Ipswich's business district, the university campus and the station by limiting access to and from Back Hamlet.
With regard to sustainability, an underused railway serves Old Martlesham and Woodbridge. It would be much easier to provide the 'low carbon' travel options we'll all need in the future if development were centred there or elsewhere along the line through Bealings.
SCDC Response: 11, 13, 16
5 HOW HAS THE HOUSING DISTRIBUTION BEEN DRAWN UP? AND HOW AND WHY HAS IT CHANGED?
Respondent Name: Colin Maunder [115] Submission Agent Respondent ID: 115 ID: 115 ID: SUBMISSION Under 5.17, you say: "The area East of the A12 was chosen as the Preferred Option as offering the best all round solution to meeting the objectives set out above, creating a stand-alone community but well related to a range of employment uses, the primary road network, public transport and other facilities and having the least impact on other individual communities."
The area will only be "well related to a range of employment uses" if BT commits to expanding the workforce it has based at Adastral Park (those currently employed there already have places to live) and the vision of attracting other firms to set up on the campus comes to pass. Based on current trends in the IT and communications industries, neither of these eventualities is likely.
Assuming the plan to build 2,000 homes adjacent to Adastral Park goes ahead, somewhere in the region of 3,000 new jobs must be created (assuming that more than one person per household works and that the rationale of locating homes close to places of employment holds).
In addition, the most likely eventuality is that job creation and housing construction will not proceed in lock step. If jobs are created first, they will be filled by people who have to travel in. (This is what happened when BT first moved to Adastral Park, before Martlesham Heath was built.) If houses are built first, those living there will have to travel further afield for work.
SCDC Response: 7 Other comments noted
3 BACKGROUND
Respondent Name: Colin Maunder [115] Respondent ID: 115 Submission 115 Agent ID: ID: SUBMISSION 3.02 - bullet 4 "It acknowledges the wider economic role that the Port of Felixstowe and BT research and development at Martlesham Heath play both nationally and within the Haven Gateway sub-region." It is an unfortunate fact that BT has been winding down the research work it does at Martlesham Heath for several years. This echoes trends elsewhere in the communications and IT industries: R&D work in these areas has been moving to Asia. The LDF needs to be based on an accurate and up-to-date understanding of BT's intentions regarding the number of staff it employs in the Ipswich area. Staff have been moved in to Adastral Park from offices in Ipswich and Felixstowe, for example, which may well amount to a reduction in employment overall. In addition, BT is a big advocate of home working. More than 10 per cent of its staff work from home - a factor that has helped the company close a number of office premises. 3.05 "Inevitably, for a plan such as this, not everyone will be happy with what is proposed." While this statement is clearly accurate, the phrasing of this sentence implies that most people are happy. Looking at the feedback from the first round of consultation, it appears that most who expressed a view were unhappy about the proposal for development adjacent to Adastral Park.
SCDC Response: 7
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Colin Maunder [115] Submission Agent Respondent ID: 115 ID: 115 ID: SUBMISSION On Page 7, Policy SP20, Assessment summary, it says the area adjacent to Adastral Park is: "Considered in site specific assessment as the worst site for congestion and environmental impacts"
The suggestion here is that this bleak assessment is offset by the plan to develop new employment opportunities at Adastral Park. However, for this to be the case, the people who move into the new development would have to be those who take the new jobs. While some may value living so close to their work, many will not - negating the 'offset'.
In particular, it must be noted that those who already work at Adastral Park already have places to live. It is unlikely that many will move closer to work, so the 'offset' will be achieved only if new jobs are created to employ the development's new residents.
SCDC Response: 7
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Colin Maunder [115] Submission Agent Respondent ID: 115 ID: 115 ID: SUBMISSION On Page 6, Policy SP20, Objective 5, it says: "Upgrade public transport, foot and cycle paths. Good access to town centre."
While such initiatives are to be applauded, none guarantees that people will leave their cars behind and use alternative options instead. The journey from Martlesham Heath to Ipswich by Route 66 bus already takes more than 30 minutes off peak. The effects of congestion on the bus service are significant. At times of day when buses should arrive every 15 minutes, it is not unusual for two or three to come along within a few minutes of each other.
The cost of the service is a further issue, especially in comparison to local Park & Ride fares. Compared to the cost of equivalent journeys in London, fares are extortionate. Those who currently commute to Ipswich by bicycle tell me their journey times are significantly shorter than they would be by bus, but these fit and hardy individuals are the exception. While cycle routes extend to Kesgrave and from Ipswich Hospital into town, there is a significant gap in between. Cyclists either have to use the A1214 or Foxall Road, neither of which is 'cyclist friendly'.
It addition, it must also be born in mind that relatively few of the places where people might work are in central Ipswich or accessible by public transport from Martlesham Heath. The inevitability is that people will drive to and from work.
SCDC Response: 7, 11
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT?
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION 4.02 It is difficult to reconcile this statement with that elsewhere saying the reason for the doubling of the allocation for the Adastral area is to create "a self-contained community".
SCDC Response: 16
THE MARKET TOWNS
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION It is possible now to identify Sizewell as the government has this month identified this as a preferred site for a new nuclear power station. This means that the allocation for Leiston and Saxmundham can now be increased.
SCDC Response: 4
IPSWICH POLICY AREA
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION Why is the David Lock Associates' plan for Felixstowe/Trimley made such play of in 7.04 and elsewhere but the David Lock Associates' plan for the area East and South of Adastral Park (commissioned by BT) and their subsequent submissions not similarly acknowledged here and throughout this report.
SCDC Response: A study that the Council has not been involved in would not be used as part of its evidence base.
IPSWICH POLICY AREA
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION "Integrate the development into the remainder of the Martlesham community" seems at odds with the reasoning elsewhere about the the Adastral Park development needing to increase in size so as to be "self- contained".
SCDC Response: 16
THE OVERALL STRATEGY
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION The "Major Centres" share goes up from 48% to 52% despite the sharp reduction in the number accorded to the Felixstowe/Trimley development. The sole purpose of this seems to be to enable an increase in the allocation for Ipswich Policy Area to precisely match the number of dwellings already applied for in BT's planning application for the site East and South of Adastral Park. Who is leading the development strategy here?
SCDC Response: 4, 15, 22
BASE REQUIREMENTS
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION If the LDF restored the windfall figure back to the previously proposed 1,320, or even went higher, this would give the council the go-ahead to approve a sufficient number of the flood of planning applications that would be brought forward. The market would respond! This would allow the consideration of developments in a smaller scale and in their local context. Communities would grow more organically and happily as a result.
SCDC Response: Noted
MARKET TOWNS - INCREASE PROVISION FROM THIS SOURCE
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION It is sensible to increase provison here to make the existing communities and their facilities more sustainable. Indeed further increases beyod those suggested should be manageable - and indeed, as the age structure changes, desirable..
SCDC Response: 4
SMALL WINDFALL PROVISION - REDUCE PROVISION FROM THIS SOURCE
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION There is an enormous reduction here: from 1,320 in your 12/08 housing distribution to only 540 in the present proposal. This decrease of 780 compares with the 950 house increase for the Ipswich Policy area. An organic development such as now in part conceded for the Felixtowe area should be extended by reinstating the larger number for small windfall development so that smaller scale, more sustainable development can take place, both within the Ipswich policy area and more generally.
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION The previous proposal of 1050 homes in one lump in this area was already too great - such homes would be better dispersed. The argument about increased size justifying increased infrastructure is completely circular. The landscape argument used here is specious as the quarried area is due to be returned to greenfield and this creates a landscape opportunity - particularly for restoring heathland which is a threatened resource both locally and nationally. The repeated mentions of dog walking betrays the shallowness of argument. "The impact of 2,000 homes, as opposed to 1,000....is limited" shows a fundamental lack of mathematical awareness.
SCDC Response: 4, 16
THE UPDATED PREFERRED OPTION REPORT JULY 2009
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION The council do not seem to have realised that doubling the number of new houses at Adastral Park made a huge difference to their proposals and their impact on the local area which is why it was only at the last moment and under the threat of legal consequences that this further round of consultation was conceded.
SCDC Response: Noted
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION What would effectively be a small town with a population of 5-7,000 in area 4 east of the A12 would have an enormous impact on the surrounding communities. What criteria of "acceptability" does the Council use? Who is making this judgment and where do they live? The Council should not ride roughshod over the views of those who will be hugely affected by the development?
SCDC Response: 16
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY?
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION Re 5.12 Each round of consultation has brought "more and more comments" - why have they not been heeded? It should be noted that the area to the South and East of Adastral Park is NOT a brownfield site and that current workers at Adastral Park do NOT choose to live in the immediate area - 3% in one estimate up to 12% in Adastral's travel plan (see their website as of today(.
SCDC Response: 11, 16
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION The proposal to place 2000 houses at Martlesham shows scant respect to wildlife,landscape and the local environment in general. The character of existing communities and settlements will be destroyed as they are swamped by the coming of another 5,000 or more people to their immediate area.
SCDC Response: 16, 17
STEP 1-THE SETTLEMENT HIERARCHY
Respondent Name: Colin Reid [333] Respondent ID: 333 Submission 333 Agent ID: ID: SUBMISSION From 5.07, 5.08 and Appendix 5 Table 1, we see in the amendments to the settlement hierarchy the effect of recent developments (e.g post office closure)in leading to the demotion of 7 villages against the upgrading of 1, with 1 new village created. This "hollowing-out" of the countryside should be countered by a different LDF to disperse development making village communities more sustainable in the long term. A large 2000 house,6000 resident development at Adastral Park will sap the vitality of nearby villages - will for example the outreach post office and small primary school at Waldringfield survive?
SCDC Response: 4, 27 Other comments noted.
3 BACKGROUND
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION Para 3.02: As energy prices rise the trend towards declining household size is likely to slow and probably reverse. Since the East of England Plan 2008 was completed the recession has led to a slowdown at Felixstowe, an increase in local unemployment and a reduction in immigration. The East of England plan needs revision. In November 2009 BT announced that it will cut jobs nationally by 15,000 by March 2010. How can a huge Martlesham development right up to the very edge of the AONB not threaten the world- class countryside so close at hand?
SCDC Response: 9
2 THE CONSULTATION IN BRIEF
Respondent Name: Colin Reid [333] Submission Agent Respondent ID: 333 ID: 333 ID: SUBMISSION 2.02 I do not understand how the changes in housing distribtution can be seen as a response to concerns raised in the earlier phase of consultation when there was such a number and range of objections to the siting of a smaller number (1050) of homes in the Adastral Park area.
SCDC Response: 1
THE MARKET TOWNS Cretingham, Monewden & Hoo Parish Council (Mrs Carol Smy) Respondent Name: [75] Submission Agent Respondent ID: 75 ID: 75 ID: SUBMISSION In response to the invitation to comment on the above Cretingham, Monewden & Hoo Parish Council wishes to record its concern at the prospect of over development in market towns such as Framlingham thus destroying their ethos. This is seem as particularly important when Framlingham is constantly voted such a delightful place to live...this is because it retains the character and charm of a quintessentially English market town. There is, already, a lot of new housing here and any more would destroy it. The same applies elsewhere.
There is insufficient infrastructure to support more properties in many villages in the SCDC area. Without good roads, adequate school places and services such as drainage able to cope with an increase in population growth is a recipe for disaster.
SCDC Response: 27
KEY SERVICE CENTRES Darsham Parish Council (Mr Respondent Name: Roger Coates Smith) [466] Submission Agent Respondent ID: 466 ID: 466 ID: SUBMISSION Some members of Darsham Parish Council which once again second their objection to Darsham being placed in "the Local Service Area" category. They feel Darsham should be listed as a Key Service area. Even though Darshan does not have a school, P.O, surgery, it does have many other facilities particularly within the employment category. There are appox. 150 persons employed either full or part time within the parish boundaries; it is primarily this fact which on which an objection is placed.
SCDC Response: 27
THE OVERALL STRATEGY David Houchell Ltd (Mr David Respondent Name: Houchell) [409] Submission Agent Respondent ID: 409 ID: 409 ID: SUBMISSION We note the need for 7,710 new homes by 2025 (around 450 per annum) Of these: 1780 have already been approved 1040 could be an urban brownfield site this leaves 4890. Of the 4890, 270 are already outstanding. We therefore need to create 4620 new plots by 2025. Do we really want 3,000 of these concentrated at Felixstowe and Martlesham? This will put a tremendous strain on our already congested road system. I also note there is spare capacity of gas! Great news, but for how long. We need to be more long sited. Small towns and villages are being neglected and becoming less viable due to planning policies over the years. I would like to see the major development allocations slashed by at least 20% and more small developments in key service centres, local service centres and other villages. Spread the development more thinly, avoid congestion, address more green issues of sustainable development with more emphasis away from the use of fossil fuels. Encourage more car sharing, local working and family values. We need to think outside the box, take note of the problems and resolve the issues that exist. Lets learn our lesson from Ipswich! Do we want more congested roads, piles of flats and poor neighbourhoods where no-one knows their neighbour! Its time to put some life into our smaller towns and villages.
SCDC Response: 4, 11, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: David Lock Associates [433] Submission Agent Mr Lawrence Respondent ID: 433 ID: 433 ID: Revill SUBMISSION HOUSING DISTRIBUTION - UPDATED PREFERRED OPTION 7/09
We welcome the opportunity to comment on the content of Suffolk Coastal District Council's Housing Distribution - Updated Preferred Option 7/09 document on behalf of BT. On a general level the revised housing distribution strategy is endorsed, however BT wishes to make the following detailed comments.
Para 7.02 and 7.03 - Ipswich Policy Area
BT supports the housing distribution strategy for the Ipswich Policy Area as set out in section 7. BT has submitted a planning application for the development of land east and south of Adastral Park which aligns with this emerging policy.
The overarching vision for Adastral Park includes:
* A regenerated Adastral Park to bring together BT, other technology companies and universities to develop new services and technologies
* An Innovation Park that will encourage and support new and developing businesses in the ICT sector located close to BT's operations
* Strengthening the role of Adastral Park as a major local employer through the creation of around 2000 new jobs, in addition to the 4000 jobs currently on site.
* A new residential community in a sustainable location that is properly integrated with existing communities and with employment and other services
* Providing opportunities for learning and education
* A richer mix of facilities and services for the communities of the Martlesham area as a whole, accessible to all
* An overall energy and sustainability strategy that minimises the adverse impact of the project on climate change, in a way that no other development site in the area can match
Table 1 - Housing Numbers
BT supports the increased allocation in the Ipswich Policy Area from 1050 to 2000 homes. BT wants diversify the businesses located near its research centre to build on the economic engine that delivers high salary, high skill jobs into the local economy. BT then sees huge benefit in creating new homes close to these new jobs so that people have a wider choice in the local housing market to live very near to job opportunities in high quality, energy efficient and sustainable homes. This will be part of the attraction for talented people to carry out research here, for BT and for other companies.
The aim is for a development that can swallow its own smoke. This size of development is necessary to support a range of local services to reduce the impact and reliance on existing communities and infrastructure but also to enrich the choice of services and facilities to those communities, including:
* A new primary school and appropriate provision for secondary schooling. A collection of houses without a school is just a housing estate. It has no heart, and has reduced potential to develop as a true community. A primary school creates a key focus for a community: the houses will attract families with children; the children will develop friendship groups that initiate social cohesion; pre-school and nursery groups will spring up as school feeders; the primary school will feed into enhanced local secondary provision; teachers and support staff will move in; local shops and community facilities will be supported by a working community, a residential community and a community attracted by the schools; and the school itself acts as a community centre. Economies of scale mean that the optimum size for a new primary school is two-form entry with 420 places. The threshold to support a new two-form entry school is 1800 to 2000 households. * Health and welfare services such as doctors, dentists. * Significant public open space. * Community facilities such as a meeting hall and; * A local centre with a small retail presence meeting local need.
Providing land for fewer than 2000 dwellings in any one location, here or elsewhere, constrains the range and viability of the social infrastructure that can be provided. For example, it means a new primary school might not be deliverable which would affect its synergetic relationship with other community facilities. The external pressure on existing infrastructure of a lesser development would be significant and in all areas there are local capacity issues.
Para 7.01 - Base Requirements
The reduction in the reliance on windfalls from 1,320 to 540 dwellings is supported. Though there is a record of historic delivery from windfalls this is unreliable and Government guidance is that it should not be extrapolated forward to be relied upon as a significant proportion of future supply. It is inevitable that the opportunities for infill development will decrease in time as the supply of such sites is exhausted.
Para 3.02 and Para 5.12 Criterion 4 - Economic Impact
The spatial strategy for the location of housing in the district cannot be divorced from other land uses which are required to be located close to housing to lessen the need to travel and to create sustainable places. It is recognised that the location of existing employment sites has influenced the preferred option; however, it is suggested that greater emphasis should be placed on the need to locate housing close to expanding or new employment sites.
Suffolk Coastal District is obliged to make proposals to satisfy the Regional Spatial Strategy requirement for 8000 new jobs in the period 2001-2021 in addition to the 13,600 jobs that are likely to have to be replaced during the period 2001-2021. Adastral Park can assist in achieving this requirement, in a way that no other single site in the District can.
BT's contribution to the regional economy is in excess of £800M every year spent through Adastral Park , which currently employs around 4000 people, most directly by BT. Regeneration of Adastral Park could provide capacity for the creation of an additional 2000 jobs as part of a sustainable community. Furthermore, Innovation Martlesham is a high-tech business cluster which has already led to around ten new companies setting up at Adastral Park.
Para 5.17 & pages 11 - 12 - Stand-alone community
At various points in the document reference is made to the ability of 2,000 homes to create a "stand-alone community" East of Ipswich. Though the reasoning for the use of this term is understandable it is perhaps misleading.
Development of land south and east of Adastral Park is of a size and scale capable of providing the infrastructure to deal with many of the day-to-day social, environmental and infrastructure demands that it creates. A strategy of dispersed housing would not be able to do this and would be reliant on existing facilities and services across the District, some of which may already be at or near capacity. However, it is not BT's intention that the development of 2,000 homes would be isolated from other communities in its context. A key driver in BT's vision is the integration of the existing Adastral Park employment focus more fully into the area, taking down the perimeter fence and linking it and its facilities to the existing communities of Martlesham and Martlesham Heath. In the same way it is envisaged that the proposed housing, and the associated facilities that are also proposed (including parkland and other open space, an education campus, community facilities and local centre) would be available to the residents of new housing but also existing residents in the wider local area.
Secondary Schooling
Section 6 suggests that doubling the number of new houses at Martlesham triggers "the need for wider community benefits, particularly a secondary school". It is not yet clear that the development alone requires a full secondary school and there are other solutions, including an annexe for the existing Kesgrave School, that could deal with additional pupil numbers that arise from the development. Although there may be the potential to provide for secondary school provision at Adastral Park, new development cannot be obliged to resolve existing capacity deficiencies in secondary education in the wider area.
Housing Delivery
SCDC's Five Year Housing Land Supply shows a deficit of some 200 dwellings to 2014 within the Ipswich Policy Area. Land at Adastral Park can accommodate this requirement within this timeframe. A number of locations within the current planning application site are suitable and capable of delivering the homes.
The infrastructure constraints identified in the Roger Tym study are relevant to all land within the IPA. The development of 2,000 homes at Adastral Park is considered to be more likely to be able to resolve infrastructure issues, rather than through a dispersed strategy. Locating the early release of 200 dwellings elsewhere within the IPA will increase pressure on infrastructure with no scope to alleviate it. As such, the early release of 200 homes at Adastral Park can be delivered with certainty that infrastructure issues will be met given the scale of the wider development proposed.
We trust that the above comments are clear. Please call should you require further information.
SCDC Response: Noted
THE OVERALL STRATEGY
Respondent Name: DDP (Elaine Connolly) [558] Submission Agent Respondent ID: 558 ID: 558 ID: SUBMISSION We write with regard to the above current round of LDF consultation. Our representation is made further to earlier responses made on behalf of Notcutts Ltd to emerging LDF documents - Preferred Options for the Core Strategy and Issues and Options for your Site Allocations Document. We stand by these earlier comments as valid in respect of the sites promoted.
In terms of the current consideration of the bigger picture of housing distribution, we make the following general comments:
* It is noted that the housing targets remain at 7,710No. new dwellings to 2025 (minimum), with 4,080No. new units to be on newly allocated land. Full regard should therefore be had to promoted sites in all settlements shown to be deliverable;
* We support the phasing of development to prioritise Brownfield land. However, in the interests of deliverability, sites should not be bound by rigid restrictions if proved supportive of sustainable housing objectives;
* We generally support the concentration of development at the major centres, market towns and larger villages. However, we would express concern at the demotion of Ufford to a 'Local Service Centre'. This implies that no land would be allocated for development going forward beyond windfall development. The settlement is sustainably located near the A12, benefitting significantly as a result in terms of accessibility. Reliance on windfall will not ensure coordinated and sustainable growth in such a location. Its demotion should therefore be reviewed;
* We support the emphasis on sustainability and accessibility in considering the location of new housing sites. These are critical considerations and where a site can be shown to be sustainable and accessible for housing, it's allocation shouldbe carefully considered.
We recognise that the current consultation document is non-site specific. However, we are aware from our attendance at the recent SHLAA Stakeholder Workshop event in September that the Council do not currently view our client's sites with favour. We can, and have, shown them to be deliverable sites for housing. They would contribute to sustainable housing development and fit with the Council's objectives for housing delivery going forward, such that we would urge a review of preliminary assessments.
It is important therefore that the following points should again be noted: 1. Land at and surrounding Woodbridge Town Football Club
* The site is located in the Market Town of Woodbridge, considered a high order settlement and favoured for growth; * It has been promoted as a long-standing housing site with the principle of its redevelopment for housing generally acceptable subject to the identification of suitable, alternative grounds for the Club. We have identified such a site east of the A12 at Ufford. This site is capable of accommodating the needs of the Club and is highly accessible. Progress is being made towards securing this alternate venue for the Club and it remains a committed and deliverable site for the Club. As such, the deliverability of the existing grounds for housing remains supportable; * Access considerations for residential development will not be an issue. In fact, trip generations would be staggered as opposed to concentrated for its current use, meaning access and movement via existing estate roads is acceptable; * The site is accessible and well-connected to the town centre and surrounding centres. It is adjacent existing residential development and as such, can easily be integrated into existing communities. * Its redevelopment for housing would present a significant environment enhancement through the removal of flood-lighting from a prominent site; * The site can provide significant housing (both market and affordable), and is capable of being delivered in the short-medium term.
2. Land east of A12, Ufford * This site, as mentioned, is promoted for mixed-use incorporating alternate grounds for Woodbridge Town FC as well as proposed housing and leisure uses. The site can capably meet the needs of the Club as a viable venture and its relocation to this location is achievable in the short-term (5 years); * Whilst we do not support the demotion of Ufford to a Local Service Centre, a proposal of this scale is still deliverable and to be considered on economic and sustainability principles; * The site is highly accessible via the A12 and presents a significantly important prospect for sustainable mixed development anchored by new Club grounds.
3. Nursery land west of Yarmouth Road, Ufford * Whilst this site is promoted for employment development, in view of the proposed demotion of Ufford, the potential to lose such a site through failure to allocateshould be reconsidered; * The site is subject to long-standing promotion for commercial/employment use and is appropriate for same; * It is well-connected to Ufford and via the A12 to surrounding settlements; * Prior discussions with Officers support its redevelopment for employment uses; * It is not hindered by physical constraint and is deliverable within 5No. years.
4. Land west of Hurtshall Park, along the River Fromus and land opposite Park Farm Bungalow, South Entrance and North Kiln Lane, Saxmundham * This site clearly supports the Council's objectives for sustainable and accessible housing land - it is well-connected to the settlement (a Market Town and focus for growth), is suitable and deliverable for housing; * The site is not constrained physically, other than the need to have regard to matters of flooding, fully addressable via appropriate mitigation; * Housing development can be promoted on the northern part, with the remainder of the site given over to a landscape buffer, thus protecting the rural character; * The deliverability of the Council's preferred site to the east of the settlement still hangs in the balance; * Its allocation for housing would contribute favourably to the settlement's housing capacity in an orderly and sustainable manner. We trust the above is acceptable. We are of course happy to discuss any of the above with your Officers in seeking to secure the best and most sustainable pattern of future growth for the District.
SCDC Response: 27 Other comments noted IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Deborah Branch [524] Respondent ID: 524 Submission 524 Agent ID: ID: SUBMISSION Dear Sir,
I write to register my comments regarding the development applications for new homes at Adastral Park and in other areas in Martlesham.
I object strongly to the amount of new homes that are proposed on the following grounds:-
1. It is absolutely obvious that the road system in this area is already up to capacity as can easily be seen during rush hour times around Martlesham and on the main roads into Ipswich during the early evening.
2. The local rural area will be unable to sustain the number of additional people that this amount of properties will bring to this part of Suffolk. The natural environment will be threatened until it cannot be enjoyed by original local residents or the new residents living in the development.
3. There are no local jobs for the new residents of the development. BT is reducing numbers - I know this for a fact as my husband works there. As any jobs will be away from Adastral Park then even more cars will be using the roads into Ipswich.
I suggest that small pockets of the necessary housing (although I am not sure necessary for who exactly) are placed around Suffolk so that the impact is on each community is minimal and can be integrated into the existing villages.
SCDC Response: 4, 7, 13, 17, 19
1 INTRODUCTION Dennington Parish Council (Mrs Respondent Name: Shirley Cunningham) [521] Submission Agent Respondent ID: 521 ID: 521 ID: SUBMISSION Dennington Parish Council has considered the new Housing Distribution proposals. Councillors agreed that they had no further comments to add.
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Dr Alan House [334] Submission Agent Respondent ID: 334 ID: 334 ID: SUBMISSION Dear Sirs, I have to object to the proposals to build a new town on the Adastral park site. The resulting congestion will be be a disaster for the many sensitive sites in the area. The local villages and hamlets in the area will be greatly affected and their individuality compromised. The utility services such as water will be severely stretched as will the health, education and fire services. Please allow more time for proper consultation to occur and public meetings to take place. Development on this scale is entirely inappropriate on this site and will compromise the life of local residents, the local wildlife, and the tranquility of the river Deben and its surroundings
SCDC Response: 19, 17 20
8 YOUR COMMENTS
Respondent Name: Dr Bernard Priestley [389] Submission Agent Respondent ID: 389 ID: 389 ID: SUBMISSION Proposed numbers of houses will be far to dense.
Why has strategic plan been changed to dump all these houses on Martlesham.
The planning of Martlesham Heath was based on the idea of low desity housing
A12 needs to be diverted from Martlesham Heath and not run straight through the middle. Already too noisy and too busy.
This revised plan is a disgrace ingnoring previous comments from Martlesham Heath residents.
SCDC Response: 13, 16
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Dr Bruce Boxall [510] Submission Agent Respondent ID: 510 ID: 510 ID: SUBMISSION Housing Distribution - Updated Preferred Option 7/09 - Consultation
Summary I strongly object because: the scope of the consultation has been changed during the consultation, the scale of growth in jobs in the rural and coastal areas has not been adequately considered, the infrastructure investment requirements for A12 East have been understated and alternative cost-efficient alternatives not presented for consideration, that due diligence regarding the number of houses required to provide developer funding for infrastructure in A12 East has not been undertaken leading to a flawed proposal, that the A12 East proposal constrict access from the wider district to acute healthcare facilities, that the A12 East proposal prejudices strategic transport options, that the impact of any housing proposed in A12 East option will significantly degrade the quality of life in the surrounding areas.
In responding to the consultation on the updated Preferred Option 7/09 I strongly object to the proposals because:
Citizens have not had a clear view of the scope of the consultation and the consultation is therefore not aligned to the intended democratic process.
The public have not been provided with a clear view of the scope of the consultation since the Council has changed the scope of the consultation during the consultation period without making citizens aware nor allowing more time for the consultation. Paragraph 8.02 indicates that the consultation is very focussed and seeking views on the updated preferred option 7/09 housing distribution. However the NoAdastralNewTown group has indicated from dialogue with the Council that " the Head of Planning has agreed that comments will also be accepted on other documents which have been issued since the last consultation"
The balance of identified job growth in the plan does not fit with the forecastable needs and leads to a distortion in the profile of identified housing needs within the District.
The plan refers to growth in housing and jobs going hand-in-hand and makes reference to economic activities associated with Felixstowe/Haven Gateway and BT research and development at Martlesham Heath. However the proposals do not give proportionate consideration to growth in jobs associated with caring for an elderly population in the coastal and rural areas (significantly older than the national demographic average in the coastal and rural areas). Ensuring support for care of the elderly should be a key responsibility of the LDF by indicating significant housing to provide a responsive and environmentally friendly (low and green miles) service to people in the District. The fact that caring and support jobs may not be manufacturing jobs is not the point. These jobs will exist and housing to support is not adequately identified for these activities in the current proposals. This will increase the barriers to supporting the ageing population in the coastal and rural areas. It also leads to an unnecessarily larger numbers of houses being required in the East Ipswich and Felixstowe/Trimley areas to meet the RSS targets.
Scale of development required to meet Infrastructure Requirements is understated in the proposal East of A12 and evidence is not provided to indicate that infrastructure funding will be met without further allocation of land for development
The original proposal was for 1050 houses and this has now been increased in the LDF proposal to more than 2000 to meet RSS targets and provide scale such that developer funded infrastructure can be put in place. BT's proposals are presently for as many as 3400 houses. The proposal for East of A12 set in a disconnected rural environment creates an need for massive infrastructure both to create sufficient scale to require central amenities and schools but also to generate developer funds to support investment in new infrastructure. The phrase 'standalone' is misleading since there will be a need and a demand to access facilities in Martlesham Heath and Ipswich. Landowner proposed plans indicate a second pedestrian/cycle bridge crossing the A12. The traffic from this will put unplanned pressure on small scale paths which are part of the designed character of Martlesham Heath Village and likely to put pressure on woodland paths, adjacent SSSI and similar amenities within Martlesham Heath Village.
The proposal is only 'standalone' in concept. The original plans for the area of 1050 houses are now not considered credible in terms of infrastructure and investment by the council but the currently proposed increase to larger numbers only creates a greater need for infrastructure funding which in turn drives an increase in planned housing allocations to support the investment. Given the lack of identified infrastructure funds (correctly identified by the Council in the response CAB 67/09 to the recent RSS consultation) the development will need to be scoped to encompass further land in Waldringfield, Brightwell and Martlesham to generate the developer funds. Hence the objection is that the council has not undertaken the required due diligence to demonstrate that the infrastructure costs can be met from committed public and additional developer funding at the level of housing allocation outlined in the proposal. The likelihood is that analysis had been undertaken the consultation would have needed to have considered a much greater number of housing allocations to generate the funding. This makes the current consultation a second 'red herring' on the journey to a much larger and increasingly disruptive development. In adopting this approach citizens are not being given an holistic view of the inevitable outcome of this choice of location. Given that infrastructure investment will be such a significant factor in the total costs of the provision of houses on this scale, the current consultation should be abandoned and the public should be subsequently consulted on a range of options to meet the RSS targets in the area and the estimated cost per unit in related infrastructure costs in these new proposals.
The A12 East Proposals pose a serious risk to the acute healthcare requirements of citizens in the District and adversely impact strategic transport options for the region
The current A12 East proposal will require major changes to the road infrastructure on the current A12. The additional traffic management and associated increased likelihood of congestion associated with the development will cause road users to experience longer journey times which in turn impede economic productivity.
These additional delays will also have a strategic impact on the delivery of acute healthcare services within the District. Referring to the Suffolk Coastal "Sustainability Appraisal of the Suffolk Coastal Local Development Framework Core Strategy - Preferred Options including Development Control Policies and Strategic Housing Locations also including Appropriate Assessment - screening & scoping December 2008" section 4 indicates that:
* By 2021, the number of people over 65 is expected to increase by 14,500, 31% of the overall population (the highest in the county), whilst the number of children under 16 will drop by 3,600 to just 13.9% (the lowest in the county).
* According to figures from 2005, Suffolk Coastal has the second highest mortality rate and death rate from circulatory diseases in Suffolk.
The consequence of this is that during the planned period, there will be an increasing number of people over 65 with a greater propensity to death from circulatory diseases. People needing rapid access to acute facilities will require to be treated by accessing facilities that are the other side of the Martlesham block on the A12 which formerly served as the arterial road for all critical healthcare facilities in the area. Increased journey times will mean increased mortality and increased impairment for those who survive. The consequences of this approach are both inhumane and costly in resources.
There are also implications for the national road network because the likely outcome of the current proposals are not considered at an appropriately strategic level. By making a tactical decision to deliver the current required increase in the number of houses in such a confined location, the broader options for alternative trunk routes from the major port of Felixstowe via a northern Ipswich bypass have been preempted. The resulting constraints on route diversity from Felixstowe across the Orwell Bridge in Ipswich should be of national concern.
Impact on Quality of Life
The East of A12 proposal is presented as being of minimal impact to the surrounding area. Highways 7 lanes wide, proposals for mixed use buildings six storeys high, are all indicative of a further stage in the urbanisation of a quiet rural area adjacent to an Area of Outstanding Natural Beauty. The inevitable wider growth outside the currently defined areas to support the deficiencies in the infrastructure planning process yields joined-up-housing rather than joined-up planning. In progressing the East A12 proposal the council has not sought to consider all possible routes to mitigate the negative impact on the quality of the environment within the District.
SCDC Response: 1, 7, 11, 12, 13, 16, 17, 20
IPSWICH POLICY AREA
Respondent Name: Dr Michael Hudson [266] Submission Agent Respondent ID: 266 ID: 266 ID: SUBMISSION If the plan were for a new village of the standard of Martlesham Heath, with acceptable levels of housing density and plenty of green araes, the plan would be more acceptable. The doubling of numbers to 2000, with high density housing, traffic problems, increased pollution and further away from the main centre of entertainment and leisure in Ipswich, is asking for trouble for the new residents and will certainly impinge negatively on the quality of life of current Martlesham Heath residents.
SCDC Response: 16, 17, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Dr Michael Hudson [266] Submission Agent Respondent ID: 266 ID: 266 ID: SUBMISSION The education proposal for a new secondary school does not make sense. The figure of 400 students from 2000 houses does not create a sustainable secondary school with 6th form. Farlingaye and Kesgrave, currently highly successful and having had substantial infrastucture investment, could be adversely affected by the creation of a new school. The most sustainable solution would be extra provision at Kesgrave, rather than a new school with insufficient numbers and second rate provision. Given the closure of a secondary school in Felixstowe, the opportunity for development in that area seems to be being missed.
SCDC Response: Noted
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Dr Michael Hudson [266] Submission Agent Respondent ID: 266 ID: 266 ID: SUBMISSION The area round Felixstowe is alraedy urbanised and the town would benefit from further investment so that it thrives all year round rather than be a satellite for Ipswich. The A14 problem will be exacerbated by any development in the east Ipswich area: reducing the Felixstowe development and moving it to Martlesham does not help the A14 traffic situation which is beginning to resemble the M25. When the Orwell Bridge is blocked the whole of Ipswich and the east is totally gridlocked in the current situation: to say the A14 can cope with growth is risible.
SCDC Response: 12
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Dr Michael Hudson [266] Submission Agent Respondent ID: 266 ID: 266 ID: SUBMISSION The additional housing plan at Adastral Park is presented as an objective data-led argument. There are no details about the political and financial context for the plan however. How far has the BT site argument been swayed by other factors that are not in the plan. What does BT get out of this plan? What benefits are there to Suffolk Coastal District Council? There are no benefits to local residents: more traffic, more litter, more pollution, a reduced countryside environment etc
SCDC Response: Noted The arguments for development of the site south and east of Adastral Park have been developed over a number of years and are as a result of a number of evidence base studies. All of the arguments for development of the site have been published in reports and minutes of meetings throughout the LDF process.
2 THE CONSULTATION IN BRIEF
Respondent Name: Dr Michael Hudson [266] Submission Agent Respondent ID: 266 ID: 266 ID: SUBMISSION When Felixstowe is a town in need of regeneration, like many seaside towns, I fail to understand why the number of houses planned in the Felixstowe area has been reduced and moved to Martlesham where it will ruin the small amount of countryside between Martlesham and the Deben, which is a sustainable leisure resource (ie walking without using the car etc) for local residents. Felixstowe needs more development, not least its secondary schools which are being amalgamated because they are not sustainable.
SCDC Response: 16, 22
2 THE CONSULTATION IN BRIEF
Respondent Name: Dr Michael Hudson [266] Submission Agent Respondent ID: 266 ID: 266 ID: SUBMISSION Access to making any comment on this diocument is extremely challenging and I wonder how many representations are excluded in this way.
I feel that the growth of the area has been extremely rapid in recent years and that we now need a respite to cope with the increase in housing and the large Tesco store which has made local traffic situation difficult. This basically rural village is being transformed into a suburban sprawl.
SCDC Response: 1, 18
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY?
Respondent Name: Dr Paul Hensel [93] Submission Agent Respondent ID: 93 ID: 93 ID: SUBMISSION Sirs
I believe that the redistribution of housing between the Felixstowe area and Martlesham (Adastral Park) is a very substantial change to the original proposals in the LDF which require much further consideration than is currently planned. Full public consultation should be re-opened before decisions are taken.
SCDC Response: 1. Please note that this was a full public consultation.
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Dr Paul Hensel [93] Submission Agent Respondent ID: 93 ID: 93 ID: SUBMISSION Sirs
We wish to object to the revised proposals for the development of land east of the A12 on the BT Adastral Park site in relation to the proposed educational facilities.
The document "Housing Distribution Updated Preferred Option 7/09" says on Page 12, paragraph 6, Conclusion that:
"Doubling the numbers of new houses at Martlesham provides the impetus/opportunity to create a stand alone community which is of a scale to trigger the need for wider community benefits, particularly a secondary school"
This statement is unfounded. Even the increased number of houses envisaged for the site east of the A12 falls well short of the number required to justify a new secondary school. 2000 new houses might generate between 150 and 200 pupils - roughly one fifth of the optimum number for a successful school. Changing the boundaries of the adjacent catchment areas will still not result in a viable roll without causing significant damage to the existing schools regardless of the proposed "discount" of 1500 houses suggested in the Buchanan report.
The absence of a stand-alone secondary school will deny the community the facilities expected to be available as a spin-off and lead to increased traffic on the A12 as residents and pupils are driven/drive to other schools, sports facilities etc.
Similarly, there is no justification for a primary school when there is spare capacity at Waldringfield and Bucklesham - unless, of course, either or both of those schools are closed with consequent damage to the villages concerned. Either way there will be increased traffic on local roads.
Summary in 100 words
The educational strategy for the proposed development on the BT site east of the A12 is fundamentally flawed. There is no justification for either a new primary or a new secondary school unless SCDC is prepared to jeopardise existing schools in the neighbourhood such as Farlingaye and Kesgrave High. The absence of schools, especially a secondary school, will result in the need for alternative provision of community facilities and increase pressure on the already overcrowded road network in the area.
SCDC Response: 13, 19, 20
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT?
Respondent Name: Dr Peter Chidgey [320] Submission Agent Respondent ID: 320 ID: 320 ID: SUBMISSION The level of housing proposed for Martlesham, East of A12, is inappropriate for the rural environment. This development, if allowed, will result in the Ipswich, Kesgrave, Grange Farm urban sprawl reaching ever closer to Waldringfield and Woodbridge. Why is it necessary to cross the natural barrier formed by the A12. Increased traffic movements will have a major impact on the local transport infrastructure and any proposals for cycle paths and pedestrain rat-runs may destroy the woods and heathland which are central to the village hamlet concept behind the award winning Martlesham Heath.
SCDC Response: 18, 19
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Dr Peter Chidgey [320] Submission Agent Respondent ID: 320 ID: 320 ID: SUBMISSION You are again arguing for a stand alone community for the area east of the A12 yet in section 7 you advocate integration. 2000+ homes will swamp and destroy the local semi-rural environment. The increase in housing density proposed will also further compromise the setting of scdeduled historical monuments identified by English Heritage (in particular M21267 and surrounding monuments and archaelogical features). The development will also place at risk the remaining military features from what is still a historic airfield.
SCDC Response: 18 Other comments noted
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Dr Peter Chidgey [320] Respondent ID: 320 Submission 320 Agent ID: ID: SUBMISSION In 5.10 you state that any new infrastructure should be provided in advance of or in parallel with new development - you do not however in section 7 mandate the developer to fund this infrastructure from the outset and therefore place at risk existing community resources. This developement will not respect and maintain the character of the current communities in Martlesham, Martlesham Heath and Waldringfield.
SCDC Response: 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Dr Peter Chidgey [320] Submission Agent Respondent ID: 320 ID: 320 ID: SUBMISSION You argue for a stand alone community for the eastern fringe Martlesham Heath development yet in section 7 you cite integration with the existing community. What is it to be? In the early phases the existing infrastrucure will be impossibly stretched whilst any developer avoids building schools, medical, power, waste water, shops, and community centres which you expect them to contribute to.
SCDC Response: 16, 20
IPSWICH POLICY AREA
Respondent Name: Dr Peter Chidgey [320] Submission Agent Respondent ID: 320 ID: 320 ID: SUBMISSION Integration of this development within the existing Martlesham community will be compromised by the sheer volume of dwellings currently proposed dwarfing the current development. The new community will be isolated by virtue of the main trunk road. Elsewhere in this document you argue that the development should be stand alone in order to achieve your sustainablity targets - this is surely contradictory?
SCDC Response: 16
APPENDIX 4 - BREAKDOWN OF UPDATED DISTRIBUTION STRATEGY
Respondent Name: Dr Peter Chidgey [320] Submission Agent Respondent ID: 320 ID: 320 ID: SUBMISSION The proposal to increase housing numbers from 1050 to 2000 in the eastern fringes of the IPA (Martlesham Heath) will result in a disproportionate community isolated from both the Martlesham and new Martlesham Heath settlements. This community will be isolated by the major trunk road and the proposed high rise multi-tenancy units will be out of keeping with the surrounding rural landscape. This is not a town centre.
SCDC Response: 16, 18
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Dr Peter Chidgey [320] Submission Agent Respondent ID: 320 ID: 320 ID: SUBMISSION The significant increase in housing volumes and phasing of the proposed residential build within the eastern fringes will place inappropriate strain on already stretched existing school, medical and transport infrastructure in the initial years. The supporting evidence offered does not propose to mandate any developer to provide any improvements to the local infrastructure. Acceptance of the proposed changes to the LDF should not use words such as "funding is likely to be sourced from developer contributions"
SCDC Response: 20
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: E J Southgate [79] Submission Agent Respondent ID: 79 ID: 79 ID: SUBMISSION I'm against 'Ribbon' development. With no more brown field sites left in the town where is the infrastructure for the thousands of new houses going to be built? Where are you going to build premises for this huge new workforce? remember 1,000 homes = 2,280 people = 2,000 more cars. Now by 2025 any and all new born babies will be wanting jobs & driving cars! Why not complete phase 1 of this enormous project i.e. sites 1 & 2. Then reappraise the situation with lessons learned from this exercise.
SCDC Response: 22, 25 Other comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS East of England Regional Assembly (Mr Paul Bryant) Respondent Name: [156] Submission Agent Respondent ID: 156 ID: 156 ID: SUBMISSION Subject: Suffolk Coastal District Council Core Strategy: Housing Distribution - Updated Preferred Option 7/09 Report by: Report by Regional Secretariat Purpose: To give a response to the Suffolk Coastal District Council's Core Strategy: Housing Distribution - Updated Preferred Option 7/09 consultation document. Recommendation: The Standing Committee is asked to consider the recommendation that Suffolk Coastal District Council's focused Core Strategy review does not give rise to any conformity issues.
1. Introduction 1.1 Suffolk Coastal District Council (SCDC) is consulting upon a focused review of its emerging Core Strategy's housing distribution policy. Whilst the number of new homes being planned (7,710 by 2025) remains unchanged, the Council is seeking to alter the distribution of new housing, most notably through an increase in that proposed to the east of the A12, at Martlesham, and a reduction in the amount of housing planned for the Felixstowe and Trimley areas. Other minor changes will affect some market towns and smaller settlements. 1.2 The closing date for comments is the 18th November 2009. Further details can be found on the Council's website at: http://www.suffolkcoastal.gov.uk/yourdistrict/planning/review/corestrategy/housing/default.htm 1.3 A map showing the relevant part of Suffolk Coastal District Council, neighbouring Local Authorities and the Ipswich Policy Area is included at Appendix A
2. Regional / Local Policy and background to this review
2.1 Regional planning guidance is set out in the East of England Plan (May 2008) (the 'Plan'). Policy H1 sets out minimum district housing provision targets from 2001 to 2021. Suffolk Coastal is expected to provide at least 10,200 new dwellings, a figure that includes about 3,200 homes expected to come forward as part of the Ipswich Policy Area (IPA) (see appendix A). Policy H1 also requires that local authorities plan for delivery of housing for at least 15 years from date of adoption of relevant development plan documents. 2.2 Suffolk Coastal's Core Strategy has reached the Preferred Options stage, having undergone public consultation during the winter of 2008/091. It is also anticipated that the Core Strategy will be adopted in 2010, and it therefore plans to 2025. 1 RPP-SC 2009-01-23 - Report on SCDC's Core Strategy Preferred Options document 2.4 The Core Strategy stated that the focus for housing growth will be towards the east of Ipswich and at Felixstowe, the Major Centres. In terms of distribution, the Preferred Option document allocated some 1,050 new dwellings to the Ipswich Policy Area and 2,260 to the Rest of the District (of which some 1,660 relate to the Felixstowe and Trimley Peninsula). The Core Strategy also stated (in para. 4.20) that Regional Policy is quite clear in terms of identifying a specific number of houses to be located within the IPA - a point that was corrected in the both the Assembly's formal response and in subsequent, communication, i.e. all H1 figures should be treated as minimums. 2.5 In brief, SCDC are now proposing that:
􀂃the IPA allocation be increased by 950 units to 2,000 (allocated at Martlesham);
􀂃that delivery at Felixstowe and the Trimleys be reduced by 650 units to 1,000 - and that delivery be phased with the first new homes restricted to previously developed land and, if necessary, one small-scale greenfield site, and
􀂃that there be changes to the amount of housing coming forward in the market towns (up from 400 to 870) and that anticipated from small windfall sites (down from 1,320 to 540).
3. Comments 3.1 As noted, regional housing figures should be treated as minimums. Regional policy also requires that housing, and other development, should come forward in appropriate locations. Both Ipswich, as a Key Centre for Development and Change and as a focus for the ICT/telecommunications industry, and Felixstowe, as a major port, are prime examples of such locations. This review retains the priority for growth to these two areas. 3.2 The precise distribution of new housing within Suffolk Coastal is ultimately, a matter for local determination. By increasing the amount of new housing allocated to the IPA the Council states that this will bring positive local benefits in terms of terms of transport and community facilities. The Assembly is also aware that an outline planning application exists for this same area which seeks to deliver some 2,000 homes as part of a mixed-use community on land east of the A12. 4. Recommendations 4.1 The Standing Committee is asked to consider that Suffolk Coastal District Council's focused Core Strategy review does not give rise to any conformity issues.
SCDC Response: Comments noted
IPSWICH POLICY AREA
Respondent Name: Eileen and Colin Russell [443] Submission Agent Respondent ID: 443 ID: 443 ID: SUBMISSION We would like to say that we are very strongly opposed to the Adastral new town proposed for our area.
Apart from the impact this would have on our environment and the wildlife, this new town will take up land that the local farmers use for their crops - which we benefit from, but I suppose we can always import more produce.
2000 homes - 4000 plus more people, children and vehicles. This area cannot take anymore schools, shops and transport. The local hospital is already bursting at the seams.
What is happening to our "green and pleasant land"?
We do hope the above proposed development is a foregone conclusion!!
SCDC Response: 17, 15
8 YOUR COMMENTS
Respondent Name: Elisabeth Johnson [305] Submission Agent Respondent ID: 305 ID: 305 ID: SUBMISSION We pride ourselves as being a democratic country and yet we are being dictated to by the rich and powerful, in this case BT. When deciding about the huge development for Martlesham please consider the views of the people foremost whom you represent instead of being the pawns of BT, because it is our village that will be lost.
SCDC Response: 16 Other comments noted
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Elizabeth Atkins [183] Submission Agent Respondent ID: 183 ID: 183 ID: SUBMISSION Para4 Natural England's comments on SP2,5,8,16,17,18,20 all refer to negative impacts of devt. Para4.7.1 "the area near Martlesham identified as 'preferred option'could have particularly negative impacts upon the Deben estuary SPA/SSSI" I can find nowhere where SCDC has addressed this concern. A warning such as this from NE must be taken seriously. A major development will have an irrevocable effect on the area. We do not want to see the unique qualities of the Suffolk Coastal area lost to succeeding generations by imposition of an intrusive development when housing needs can be met more imaginatively and incrementally.
SCDC Response: 9
8 YOUR COMMENTS
Respondent Name: Elizabeth Atkins [183] Submission Agent Respondent ID: 183 ID: 183 ID: SUBMISSION The reasons behind the updated figures are not justified. SCDC cites the effect of recession on the Port of F'stowe to justify a decrease in housing nos.there, but ignores the effect of recession on projected employment provision at Adastral Park. The benefits of integrated development are lauded for F'stowe but not for Ipswich policy area. SCDC picks reasons at will to back up its main policy thrust which is to focus massive development on the one site it is sure is coming on stream ie Adastral. The planning process is being subverted.
SCDC Response: 7, 15, 16, 22
IPSWICH POLICY AREA
Respondent Name: Elizabeth Atkins [183] Submission Agent Respondent ID: 183 ID: 183 ID: SUBMISSION Para 7.03 is an example of the confused thinking behind this policy: is it an opportunity for a stand-alone community or is it a development which must be integrated with the rest of the Martlesham area? (If the latter it will well and truly swamp both M'sham Heath and Old M'sham). The lack of coherent argument leads one to the conclusion that the latest decision to increase the housing nos.is entirely driven by BT's requirements, and that SCDC will jump through any semantic hoops in an attempt to justify the decision for which it cannot produce actual evidence.
SCDC Response: 16, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Elizabeth Atkins [183] Submission Agent Respondent ID: 183 ID: 183 ID: SUBMISSION The argument seems to be that the doubling of the housing nos. will allow for economies of scale when providing "mitigation". This is likely to be true but is a smokescreen. The crucial point is that 2000 homes take up double the amount of land and double the population on the site with the concomitant pressures this will bring. The significance of the difference between 1000 and 2000 homes is glossed over by SCDC and the 'evidence' that the benefits outweigh the disbenefits is nowhere demonstrated.
SCDC Response: 15
HOUSING DISTRIBUTION FELIXSTOWE/WALTON AND TRIMLEY VILLAGES
Respondent Name: Elizabeth Atkins [183] Submission Agent Respondent ID: 183 ID: 183 ID: SUBMISSION Here organic and evolutionary growth are seen as bringing many benefits vis.reduced impacts on communities, road networks etc.. These are general arguments which apply equally to the Area E.of Ipswich so why are they not considered there?
SCDC Response: 16
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Elizabeth Atkins [183] Submission Agent Respondent ID: 183 ID: 183 ID: SUBMISSION Nowhere can I find any reasoning as to why a stand-alone community is so highly prized. Elsewhere in your documents all the reasoning is about integration.(see comment on para5.19)
SCDC Response: 16
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT?
Respondent Name: Elizabeth Atkins [183] Submission Agent Respondent ID: 183 ID: 183 ID: SUBMISSION In all the documents I have read I can find no solid justification for the increase in housing nos.at Martlesham. Only one reason is stated vis.that the original figure was insufficient for a stand-alone community. Since this comment came from only one source(David Locke Associates - BT's agents)it seems that SCDC is using the LDF process to facilitate an upcoming planning application and is failing to consider seriously any other proposition. Will the broad strategy be better met? No,because the increased population will be less well integrated into the area. The local area would be better served by flexible approach.
SCDC Response: 16
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Elizabeth Atkins [183] Submission Agent Respondent ID: 183 ID: 183 ID: SUBMISSION The Sustainability Appraisal is a weak document. Methodology is flawed and perverse and contradictory conclusions are reached. See attached comments. (Full comments are available via http://suffolkcoastal.jdi-consult.net/ldf/)
SCDC Response: 8 Other comments noted
IPSWICH POLICY AREA Europa Translations (Mr John Respondent Name: Bennett) [176] Submission Agent Respondent ID: 176 ID: 176 ID: SUBMISSION I wish to object to the proposed development of Adastral Park, particularly as the proposed pedestrian/cycle bridge across the A12 will result in more cyclists illegally riding along the narrow paths that run between the various parts of Martlesham Heath.
Of particular concern to me is the path that runs down alongside our house from opposite the proposed bridge to the bottom of Birch Grove.
This is a very narrow path with a fairly steep incline where it joins Eagle Way, which means that cyclists ride down this lane at high speed. There have been numerous collisions at the bottom of this lane between cyclists and cyclists, cyclists and pedestrians and cyclists and dogs (including our own). To my knowledge, three people have been injured outside our property. No doubt there have been many more collisions and injuries that I am not aware of.
A few years ago, when I phoned the council about cyclists whizzing around the blind corner and past our gate at dangerously high speed, and mentioned the collisions and injuries that had occurred, I was told that nothing could be done as this was a footpath and that it was "illegal" to ride on footpaths!!!
The accidents and near misses that occurred when backing our car out of our drive and across the path were a major factor in our decision to redesign our garden three years ago at a cost to us of £9000 so that vehicles could exit our property forwards in order to reduce the risk of collision.
Building a bridge across the A12 and ending up in Eagle Way will inevitably result in an increase in the number of cyclists illegally riding along the narrow walkways with a corresponding increase in the number of collisions and injuries.
Like many others, we moved to Martlesham Heath because of its unique self-contained village atmosphere. It is now being proposed that we be "linked" to a major development on the other side of the A12 against the wishes of the vast majority of the residents of the Heath.
Please leave Martlesham Heath alone and abandon this ill-conceived idea.
SCDC Response: 18
MARKET TOWNS - INCREASE PROVISION FROM THIS SOURCE EWS Chartered Surveyors (Mr M Respondent Name: and P Underwood) [293] Submission Agent Respondent ID: 293 ID: 293 ID: SUBMISSION My clients support the additional allocation to market towns - particularly Saxmundham.
They own a significant part of the 'greenfield allocation' referred to, for which SCDC has approved planning permission, subject to prior conclusion of Sec 106 Agreement. These formalities are almost complete.
My clients have also suggested the inclusion of Street farmand land to the north, to the south of the railway in submission to the LDF process. This would provide additional development land, restore unsightly buildings in a location where there is little or no adverse impact. Further development here could be sequential to that SCDC has already approved.
I attach a copy of the plan also the line previously submitted udentifying the suggested additional area.
I commend this allocation to you.
SCDC Response: Noted
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: F Boyle [91] Submission Agent Respondent ID: 91 ID: 91 ID: SUBMISSION I OBJECT TO THE CORE STRATEGY IN IT'S ENTIRETY AS IT AFFECTS FELIXSTOWE, WALTON AND THE TRIMLEYS. APART FORM A SMALL NUMBER OF AFFORDABLE HOMES FOR LOCAL NEEDS, THE REST SHOULD BE DISTRIBUTED ACROSS THE DISTRICT TO MINIMISE INFRASTRUCTURE COSTS AND MAXIMISE SUSTAINABILITY FOR SMALLER COMMUNTITES.
SCDC Response: 22
IPSWICH POLICY AREA
Respondent Name: F Matheson [474] Submission Agent Respondent ID: 474 ID: 474 ID: SUBMISSION It is a very sad state of affairs if we the people most affected by the latest option, or for that matter, any option, should still have to raise objections against its implementation. Many obvious reasons have already been given as to why we do not consider any development is viable in any shape or form. The overwhelming numbers of people it will engender is mind boggling, let alone all the ancillaries that go with ordinary day to day living.
Waldringfield parish Council have provided strong objections, once again to any development being allowed, which I thoroughly endorse.
SCDC Response: Noted
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES Felixstowe and District Council for Sport and Recreation (Mr Respondent Name: Michael Sharman) [424] Submission Agent Respondent ID: 424 ID: 424 ID: SUBMISSION This local sports council strongly challenges the assertion that "there is currently a slight oversupply of space within Felixstowe". The Local Plan requirement for playing pitches and sports grounds is almost 50% dependent on the provision at Deben and Orwell High Schools. This over-reliance neglects to realise that arrangements for community use of high school provision are not always easy for a whole variety of reasons so take-up is not as high as is apparently supposed. Moreover, when the two schools close in 2013 some 10 hectares or a quarter of the existing total provision will disappear. The existing statement alleging slight over supply of sporting facilities may seriously impinge on the provision of a multi-sports park for school and community use on the new high school site which it is hoped will dramatically increase sporting resources available in Felixstowe and district and meet the demand for further sport and recreation provision by existing residents identified by the 2006 David Lock Associates Report " A local strategy for the Felixstowe Peninsula". This matter is urgent as developers have already distorted the statement to drop 'slight' and to claim there is over supply in Felixstowe. The District Council should carry out a further audit of all sporting facilities within Felixstowe to determine the deficiencies which this local sports council believes to exist.
This local sports Council takes exception to the claim that "any 'common' facilities that are normally offered in sports halls could be provided in a secondary school gymnasium". This statement seriously confuses the differing natures of a gymnasium, for such activities as gymnastics, judo, karate and trampolining and a sports hall, equivalent to two basketball courts in size, for such activities as archery, badminton, basketball, fencing, indoor soccer, mini-tennis, table tennis and volleyball.
SCDC Response: Noted
8 YOUR COMMENTS Felixstowe Rifle Club (Mr Respondent Name: William Bond) [316] Submission Agent Respondent ID: 316 ID: 316 ID: SUBMISSION On behalf of the Felixstowe Rifle Club I wish to object to the current plan for additional housing within the Felixstowe area. The club feels that the quantity of housing is too high and that any development should be limited to the availablility of any brown filed sites ONLY.
SCDC Response: 22
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS Felixstowe Town Council (Mrs Respondent Name: Susan Robinson) [461] Submission Agent Respondent ID: 461 ID: 461 ID: SUBMISSION (REG 25) CONSULTATION ON SUFFOLK COASTAL LOCAL DEVELOPMENT FRAMEWORK (LDF): CORE STRATEGY: PROPOSED CHANGES TO HOUSING DISTRIBUTION.
Thank you for consulting Felixstowe Town Council concerning the (Reg 25) Consultation on Suffolk Coastal Local Development Framework (LDF): Core Strategy: Proposed Changes to Housing Distribution.
The Town Council considered the proposed changes to housing distribution at a meeting on 16th November 2009 and I was asked to forward the following comments to you:
" This Council accepts that there will be a need for additional housing, especially affordable housing, in our area but it should be developed according to the area's needs, using brownfield sites first and wherever possible. It calls on the Cabinet at Suffolk Coastal District Council to reject the LDF Task Group's recommendation that Felixstowe should be targeted for such substantial growth and believes that such growth should be equitably distributed across the whole District. "
SCDC Response: 4, 22
IPSWICH POLICY AREA
Respondent Name: G D M de Margary [567] Submission Agent Respondent ID: 567 ID: 567 ID: SUBMISSION Dear Sirs,
I write with reference to the proposed development (and enhancements to it) at Ad Astra Park, Martlesham Heath.
Summary
I object strongly to the proposed plans - infrastructure cannot take such large increase, substations and sewage plants required,Orwell Bridge almost at full capacity, only one point of access to the immediate area A12, no mention of Ipswich Northern bypass, loss of good farming land, failure to survey land for quality, infringement on AONB, confusion between integrating into existing community or building standalone development, destruction of village life in Martlesham and Waldringfield. In short, Martlesham will become part of Greater Ipswich.
Objections
I have viewed the amended plans for the proposed development and object to the proposal for the following reasons:
Assumptions
2000 houses = 4000 adults and 4000 children. It is possible that there will be some one-parent families (thus reducing the numbers involved) and also that some of the properties would be turned into flats (thus increasing the numbers involved). Taking affordability into account it would be reasonable to work on a basis of 2500 adults and 2000 children in occupation.
Thus it is reasonable to expect in the current age that just about every adult will have a car - say 2500 cars. On the basis that at least one person per household is working and the other (if not working, which is likely in current times) will go out shopping, etc., will result in 5000 traffic movements per day. There are certainly not 2500 new jobs in the Martlesham area and thus this road traffic is certain. It is unlikely that anyone working at Ad Astra Park will want to live on site, as who wants to live on top of their work.
Roads. The intention is to enhance the existing roundabouts on the A12 by adding lanes and traffic lights that will allow the extra traffic onto the A12. Further, there is now a proposed entrance to the site North of Sheep Drift Farm, opposite the road to Brightwell, this junction being some 200 metres from the A12 Foxhall roundabout.
As I see it, the effect of adding 5000 traffic movements per day onto the A12, the bulk of which will be during the rush hour, is as follows:
1. Pulsed traffic caused by traffic lights on roundabouts will cause chaos as the proposed lights are too close together and will interfere with each other, especially during rush hour. Long distance traffic to Lowestoft and Felixstowe will become ensnared in the local traffic.
2. This will throw much traffic onto the only other alternative routs, C class Waldringfield Road which will become a rat run, with the consequential effect on the local existing communities and wildflife.
Orwell Bridge at almost full capacity and will not be able to take the extra traffic, let alone when half the houses have been built and occupied and there is still the developers traffic and quarrying traffic (due to continue for another 10 years - is there any form of joined-up thinking/planning involved anywhere in this scheme?)
AONB. An Area of Outstanding Natural Beauty adjoins the proposed site and in the past, applications have been turned down for this proximity (a green burial was one, which would have absolutely minimal impact on the area as compared to the proposed development). The Appropriate Assessment comments that river walks at Waldringfield will not be affected as there will be no car parks built and therefore people cannot get to them. This is ridiculous as, if you have a housing development of 2000+ homes, which equates to 5,000 people, many of them are going to want to access the 'local beauty spots' and they are not going to walk, with the totally predictable traffic chaos. This particular comment in the Appropriate Assessment is not in touch with the real world.
Terrain. I understand that part of the agreement to allow quarrying to take place was that the land would be returned to heathland, which we are short on in the area. This development is contrary to that agreement, which would appear to have been conveniently forgotten.
The plan states that the land on which these 2000+ houses, etc., will be built is low grade. In discussing this with local farmers, I understand that this is not the case as it has been used for agricultural purposes for many years and as a result , the land is far from poor.
This area is much loved for its natural beauty, charm and tranquility. There are many walkers in the area and those from afar who enjoy the walks down to Waldringfield and the Deben. All this will be shattered by the proposed development.
If it is necessary to build these houses (which I doubt as I understand that there are 800+ houses empty in the area), then brown field sites should be used and not reduce the amount of land given over to agriculture. If we end up as a nation who has built over their agricultural land and cannot feed itself, in time of a European or world food shortage, we will not be able to buy it in.
The Development
A development of 2000+ houses with few shops, pubs, places of worship, cinemas or even corner shops will rapidly become a sterile place with nowhere for the inhabitants to congregate. The presence of the Martlesham Heath shopping area, including Tesco, is hardly sufficient. What you will end up with is groups of bored youths out looking for something to do, which normally spells trouble.
I have seen no mention of the effect on local surgeries, dentists, Fire and Rescue Services, Police or other agencies in the proposal.
This project, taken alongside the developments in Grange Farm, Foxhall, Martlesham Heath and Kesgrave, will mean that Martlesham (and in time, no doubt, Waldringfield) will be swallowed up in Greater Ipswich and the local communities destroyed.
Building the entire stock of houses in Area 4 in one place is local government vandalism carried out by SCDC, clearly the thought is to dump them all in one place so that there will only be a few local protesters as the rest of the area will be left untouched. This is a dreadful attitude by our locally elected 'representitives' and will be catastrophic to the local area.
No upper limit to the number of houses to be built has been given.
Replies to the first consultation gave the impression that SCDC will be looking to the developers to resolve any problems (some of which are mentioned above) and there forenot considered to be a SCDC problem. Experience in other parts of the country show that the developers will shut down the building company when all tthe profits have been taken and leave nothing left to fix problems. Be aware.
Is SCDC that short of cash that it needs the extra revenue that will be generated by these new houses?.
In conclusion, I object to the proposed plan for the reasons given.
SCDC is meant to protect our environment and communities, not shatter them.
SCDC Response: 7, 9, 13, 14, 15, 16, 17, 18, 19, 20
IPSWICH POLICY AREA
Respondent Name: Georgina Challis [457] Submission Agent Respondent ID: 457 ID: 457 ID: SUBMISSION We act as planning advisers to the East of England Co-operative Societty in respect of an existing Land Bid at Mill Farm, Old Felixstowe Road, Martlesham.
We have carefully considered the updated housing Distribution and fully support the proposed revisions which in essence involve increasing the number of dwellings proposed within Martlesham to 2000. Martlesham is a highly sustainable location suitable for residential development and has the capacity to accommodate the growth identified.
SCDC Response: Noted
8 YOUR COMMENTS
Respondent Name: Gill Harris [138] Submission Agent Respondent ID: 138 ID: 138 ID: SUBMISSION The scale of the development is far too big. I originally agreed that Adastral Park was the preferred option of the 5 in the East of Ipswich Area but specified that the original ~1000 dwellings was more than sufficient. I also expressed concern that the Trimleys would get away scot free when the inevitable suggestion that the 2000+ proposal for Adastral Park came to be considered.
I still believe that the impact on roads, traffic flow and pollution will be totally unacceptable, as will the pressures on any remaining green space. I am slso concerned at the 'urban' nature of the actual housing proposed;multi-storey blocks etc. Only a minority of people living there will work locally and do any of us believe that sufficient infrastructure will be in place to accommodate the influx of people
SCDC Response: 7, 16, 17, 18, 20, 22
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Gillian Mason [470] Submission Agent Respondent ID: 470 ID: 470 ID: SUBMISSION The proposed changes are not justified - this level of housing is not needed in Felixstowe, and Greenfield land should not be sacrificed in this way. I object to the core strategy as it does not reflect housing needs in Felixstowe. There are currently 400+ houses available for sale, which has been ignored. 1000 houses on greenfield land cannot be justified and are not needed. The housing is needed elsewhere in the district, and this is also being ignored. Apart from a small number of affordable houses for local needs, the rest should be dispersed across the district, to minimise infrastructure costs and maximise sustainability of smaller communities.
SCDC Response: 4, 22
2 THE CONSULTATION IN BRIEF GO East (Miss Maydo Pitt ) Respondent Name: [87] Submission Agent Respondent ID: 87 ID: 87 ID: SUBMISSION End Date
We note that your previous Core Strategy consultation included a 2025 end date at which time it was anticipated that the Core Strategy would be adopted in 2010. We note that the current consultation document also has a 2025 end date but we are aware from recent correspondence and the table on Sheet 1 of the FAQs that the adoption date is scheduled to be in 2011, which means that the Core Strategy carries a risk of not reflecting guidance in PPS3, paragraph 53. Therefore, in order to minimise this risk and coupled with the fact that PPS3, paragraph 53, advises that Local Planning Authorities should plan for the delivery of housing for at least 15 years from the date of adoption, we request that you consider whether the Core Strategy should have an end date beyond 2025 i.e. 2026.
SCDC Response: 2
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT? GO East (Miss Maydo Pitt ) Respondent Name: [87] Submission Agent Respondent ID: 87 ID: 87 ID: SUBMISSION Housing Supply
We are pleased to note that the proposed changes to the housing distribution document excludes the windfall reliance within the first ten years of the plan.
SCDC Response: Noted
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT? GO East (Miss Maydo Pitt ) Respondent Name: [87] Submission Agent Respondent ID: 87 ID: 87 ID: SUBMISSION Overall Comments on the Document
Overall, we think that you have produced a helpful consultation document, which clearly sets out the proposed revised housing distribution. We are pleased to note that the Authority has assessed the infrastructure requirements for the proposed revised housing distribution and that these are explained in the FAQ paper. Moreover, we are pleased to note that the Authority has carried out a sustainability appraisal and appropriate assessment of the proposed revised housing distribution.
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Grainger PLC [585] Submission Agent Respondent ID: 585 ID: 585 ID: Mr Chris Rees SUBMISSION Grainger PLC broadly supports the increase in housing allocation to 2,000 dwellings within the IPA, but changes to the Core Strategy are required to make this document sound.
See supporting statement and appendices
The Outline Landscape and Visual Baseline Report for Land at Longstrops, Kesgrave which could not be attached is available to be viewed at the councils offices in Woodbridge.
SCDC Response: Noted
APPENDIX 5 - REVISED SETTLEMENT HIERARCHY GVA Grimley (GVA Grimley Ltd) Respondent Name: [541] Submission Agent Respondent ID: 541 ID: 541 ID: SUBMISSION We write on behalf of our client, the Royal Bank of Scotland, in response to the invitation to comment on the Suffolk Coastal District Council (SCDC) Housing Distribution Updated Preferred Option 7/09 ("HDUPO"). The following representations have been prepared on behalf of our client with specific regard to land off St Margaret's Crescent, Leiston.
Introduction
We previously submitted representations on 20 February 2009 to SCDC on behalf of our client concerning the Core Strategy preferred Options consultation Document. We also submitted representations on 20 February 2009 concerning the Site Specific Allocations and Policies Issues and Options. The latter representations were to advocate the inclusion of Site 775 (site adjacent to 26-52 St Margaret's Crescent, Leiston) as an allocated site for residential use within the Site Specific Allocations and Policies DPD, in accordance with national and regional policy, as well as assessment criteria set out in the Site Specific Allocations and Policies Issues and Options DPD.
We consider site 775 to be well located for housing development, being within the settlement boundary and in close proximity to local services, employment, transport and infrastructure, making it a sustainable and suitable location in accordance with planning Policy Statements 1 and 3 (PPS1 and PPS3 respectively). It is also both 'deliverable' and 'developable' in accordance with the objectives and criteria of PPS3, making it suitable for both short and longer term allocation, to help meet and exceed the Councils strategic housing targets.
With regard to the current consultation document, we note that the HDUPO does not alter the housing target itself, but proposes significant changes to the distribution of new housing, most notably in Felixstowe and Martlesham. The consultation document requires us to comment specifically on whether we think the reasons behind the proposed changes are justified, and whether we think the broad strategy will be better met as a result of these changes. We set out our comments under the specific heads below.
Windfall Sites and Strategic Allocations.
The HDUPO states that changes to housing distribution are in part due to a need to reduce the reliance on "Small Windfall provision". Windfall provision should not be discouraged, as it is a useful resource in not just meeting, but also exceeding strategic housing targets, as required by the East of England plan. However, we welcome the objective to accord more fully with PPS3 by placing greater emphasis on the 'deliverability' of allocated housing sites, particularly in the first ten years of the plan. We recognise that the re-use of previously developed land is a priority in accordance with national policy however this is not always deliverable or developable. A Greenfield site such as Site 775 offers an 'available' and 'achievable' development potential within a settlement boundary. This is because the site benefits from being vacant and in single ownership with no land assembly and land contamination constraints. The site is therefore an appropriate allocation with the potential to assist the Council in meeting and exceeding housing targets.
Re-distribution to Market Towns
With regard to the designated Towns/Market Towns, the HDUPO explains at page 12 that the changes suggested for the areas East of Ipswich, Felixstowe/Walton and Trimley villages, plus the reduction in reliance on small windfall provision, necessitates adjustments elsewhere "to meet the RSS housing requirements". We welcome the increase of an additional 470 units at designated Towns/Market Towns including Leiston. This should be focused on 'deliverable' prospective allocations such as Site 775, which, as a vacant site with no land assembly constraints, has significant potential to contribute towards the now increased proportion of housing required in the Market Towns. We note however that the HDUPO says "to meet", but does not add "and exceed" RSS housing requirements. We would stress that the East of England Plan regards the housing figures as "minimum targets to be achieved, rather than ceilings which should not be exceeded", and Housing Distribution policy should therefore be amended to explicitly encourage housing targets to be exceeded.
Phasing
In terms of whether the proposed changes will help better meet the broad strategy, we suggest that the stated ambition to wait until the third phase (page 12 and page 14 (section 7.05) of the HDUPO) before providing the further 470 units in the Town/Market Towns should be reconsidered. As stated above, the East of England Plan requires the housing targets to be exceeded, and therefore efforts to deliver housing earlier rather than later should be encouraged. This will protect against delays or shortfalls in housing provision at a later date. We therefore recommend that the provision of the further 470 units should be bought forward at least at the second phase of the plan period to maximise the opportunity for targets to be exceeded.
Density
We also note that in the "Revised Settlement Hierarchy" of the HDUPO (Table 2 of Appendix 5) it states that a Town provides the "focal point for estate-scale housing, employment, shopping and community facilities". We welcome the inclusion of "housing" in this description. However, housing development should not be prescriptively limited to "estate-scale" only as other forms of higher density development might be suitable to optimise the use of land. Policy should explicitly seek to maximise development density by making 'best use of land' (in line with PPS1 and PPS3)within the settlement boundaries, subject to design quality, mitigation of environmental impacts and infrastructure capacity.
In summary, subject to the amendments above, we support the proposed changes and broad strategy set out within the HDUPO. We also support the inclusion of Leiston as a Town/Market Town within the Settlement Hierarchy and re-emphasise the potential offered by Site 775 as a prospective strategic allocation to contribute to SCDC's housing targets.
We trust you will take into account the above comments and our previous representations submitted, and we look forward to confirmation of receipt of these representations and to early notification of how we can further engage in the later consultation process.
If you have any queries please do not hesitate to contact either Fred Drabble (020 7911 2216) or Will Wallace (020 7911 2746).
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Haines Watts (Mr Clive Wilkins) Respondent Name: [159] Submission Agent Respondent ID: 159 ID: 159 ID: SUBMISSION Dear Sirs
I write regarding the new proposed housing site on Adastral Park Marlesham Heath.
The area is quite well populated and the road structure can only cope with the present day traffic Also with the introduction of so many new homes the impact on the local environment will be enormous.
The introduction of the Park and Ride site on the roundabout met with local objection and although it contravened many planning laws due to its location and road structure it still became a reality.
Many people are opposed to this new proposal for housing so for once pleased take the views into consideration.
SCDC Response: 12, 13, 19
THE MARKET TOWNS Harcourt-Powell (Mr Nick Respondent Name: Harcourt-Powell) [21] Submission Agent Respondent ID: 21 ID: 21 ID: SUBMISSION We SUPPORT the development of Saxmundham as it is a focus point for employment, shopping, and community facilities and a transport hub.
SCDC Response: Noted
LOCAL SERVICE CENTRES Hasketon Parish Council (Mrs Respondent Name: Rosemary Good) [67] Submission Agent Respondent ID: 67 ID: 67 ID: SUBMISSION Dear Madam,
(Reg 25) Consultation on Suffolk Coastal Local Development Framework (LDF) Core Strategy: Proposed changes to Housing Distribution.
Thank you for your letter of the 23rd September 2009, and for all the information in respect of the above.
The proposals have been studied, and it is noted that the only changes to be made are to increase the number of houses at Martlesham (next to BT) to 2000, and reduce those on the Felixstowe peninsula.
With regard to the Parish of Hasketon, it is noted that Hasketon remains under the category of Local Service Centre which is lower than Key Service Centre. This allows only development within the village envelope. The affordable housing provision is the normal 1 in 3 units in housing developments of 3 or more units. It also allows for affordable housing on exception sites on edges of the village envelope.
Hasketon is, therefore, not affected by the proposals put forward.
SCDC Response: Noted
8 YOUR COMMENTS
Respondent Name: Heather Hann [135] Submission Agent Respondent ID: 135 ID: 135 ID: SUBMISSION I worry that the infrastructure of the development at the size being proposed will be done at the end rather than the beginning. schools in the area are full to bursting now as are the roads. I feel that the proposed larger number of houses approx 2000 will lead to gridlock on motorway style lanes.This will have huge environmental issues. roundabouts will be changed into traffic lights leading to congestion, road safety issues and pollution as well as environmental impact the housing is proposed for workers from BT where large numbers of staff continue to be laid off
SCDC Response: 7, 13, 19, 20
IPSWICH POLICY AREA Hemley Parish Meeting (Mr. R Respondent Name: Pasco) [407] Submission Agent Respondent ID: 407 ID: 407 ID: SUBMISSION I am writing again to register the Parish's continuing strong opposition to the residential element of proposals for the development of "Greenfield" land, to the east of Adastral park, and would draw attention to previous objections, the points listed in them still pertinent today, dated 14th may and 13th February 2009 and 29th September, 4th July and 18th march 2008, made on behalf of the village.
As previously stated, we have no objection to "employment development" within the ring fence of Adastral park, but it seems to us that residential development, supported by only 4% of the local population, according to SCDC figures on a "Greenfield" site is totally out of keeping in such an open rural area and with the wishes of the local population.
The proposals by BT will cause major traffic congestion on the A12, the A1214 and Foxhall Road, particularly as more "work trips" from this area already go to the centre of Ipswich than to Adastral park and with BT making substantial reductions in the number of people working for them, this trend is likely to increase in the future. Access and egress from the proposed site is far from satisfactory, as roundabouts and traffic lights on the busy A12 will, we believe, cause greater congestion than at present and the entrance onto the C356, just before a sharp bend would be difficult, to say the least. The density and height, of some of the suggested buildings are very much out of keeping with the open rural area. New smaller developments, added to existing built up areas, would make better use of existing facilities, help to reduce traffic congestion and may even provide them with the additional facilities needed. This policy would also accord with the amended proposals for the Felixstowe/Trimley area, and would limit damage to the villages surrounding Area 4 the Areas of Outstanding Natural Beauty, SSSI sites etc.
The villagers were particularly concerned about the provision of "temporary open spaces" as this appears to allow for an even greater density of development in the future.
We hope that on reflection you will refuse the residential element of the present planning application.
SCDC Response: 4, 13, 17, 19
THE MARKET TOWNS Hopkins Homes (Mr Chris Respondent Name: Smith) [552] Submission Agent Respondent ID: 552 ID: 552 ID: SUBMISSION 7.01 - Base requirements
The move from the over-reliance upon unallocated 'windfall' sites to positively allocating locations and sites to accommodate the minimum level of growth required is warmly welcomed. To do otherwise would represent a complete failure to 'Plan'
7.02 - The Overall Strategy
The stated strategy of the 'Development at market Towns to be generally restricted to previously developed land' with only 'modest Greenfield allocations in the final phase', whilst no doubt highly politically desirable, is unfortunately both unrealistic, given the minimum requirements in terms of numbers of dwellings and associated facilities required to plan for, and appears at odds with the more detailed breakdowns of growth proposed for each tier of settlement within the hierarchy, within paragraphs 7.03 - 7.08 of the document.
Table 1 within Appendix 4 of the document clearly indicates that a limited supply of existing brownfield sites exist, whilst the Greenfield allocation suggested to be carried forward for Saxmundham has obviously previously been accounted for within the third column, hence does not count in reality towards the Greenfield allocations requirement for th market towns. Whilst as indicated elsewhere, Hopkins Homes, as the promoter of the previous allocation at Saxmundham, is obviously supportive of the Council's stance towards the role that this site will play in the growth of Saxmundham, it is perhaps somewhat misleading to suggest that this will form part of the 'first-phase' of growth within the plan period, given that in reality it has already been accounted for within the current plan period.
As is expanded upon in other representations, strategic Greenfield allocations will be required at Woodbridge within the early stages of the Plan period, the broad locations of which require determining at this strategic stage, whilst further Greenfield allocations will be required across the board in the latter stages of the Plan period, in order to deliver the minimum dwelling numbers required. In order to make the strategy sound, such changes in both emphasis and content of the document therefore need to be made.
7.05 - The Market Towns
Saxmundham
As per the comments made in February 2009, Hopkins Homes Limited welcomes the continued commitment by the local planning authority to support this residential development of the local plan allocation made under Policy AP148 (Land to the East of the River Fromus). Hopkins Homes Limited remains committed to developing the site, for which a resolution to grant permission has been made by the local planning authority (C07/0362), which will enable the continuation of the regeneration of the adjacent town centre, via improved pedestrian accessibility, together with the creation of new public open space alongside the Fromus.
Hopkins Homes Limited further supports the Local Planning Authority's stance of preventing any further release of peripheral Greenfield land in alternative locations unrelated to this site elsewhere around the town.
Notwithstanding the obvious support for the Council's stance with regards to Saxmundham, it is perhaps somewhat misleading to suggest to the wider public that this will form part of the 'first-phase' of growth within the plan period, given that in reality such growth has already been accounted for within the previous plan period, as highlighted within the third column of Table 1 within Appendix 4 of the document.
Woodbridge
As indicated in February 2009, whilst Hopkins Homes Limited is fully aware of the acknowledged physical and environmental constraints which surround the town, we would raise serious concern with the proposed approach of seeking to promote limited residential growth on a range of sites across the town, without any form of strategic guidance upon how this might be achieved in practice.
In view of the previously acknowledged need to identify new sites for a minimum of 200 dwellings within and around the town during the plan period, together with the stated objective of providing housing of a type, size and tenure appropriate to the needs of the District (the bulk of which we would assume to be low density family housing) and the acknowledged lack of identifiable brownfield sites, it was suggested that serious consideration should be given within the Core Strategy at this strategic stage as to the broad location(s) to accommodate this growth. The fact that the minimum number of dwellings to allocate land for has now effectively more than doubled since February compounds the importance of doing so.
In the interests of proper planning and effective delivery, it is therefore strongly suggested that the local planning authority should, at this initial stage, seek to positively plan for the achievement of such growth during the early stages of the Plan Period, rather than sit back and hope that it occurs sporadically on a piecemeal basis over the longer term. Depending upon the potential restrictions which could be placed upon growth at both Saxmundham and Leiston, given the social and economic role that Woodbridge plays within the District, it would appear prudent to allow for much higher minimum levels of housing growth at Woodbridge, in the order of 400-500 dwellings rather than the 200 that were previously suggested, in order to meet the acknowledged residual minimum requirement of almost 900 dwellings.
Leiston, Aldeburgh and Framlingham
Whilst acknowledging the potential that exists to provide further housing growth at Leiston over the Plan Period, the recent announcement of the intention to construct Sizewell 'C' during the early years of the Plan period is likely to have a direct consequence upon the acceptability of any more than infill and incremental growth for Leiston. Given the known flood risk and environmental constraints which exist in and around Aldeburgh, together with potential 'Sizewell C' related restrictions which may apply equally to Saxmundham, Framlingham is therefore left as the only other 'Market Town' to Woodbridge which would be available to accommodate the future growth suggested for this tier of settlement within the District.
Whilst acknowledging that little mention was made of further Greenfield allocations around Framlingham in February 2009, presumably on the basis that previous Greenfield and recent commitments by the Council to permit large-scale redevelopment of brownfield land within the town made such additional allocation difficult to support politically, the level of growth now required to be allocated appears to leave Framlingham as the only realistic option.
As the Council is aware, Hopkins Homes Limited have outstanding planning permission for 65 dwellings upon part of a previous Greenfield Local Plan housing allocation in Framlingham, with a resolution to grant planning permission for a further 140 dwellings upon an existing brownfield former Local Plan employment allocation within the town. As with Saxmundham, however, these 205 dwellings have again already been accounted for within existing commitments, such that they do not affect the additional minimum levels of housing allocations now required.
Similarly to Saxmundham, any such additional Greenfield allocations for Framlingham should be phased for the mid to latter stages of the Plan Period, in order to ensure that the existing brownfield and extant Greenfield commitments are able to be viably delivered in the interim.
SCDC Response: Noted
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Ingleton Group [101] Submission Agent Ms Claire Respondent ID: 101 ID: 101 ID: Mitcham SUBMISSION Early work on the Core Strategy (issues and options and task group reports) began to respond to the identified needs for Felixstowe. This has subsequently been undermined, first by the decision to pursue a strategy of dispersal (Core Strategy Preferred Option December 08), and secondly by current proposed changes. The proposal to reduce the level of housing growth for Felixstowe undermines the strategy for the whole district, and is in conflict with the stated strategy for Felixstowe. Justification for change is very weak, and not based on needs either for Felixstowe or for market towns. The attachment provides further information.
SCDC Response: 22
1 INTRODUCTION Ipswich Borough Council (Mrs Respondent Name: Sarah Barker) [514] Submission Agent Respondent ID: 514 ID: 514 ID: SUBMISSION Please find attached a scanned image of our letter setting out a response to your current consultation. (The full text can be viewed via http://suffolkcoastal.jdi-consult.net/ldf/)
At present the response represents officer level comments only. The Council's Executive will consider the matter on 24th November and after that date I will contact you to confirm or otherwise the Borough's position.
I also attach the Executive report for your consideration.
02/12/2009: Further to our previous e-mail dated 17 November, please be advised the Council's Executive has now agreed the comments sent to you on that date.
SCDC Response: 20 Other comments noted
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES Ipswich Town Football Club Co Respondent Name: limited [565] Submission Agent Mr Edward Respondent ID: 565 ID: 565 ID: Hanson SUBMISSION EXECUTIVE SUMMARY Barton Willmore Planning represent Ipswich Town Football Club Co limited who own and control training facilities north and south of Playford Road in Rushmere St Andrew.
We seek to promote the land south of Playford Road (4.43 hectares) for residential development. We have previously made representations to the Core Strategy and Site Allocation Issues and Options DPD's and seek to promote a case for residential development on this site and for it to be included within the boundary of this local settlement.
We have previously addressed aspects of the Core Strategy which impede the recognition of this site as part of the village of Rushmere St Andrew and we have promoted the reasons for the inclusion of this site, primarily on the basis of its highly sustainable location.
This submission focuses solely on the updated preferred option housing distribution that the Council is now putting forward.
We consider the changes in housing distribution across the District, specifically the proposal to reduce housing numbers in Felixstowe and increase numbers in the Ipswich Policy Area (not just Martlesham), are justified and we believe the revised strategy will aid delivery of much needed housing in the area.
We raise concern at the increased number of houses planned for Martlesham.
We do not consider that the benefits arising from a 2,000 dwelling allocation, as opposed to a 1,000 dwelling allocation, would be significantly different. Specifically we do not consider that 2,000 dwellings would come anywhere near the threshold provision required for a secondary school.
1 INTRODUCTION 1.1 These representations are submitted on behalf of our client, Ipswich Town Football Club Co Limited, with respect to the Suffolk Coastal District Council (SCDC) Core Strategy Updated Preferred Options Housing Distribution consultation document. The document has been released for a consultation period between September and November 2009.
1.2 We understand that the total number of new homes needed in the district by 2025 has not changed and remains at 7,710, around 450 per annum. Of these we understand that: * 1,780 homes available as outstanding planning permissions and 540 predicted to occur as windfall (the latter reduced by 780 from 1,320 in response to objections that the Council should not rely on windfall, it being difficult to quantify); * Balance of homes needs to be allocated, with previously developed 'brownfield' land given priority; * The release of allocations to be phased over three 5 year periods, 2010- 2015, 2015-2020 and 2020-2025; and, * Allocations are expressed as minimum figures consistent with the approach of the Regional Spatial Strategy (RSS) - The East of England Plan.
1.3 In addition to the explicit recognition of the three phases outlined in teh Housing Distribution update, the key changes in the distribution strategy include: * Reducing the amount of housing proposed for the Felixstowe/Walton and Trimley villages; * A substantial increase in the amount of new housing within the Ipswich Policy Area east of the A12 at Martlesham; * A modest increase in provision at the market towns; and, * A reduction in the number of new homes that could be expected to come forward as small 'windfall sites' 3(e.g. building on side gardens; replacing one large dwelling with two or more new ones etc).
1.4 The Council is maintaining its strategy of concentrating new housing at the major centres, market towns and larger villages, the Council also maintain the strategy of development at Martlesham being in a single location forming a new community, but adopting a dispersed strategy for development in Felixstowe/Walton/Trimley.
The Overall Strategy 1.5 For clarification, the following summerises the current housing distribution strategy: * The two Major Centres will continue to be the recipients of a large proportion of the overall housing requirements (52%). * Proposed housing numbers at Felixstowe/Walton and the Trimley villages to be managed, the scale and pace of development only increasing in order to achieve social and economic objectives for the town. * New housing in the Ipswich Policy Area - East of the A12 to be increased in order to create a large development there with an emphasis on it being a community with sufficient supporting infrastructure. The location for such a community remains at Martlesham although the location is specified as to south and east of Adastral Park. * Development at Market Towns be generally restricted to previously developed land although the need for modest 'greenfield' allocations in the final phase is recognised particularly if needed in association with Sizewell. * Allocations at Key Service Centres to meet local needs and affordable housing provision.
2.0 LOCATION AND CONTEXT 2.1 We act on behalf of Ipswich Town Football Club and their land interests in Rushmere St Andrew. Appendix 1 contains a redline boundary plan. The site is located in the village of Rushmere St Andrew which is located on the north eastern edge of Ipswich. The site is relatively well served by the existing road network with the A1214 passing within 1 km of the site, providing a link to Ipswich and further afield via the A14. The site represents an excellent opportunity for a medium sized residential development with associated infrastructure and open space. The site comprises 4.43 hectares and is currently a private sports ground.
2.2 The site is irregularly shaped being bounded on its northern edge by Playford Road and on its southern edge by Bent Lane. It is currently used as a football training ground by Ipswich Town FC, although the main training ground is located immediately adjacent to the north of Playford Road. To the east, west and south of the site are a number of houses and the predominant character of the area is residential.
Development Opportunity 2.3 The size of the site and the character of the area within which it is situated is such that it provides an excellent opportunity for a low to medium density housing development. The surrounding area consists of medium size family homes of both a detached and semi detached nature. The edge of settlement location lends itself to a modest density and the site is unlikely to accommodate flats and apartments, instead it is likely family houses will be developed in accordance with local design guidance and SCDC's desired mix, type and tenure of dwelling. There are a number of ways in which the site could be redeveloped to provide housing and a range of densities is, therefore, possible.
Proposed Densities 2.4 The total site area is 4.43 hectares, and we believe the net residential area to be in the region of 3.0 hectares. Using the dwelling per hectare calculations below the site could accommodate the following number of dwellings:
30 dph - 90 dwellings 35 dph - 105 dwellings 40 dph - 120 dwellings
2.5 Having reviewed the surrounding area, we do not suggest densities higher than 35 - 40 dph to be appropriate. The maximum capacity of the site is therefore circa 120 dwellings. Appendix 2 contains a Development Framework Masterplan showing current proposals for the site.
2.6 Over the past 12 months our client has been working up plans for the site and in October 2009 a Landscape and Visual Appraisal was undertaken. The Appraisal is contained in Appendix 3 and concludes that the proposed development would be assimilated into the local landscape and a number of environmental and visual amenity benefits would flow from the development. The development would enable a high quality residential development, set within an attractive landscape infrastructure that creates new opportunities for enhancing local views from within the urban fringe of Ipswich. Although the character of the site itself would inevitably change, from a private sports facility to a high quality residential development, there would be no significant negative impacts on the character and quality of the wider landscape and at the local level the most significant natural features of the site could be readily retained in the proposals which would assist in the integration of the site into the wider area and would create an attractive context to the scheme.
3.0 REVISED HOUSING DISTRIBUTION 3.1 The key changes in the housing distribution strategy include: * A substantial increase in the amount of new housing within the Ipswich Policy Area. * Reducing the amount of housing for Felixstowe, Walton and Trimley villages. * A modest increase in provision in the market towns. * A reduction in the number of new homes that could be expected to come forward as small 'windfall sites'.
Ipswich Policy Area - East of A12 3.2 Our client's site is located within Rushmere St Andrew on the eastern fringe of Ipswich and within the Ipswich Policy Area. Our client is not seeking inclusion of the site within this Major Centre designation, but due to the proximity of his site to this broad location, we consider residential development on land south of Playford Road to be a sustainable option.
3.3 The Ipswich Policy Area (IPA) is a regional policy designation that extends into Suffolk Coastal District. Although not the subject of preferred options, we consider the designation appropriate because it identifies specific housing targets to be accommodated within it. The Suffolk Coastal part of the IPA incorporates urbanised areas of Rushmere St Andrew, Martlesham and Kesgrave. Although separate communities in their own right, and not part of the regional centre of Ipswich, they form part of a larger area - the IPA. Further east, the IPA contains countryside with high value landscape. Our client's site is located within the IPA where the majority of new housing will be located. We support this general designation.
3.4 The 1,050 homes originally proposed for this sector represented the number required to meet the Regional Spatial Strategy (RSS) East of England Plan minimum housing figures, but the revised housing distribution paper increases the allocation to 2,000. To reduce the numbers would mean not meeting the RSS requirements, or having to build in environmentally sensitive locations. Neither of these options should be entered into and in principle we agree with increasing the overall housing provision within this sector.
3.5 The IPA east of Ipswich is appropriate for development but we believe that not all of the proposed development should be located within the defined 'Major Centre' boundary. Instead we suggest development of sites adjacent to Major Centre designations. Rather than doubling the number of new houses at Martlesham, we suggest they are distributed amongst sustainable settlements on the periphery of Ipswich. These locations such as Rushmere St Andrew are nearer to existing facilities and transport infrastructure.
3.6 Within the Housing Distribution Paper the argument against a smaller allocation in Martlesham is set out. It is stated that a larger scale of development would trigger the need for wider community benefits, particularly a secondary school, and improved public transport provision. Whilst this may be true in part, our analysis demonstrates that a new settlement should be a minimum 5,000 - 6,000 dwelling if it is to support new health and education facilities. So we do not subscribe to the benefits being promoted. The benefits arising from a 1,000 dwellings development would be very similar to those from a 2,000 dwelling allocation. We do not believe this matter has been accurately reported within the Housing Distribution Paper.
3.7 In summary we consider the proposal to increase the housing distribution within the broad location of the IPA as acceptable, but we do not believe that 2,000 dwellings should be located in Martlesham as this will not provide the benefits outlined. Instead, the housing distribution in the IPA should be distributed amongst a number of sustainable settlements.
Felixstowe / Walton and Trimley 3.8 We previously considered the level of development in Fleixstowe, Walton and Trimley villages (outlined in Policy SP4) to be misguided with regard to overall housing allocations. The area is not considered a sustainable location for a substantial chunk of the district's housing due to the proximity to the rest of the region.
3.9 We felt the six areas of directions for growth to be a concern, particularly when considering the impact on patterns of traffic movement and the general setting of Felixstowe. Within Felixstowe we believe more efficient use of Brownfield land could be made and that a slower rate of development should be linked to new jobs without being wholly reliant on the port.
3.10 The emphasis of this area should be on Brownfield development in advance of building new Greenfield sites. Whilst there are a limited number of Brownfield sites in the district, and clearly other sectors will have to develop Greenfield sites, in Felixstowe there are a number of redundant industrial areas that should be utilised first. It is, however, acknowledged that some of these sites are not deliverable or suitable for residential use.
3.11 The vision for Felixstowe was not informed through the activities that take place there. The previous plan suggested large areas of Greenfield would be developed, when the emphasis should have been on protecting the town's role as a tourist destination. We actively support decreasing the allocation in this location. Ipswich fringe, and specifically Rushmere St Andrew, is a more sustainable location and should be the principal location for new housing. Sustainability analysis contained within our clients representations to the Site Specific Allocations Issue and Options (February 2009) outline in more detail the sustainable merits of Rushmere St Andrew and the Ipswich Eastern fringe.
Market Towns and Small Windfall Sites 3.12 The revised housing distribution states that market towns in the district will receive a modest increase in provision. The changes suggested to market towns are in response to the East of Ipswich, Felixstowe/Walton and Trimley villages, and the need to reduce the small windfall allowance mean that to meet the RSS housing requirements some measure of adjustment is required across the rest of the district. Whilst in principle we do not object to this policy, we urge further clarification on the exact distribution and what the Council consider 'modest'. At present this statement is ambiguous.
3.13 National planning policy guidance relating to housing provision places great weight on the deliverability of new housing. It is essential that chosen sites are deliverable within the plan period, specifically the first 10 years. Small windfall sites by their nature are not sites which can be readily relied upon as part of the main housing provision.
3.14 A reduction in the number of new homes that could be expected to come forward as small 'windfall sites' is therefore supported.
SCDC Response: 4, 16, 20, 24 Site specific and other comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: J Maureen Burrows [526] Submission Agent Respondent ID: 526 ID: 526 ID: SUBMISSION Dear Sirs
I wish to object to the new proposal to increase the number of houses allocated to the Ipswich Policy Area and I object to the entire allocation, now 2000 houses, being built on the one site at Martlesham next to Adastral Park for the following reasons:-
The LDF is keen to create a new community - all very well but this would in fact create a completely separate isolated community effectively far from the rest of the community. This could lead to possible community problems in the future with residents in one part of Martlesham not wanting to be part of a parish community. It would also mean that many of the facilities that will be needed will not be easy for residents of the rest of Martlesham to use and vice versa.
The LDF gives one of its justifications as being close to jobs. This is a fallacy, eg. how many residents of Martlesham Heath work at BT?. In practice if this development were to go ahead the houses would be occupied by people from anywhere who happen to be looking for a new home at the time and are just as likely to work elsewhere. Being further out of Ipswich (a far bigger employment centre than BT) there could be more commuting traffic on existing roads to other parts of Suffolk. New homes will also house extended family groups, many not working in the immediate area.
Traffic and Highways - adding 2000 houses will require extreme changes to the A12 (at least what BT proposed in their planning application) which in turn will have a large adverse impact on the residents of Martlesham with more traffic volumes and congestion which will in turn could lead to traffic safety issues. In particular the residents of Martlesham Heath will have even more problems entering or leaving the only two access points (i.e. the BT and Tesco roundabouts). Increased traffic and congestion will also increase air and noise pollution. The road alterations needed will also have a devastating effect on the appearance and character of the entire area.
Public infrastructure and facilities - The LDF documents provides a sort of 'quick fix list' of what would be needed but if a development of this size is to proceed in any way then there must be compulsion to provide all of the necessary facilities at the beginning or early on. Providing all of this infrastructure will also have an adverse impact on the area over and above that of the 2000 houses. For some infrastructure requirements this impact will have a serious effect on other parts of Martlesham away from Adastral Park (eg. providing foul sewerage facilities, extra upper school places, electricity supplies etc.). Of particular concern is that SCDC infrastructure studies have been carried out with conclusions in the LDF document without the promised consultation on the infrastructure appraisals.
Sports fields - a relatively small issue but the LDF documents appear to repeat the wrong assessment of public sports fields available for public use in Martlesham. If I am right then the amount of space needed would be much greater because it seems that they may have included the Police HQ and Woodbridge Town FC, neither of which are publicly available.
If this development goes ahead Martlesham will be a very large village of almost 12000 people, only Felixstowe and Kesgrave will be larger! Martlesham will become an urban sprawl of several large residential areas with no clear focal points.
SCDC Response: 7, 13, 16, 18, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: J P Smith [165] Submission Agent Respondent ID: 165 ID: 165 ID: SUBMISSION Effects of 2000 houses on AONB and nearby villages has been underestimated. It is not just dog walking - there is already increased litter on beach and footpaths, more traffic on village roads, fly tipping on farmland and increased pressure for motorised leisure activities in countryside and on the river. There is little scope for mitigating these effects.
SCDC Response: 9, 17, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: J P Smith [165] Submission Agent Respondent ID: 165 ID: 165 ID: SUBMISSION The council's arguments relating to Felixstowe are not consistent with those for East of Ipswich: eg reducing the allocation of 1050 East of Ipswich would result in not meeting government targets, but a large reduction in Felixstowe is suggested without such a comment.
SCDC Response: 4, 15, 16, 22
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: J P Smith [165] Submission Agent Respondent ID: 165 ID: 165 ID: SUBMISSION Strongly object to these conclusions:
It is not "well related to employment uses" - most employment will be in Felixstowe. Ipswich and the Ipswich periphery. Neither is it "well related to public transport" - it is the location most remote from Ipswich, Felixstowe and Woodbridge with poor public transport links. Being close to the primary road network will only encourage commuting by road.
A large development of 2000 homes will have considerably more impact on nearby communities then a few smaller developments. There is no evidence that the identified problems can be managed to an acceptable level.
SCDC Response: 7, 11, 18
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: J P Smith [165] Submission Agent Respondent ID: 165 ID: 165 ID: SUBMISSION SCDC's approach has NOT been generally supported. Even the initial consultations rejected the option of a large development such as is now proposed. 2000 houses represents a new town, larger than Saxmundham, Aldeburgh, Wickham Market or Leiston. Subsequent consultations on 1050 houses East of Ipswich have raised an overwhelming number of objections regarding issues which have not been resolved. Most of these objections are much more significant if the number of houses is increased to 2000.
SCDC Response: 16
3 BACKGROUND
Respondent Name: J P Smith [165] Submission Agent Respondent ID: 165 ID: 165 ID: SUBMISSION The economic role of the Port of Felixstowe is quite clear but there is no evidence to support the possibility of increased employment at Martlesham Heath. BT is reducing its workforce locally and much of its work can be outsourced or utilise remote teleworking.
SCDC Response: 7
3 BACKGROUND
Respondent Name: J P Smith [165] Submission Agent Respondent ID: 165 ID: 165 ID: SUBMISSION In view of the difficulty finding suitable sites for housing, SCDC should challenge the required numbers of houses. The ONS states that predictions based on past trends should be treated with great caution. In most cases quoted there is no "need" for new homes but a "desire" for additional homes. Inward migration to the district is caused by a plentiful supply of new houses in the area. Recent surveys indicate that almost 40% of house buyers are from outside the area and commuting to jobs outside Suffolk has increased considerably. This doesn't justify destroying the local environment.
SCDC Response: 3
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: J P Smith [165] Submission Agent Respondent ID: 165 ID: 165 ID: SUBMISSION Appendix 1 SP20
The positive impacts have been overstated, particularly items 1, 5, 8, 19 and 22 which should all be negatives. It is not clear how positive and negative impacts are quantified. The negative impacts on nearby communities have been ignored.
SCDC Response: 8
BASE REQUIREMENTS
Respondent Name: J P Smith [165] Submission Agent Respondent ID: 165 ID: 165 ID: SUBMISSION Since the start of the LDF process, there has been considerable progress on the science and effects of climate change. It is now increasingly recognised that greenfield sites must be retained for food and energy production to help local and national resilience. Furthermore, it is predicted that populations will start to decline by the end of the LDF period.
SCDC Response: 15, 22
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: J P Smith [165] Submission Agent Respondent ID: 165 ID: 165 ID: SUBMISSION Conclusion: " A larger scale development also has the opportunity to provide for a more meaningful set of mitigation measures which can be provided to limit the impact of development on the nearby AONB and nature conservation interests of the estuary"
Mitigation measures clearly requires undeveloped land - doubling the amount of development reduces the potential for mitigation.
SCDC Response: 9
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: J P Smith [165] Submission Agent Respondent ID: 165 ID: 165 ID: SUBMISSION comment 5: Any development East of the A12 will cause unacceptable traffic increase on already congested roads. Housing location should be planned to reduce traffic rather than encouraging increased traffic. To deal with extra 2000 homes as well as other expansion in the area will require major road development around Ipswich, beyond the capability of developer funding.
Developing to East of A12 will encourage traffic on minor roads through Waldringfield Heath and other villages in AONB avoiding congested A12 junctions. 2000 houses will cause twice the problem than 1000.
SCDC Response: 11, 13, 19, 20
APPENDIX 3 - HOUSING DISTRIBUTION CONSULTATION TIMELINE J.S. Bloor (Sudbury) Limited Respondent Name: [571] Submission Agent Respondent ID: 571 ID: 571 ID: Mr Ray Ricks SUBMISSION SP2 We support the Settlement Policy and as advised above our representations are submitted on the basis that the Main Road site forms part of the Major Centre - Ipswich Policy Area. Such an approach would be consistent with that previously adopted by the local authority and tested by sustainability appraisal.
Paragrapgh 5.10 We would support the criteria set out within this paragraph as guiding the location of future development. We are instructed to submit representations on behalf of J.S. Bloor in respect of land on Main Road, Martlesham. J.S. Bloor have an interest in that land and seek to pursue development for housing and public open space together with provision for new footpath and cycle links. For purposes of these representations we have adopted the position of the local authority that the site comprises land South of Old Martlesham and East of the A12 and lies within a Major Centre for planning purposes within the emerging LDF. The land at Main Road lies directly adjacent to the Tesco superstore which provides the principal retail site serving the East of Ipswich urban area. The remainder of the retail centre and the Martlesham Heath employment area lie within walking distance of the site. Old Martlesham village lies to the North of Main Road and extends further to the north-east and is defined as a Key Service Centre within the proposed settlement hierarchy. The Bloors land formed part of the preferred location for growth in the Core Strategy Preffered Options document (January 2009). That document was subject to a Sustainability Appraisal.
The juxta-position of existing retail and employment development to the site will ensure that development of the Main Road site will integrate with the existing community and moreover will add significantly to green infrastructure in the form of new areas of public open space and provision for additional footpaths and cycle links. The capacity of the local highway network has been tested and indicates that development of the site can be accomodated within the local highway network. Moreover, the site is particularly well related to public transport routes, being within walking distance of the Park and Ride facility at Martlesham and on principle cycle routes that link to adjoining neighbourhoods and Ipswich town centre.
SP3 We object to this policy in respect of item (ii) for the reasons set out elsewhere. Reliance solely on Adastral Park development would result in an unsound plan based on principles of deliverability and flexability. Whilst it would be appropriate to identify that the majority of development to the East of the A12 will comprise an expansion of Adasrtal Park, specific reference must be made to other land that will be allocated for development in the Site Allocations Development Plan Document to ensure a continuous five year housing land supply.
Paragraph 5.3 We object to this paragraph since it conflicts with national policy guidance and the need to identify a continuous five year housing supply. Whilst national policy guidance the need to identify a continuous five year housing supply. Whilst this may be resolved through the Site Allocations Development Plan Document it is fundamental for the Core Strategy to be clear as to the broad location within which housing supply will be delivered. In that regard, it is our view that reference merely to 2another small area of land" is insufficient as a guide to future development locations. This may be overcome by the following wording: "However, the early release of land to the East of the A12 adjacent to existing retail and employment areas in advance of the Adastral Park development is required to maintain a five year supply of land."
Appendix 3 Paragraph 5.2 We object to this paragraph in the same way as paragraph 7.02 above. The precision in identifying Adastral Park fails the test of soundness in repect of deliverability and flexibility. In the same way we would suggest the following wording: "and the preferred location for that concentration is the East of the A12 with most development forming an expansion of the employment base of Adastral Park and also on other land immediately adjoining the existing retail and employment areas."
Section 7, paragraph 7.02 We object to this paragrapgh in that it raises issues of deliverability and flexibility. Within paragraph 5.3 of Appendix 3 to the Updated Preferred Option reference is made to the need for another small site to come forward in order to ensure a continuous five year housing land supply. We make representations in respect of that paragraph elsewhere but within paragraph 7.02 the identification of land to the south and east of Adastral Park as delivering the entirety of new housing development to the East of the A12 would result in an unsound Core Strategy because it fails to provide a continuous five year supply. We would suggest that the wording be amended to read as follows: "The location for such a community remains at Martlesham with the principal location being to the south and east of Adastral Park. Other land abutting the Martlesham Heath retail/employment area will also be allocated to ensure a continuous delivery of housing land supply."
Section 5, paragraph 5.17 We would supprot the Area East of the A12 as being the preffered option for development. It is noted elsewhere in the Updated Predferred Option a reliance on major development at Adastral Park. Land at Main Road can form an initial phase of wider development to assist the local authority in meeting its five year land supply requirements. At the same time this initial phase of development will make its own contribution to community and green infrastructure to ensure that development is well integrated within the existing local community and make a positive contribution to matters of sustainability.
Section 5, paragraph 5.12 We would support the objectives set out in this paragraph to meet the local authority's housing needs. The main road site is unconstrained and therefore is capable of early development to support the council's requirement for a continuous five year housing land supply. In addition, the site is of sufficient size to provide a broad range of house sizes and types to supprot the local authority's housing needs objectives.
As advised elsewhere, the location of the site is such that it is well related to alternative means of transport and access to facilities in Ipswich town centre and other locations can be undertaken without dependence on the private car.
SCDC Response: 6, 21 Supporting comments noted
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Jenny Parker [187] Submission Agent Respondent ID: 187 ID: 187 ID: SUBMISSION To build on greenfield sites in the Suffolk Coastal area would be destroying vital food providing land. The secondary school provision in Felixstowe will be reduced with the proposed new high school & will not have room to educate hundreds more pupils. The public transport (rail) services are not adequately frequent to make a viable means of transport for workers.
SCDC Response: 11, 22
IPSWICH POLICY AREA
Respondent Name: Joan Hudson [415] Submission Agent Respondent ID: 415 ID: 415 ID: SUBMISSION I wish to register my objection to the development of the new town proposed on the BT Adastral Park site (CO9/0555). As a resident of Martlesham Heath for the last twenty one years I have witnessed considerable changes in the local environment. Our small rural village has been swamped by developments in recent years including the building of a Tesco store and Grange Farm. All these initiatives have placed a strain on the infrastructure and have altered the atmosphere of our locality. I objected to the positioning of this new development on the borders of Martlesham Heath in the first instance when it was proposed to build 1000 homes, and now the plans have been radically changed to include 2000+ houses and businesses.
The countryside is being eroded by these developments and the quality of life is being threatened for the villagers of Martlesham Heath. I consider the concept of this venture to be at the expense of the householders of our village and no concern has been shown about our welfare by BT and Suffolk Coastal who should be acting on our behalf.
SCDC Response: 16, 18, 20
8 YOUR COMMENTS
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "... the broad strategy that you have already commented, and which has achieved a large measure of agreement ...".
A 'large measure of agreement' from who?
How about some statistics, or some quotes, or some anything to support this patently untrue notion?
SCDC Response: 1
KEY SERVICE CENTRES
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "The target will be 330 new homes overall of which 1 in 3 will be affordable ones".
This is only getting referred to here in the Key Service Centres section. Surely it should apply to all the areas?
See "There is a need for affordable housing across the district" (LDF Core Strategy, Preferred Options, §7.06)
SCDC Response: See affordable housing policies DM1 and DM2
IPSWICH POLICY AREA
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "An allocation of 2,000 new homes be made at Martlesham".
As there is no identified need for the extra 1,000 houses, there is no justification for doubling the allocation, and doubling the problems.
"... integrate the development into the remainder of the Martlesham community"
The new town will be on the other side of the A12 from Martlesham Heath.
These notions also contradict all the talk of the stand alone community elsewhere in the document, as well suggesting it will be of "sufficient size to provide a relatively self contained community" and "the opportunity to provide for a more self contained development". (6.03)
SCDC Response: 16
THE OVERALL STRATEGY
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "The location for such a community remains at Martlesham although the location is specified as to south and east of Adastral Park"
What happened to the much less specific location in the previous version of the LDF, which says: "The area of search for housing sites will extend in a "half collar" around the employment area at Martlesham Heath, including BT at Adastral Park. Opportunities for sites include within Martlesham village, on the old Felixstowe Road, the sand quarries east of Adastral Park and the farmland north of Waldringfield Road." (LDF Core Strategy, Preferred Options, §3.21)
Why hasn't there been an explanation given for narrowing it to the south and east of Adastral Park?
And what happened to the advantages of a wider search area previously given? "There is also the ability to separate the area into distinct sections, thereby giving the opportunity to phase the development and also not to rely on one landowner" (Future Location Of Strategic Housing Growth In The Ipswich Policy Area , §4.3)
We are cetainly relying on one landowner now - BT.
"Allocations at Key Service Centres to meet local needs and affordable housing provision" The need is 2,722 homes per year in Suffolk (Delivering affordable housing in rural Suffolk, Ian Tippett Babergh's Strategic Housing Manager, 9 October 2009). The proposal falls far short of this.
Why?
SCDC Response: 16 Other comments noted
BASE REQUIREMENTS
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION This section seems to be suggesting that the LDF figures are minimum ones, to be exceeded by developers if they so wish.
I understand that the figures provided in the LDF are not minima, they are the actual numbers that SCDC's strategy requires to be built.
SCDC Response: 3, 4
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "1. (1050) is of sufficient size to provide a relatively self contained community including a measure of health, primary education and a district centre type facility."
Swelling a figure so it hits a target suggests either the site or the target are flawed. As 84% of locals have suggested, preferring the Felixstowe peninsula approach approved by SCDC.
"2. 1,000 is insufficient to provide a stand-alone community"
Only one respondent made this comment - BT's consultant.
What about the many respondents who called into question the need for a new standalone community at all? And who proposed instead the 'peninsula' solution?
"...A larger allocation provides the basis for a significantly improved range of community facilities"
So 2,000 houses are needed to justify providing the facilities, but the only reason the facilities are needed is to service the 2,000 houses!
Referring back to the RSS, the actual need is for 1,050 houses - and if dispersed throughout Suffolk Coastal, the need for new facilities and infrastructure would be lessened.
"The evidence suggests that the benefits do indeed outweigh the disbenefits."
This is a completely unsupported assertion. What evidence? What supposed benefits? Surely not the weakly argued jumble in this section of the document?
This is so important that the lack of evidence presented at this stage surely renders this whole line of argument redundant and the entire proposal should be thrown out.
"One of the reasons for choosing this area east of the A12 is to create a stand alone community,"
The LDF is about intelligent distribution, not a charter for the creation of new towns. To claim now that stand alone communities is an implied aim or reason is pure reverse-engineering of the facts that have led us here.
"...triggers the need for additional infrastructure, particularly secondary education which is of wider benefit to other existing communities."
Not true. See the Future Secondary School Provision Alternative Sites Assessment IPA, "Demand for one new secondary school would normally be required for 5,000 new homes"
"It also offers the opportunity to better mitigate the potential impact of visitors and residents on the neighbouring countryside and estuary through properly managed informal open space provision e.g. for dog walking."
The idea that 4800 extra people will confine their activities to walking the dog round their new town rather than journeying in their cars to the attractions of the nearby villages is hopelessly out of step with human nature.
"Provision of structural landscaping can help with visual intrusion."
Double the houses makes the site less intrusive? Landscaping can do lots of this but not this.
"The lie of the land in the proposed area, coupled with the fact that much of the land involved either has been or is scheduled to be used for mineral extraction..."
This ignores that the planning permission for the quarry stipulates that it must be returned to greenfield status upon finishing. Why is this not mentioned, but instead there is an assumption that quarry equals brownfield and that's it? This has been drawn to SCDC's attention many times.
"degree of the disbenefit from damage to the landscape, loss of agricultural land and the like from the increased size of this allocation is limited, and overall is less than that resulting from other potential locations."
This is another unsopported statement. Where is the evidence that the other areas have better or worse claims? The word limited is used, but limited compared to what?
"Increasing the numbers also offers greater funding opportunities for improving existing and creating new public transport provision which will also be of benefit to these other local communities."
It will also aid the 4800 extra people to get to the local communities.
"Development on this scale must be undertaken as part of a comprehensive development which places significant emphasis on mitigating these potential impacts. This could include significant levels of advanced planting;"
Mitigation will do little to help with 1050 houses. To claim it can somehow be even better with double the number is pure sophistry.
"large well managed open areas for dog walkers etc which would help to lessen the impact on the nearby AONB and estuary."
See above. Only a non-dog owner could ever write this. Dog walkers will go to the river walks along the Deben at Waldringfield.
"However the impact of 2,000 homes as opposed to 1,000 on individual junctions etc when linked to new and improved transport infrastructure is limited"
This is saying that doubling the traffic will have limited consequences. It will have double the consequences: that is obvious.
"but will help to secure the necessary developer funding to secure these upgrades to a good standard."
This funding is necessary, surely, whatever the size of upgrade. To suggest it needs to be bigger to acheive a standard is highly questionable.
SCDC Response: 4, 9, 11, 16, 17, 20
6 THE COUNCIL'S RESPONSE & REASONS FOR PROPOSED CHANGES TO HOUSING DISTRIBUTION
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "The traffic studies which have been done indicate that the A14...will be able to cope"
The EERA Newmarket to Felixstowe Corridor Study says: "Demand on the Orwell Bridge is forecast to increase in the future...30% of the demand in the peak hour will not actually be able to flow through the link because of congestion."
All this is without the extra traffic due to the proposed 2,000 and 1,000 houses at Martlesham and on the peninsula.
SCDC Response: 12
HOUSING DISTRIBUTION FELIXSTOWE/WALTON AND TRIMLEY VILLAGES
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "5.19 All of these options however were rejected in favour of a Preferred Option dispersed strategy of "organic and evolutionary growth"
Why is this allowed over on the Felixstowe peninsula, but not for the rest of Suffolk? All the good reasons for it would provide a handy checklist for all the failings of the East of the A12 new town.
"...this would be more difficult than developing on one or two large sites."
East of the A12 it is evidently not only more difficult, but also impossible.
SCDC Response: 15
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "5.17 None of the five options considered offered a perfect solution."
This is understandable.
But if this was the case, the search should then have been widened to find smaller sites (the local preference) to make up the numbers.
But SCDC took the least-worst option and bent it into all sorts of shapes until it was acceptable - if only to them.
Now, having admitted the choice was flawed before they started, they are doubling the number of houses.
SCDC Response: 4
THE PREFERRED OPTION REPORT DEC 2008
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "5.16 The evolution of proposals through the above two reports are summarised below."
The word 'evolution' creates the impression that local opinion was taken into account. The first report saw an 86% rejection rate and the second, 90%.
SCDC Response: 1
THE FURTHER ISSUES AND OPTIONS REPORT FEB 08
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "5.14 ...the Further Issues and Options Consultation, which targeted specifically the East of Ipswich..."
I understand the decision to go for Area 4 (East of the A12) was made by SCDC discovering non-existent 'advantages' in the site as opposed to the others and ignoring Area 4's many disadvantages. This is carefully detailed in the Waldringfield Parish Council's response to the Preferred Options consultation, December 2008.
SCDC Response: Noted
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY?
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "5.12 As noted, the broad scale and distribution of development has evolved and refined over time as a result of public consultation."
It is hard to see how the sudden imposition of a further 950 houses on an unwanted single site (90% against) is the "refinement as a result of public consultation" so cosily referred to here.
"To provide new housing where it will support new employment provision..."
BT is shedding 15,000 jobs this year and, as stated above, only 3% of BT employees live in Martlesham (BT's own figures). The case for BT providing employment for the new town is therefore very weak, when there is no concrete connection between local living and local employment.
"Limiting any adverse impact of new development on existing communities, countryside and wildlife"
If this is the case, why are the RAMSAR, AONB, SSSI and SSS sites, some within 1km of the site, not being protected? The Waldringfield SSSI is within the site itself.
This objection resulted in a previous, 90% smaller planning application (C/05/04930), being refused.
"To make best use of known "brownfield" development opportunities;"
The Planning Permission for the quarry within the site stipulates that upon completion it returns to greenfield status, preferably a bio-diverse heathland, for which there is a call for a dramatic increase in national policies.
"To provide a high quality, sustainable living environment for all residents, new or existing"
How the surrounding villages are served by 4800 new residents swamping the area is not explained.
SCDC Response: 7, 9, 15, 18
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "5.09 ...The main concerns related to the area East of Ipswich and Felixstowe/Walton and the Trimley villages where the bulk of the new homes are proposed."
This suggests that the five areas we were given to choose from were not all flawed, and SCDC's decision to go with Area 4 has never been adequately explained and therefore remains to be questioned by the independent inspector - see the Waldringfield Parish Council website for more on this.
"5.10. We should look first to re-developing old "brownfield" sites before looking to identifying new greenfield sites; (these are however limited in number and scale);"
"Building on high quality agricultural land should be avoided as far as possible"
The Planning Permission for the quarry within the site stipulates that upon completion it returns to greenfield status, preferably a bio-diverse heathland, for which national policies call for a dramatic increase.
"The road, rail and other public transport networks should be capable of accommodating the traffic and journey requirements that new housing inevitably brings with it;"
With only 3% of Martlesham working at BT (BT's own figures) it is hard to see how 4800 extra occupants will not swamp these services when they drive out of the new town to do practically anything.
"New housing should allow integration with existing communities but at the same time should respect and maintain the character of individual settlements and communities;"
Apart from the contradictory nature of this notion, the new town will be built the wrong side of the A12 to integrate with the existing village. Footbridges and road-widening will not make a larger community.
"In deciding where new development should go, it should respect the quality of the local environment;"
2000 houses are to be built on heathland.
"Protection should be given to wildlife and to the landscape, particularly those areas that are designated as being of national and international importance;"
If this is the case, why are the RAMSAR, AONB, SSSI and SSS sites, some with 1km of the site, not being protected? The Waldringfield SSSI is within the site itself.
This objection resulted in a previous, 90% smaller planning application (C/05/04930), being refused.
"That housing and jobs should be provided in tandem"
BT is shedding 15,000 jobs this year and, as stated above, only 3% of BT employees live in Martlesham (BT's own figures). The proposal therefore pins its employment for the new town on BT, when there is no concrete connection between local living and local employment. Furthermore, BT has recently closed its graduate programme, with 'no plans' to reopen it.
SCDC Response: 7, 9, 15, 16, 17, 20
5 HOW HAS THE HOUSING DISTRIBUTION BEEN DRAWN UP? AND HOW AND WHY HAS IT CHANGED?
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "5.02...the opportunities and constraints for each of the main settlements or settlement types."
Here the opportunities rest with BT. BT shed 15000 jobs last year and is shedding 15,000 jobs this year (BBC website). Only 3% of BT employees live in Martlesham (BT's own figures). The proposal therefore pins its employment for the new town on BT, when there is no concrete connection between local living and local employment. Furthermore, BT has recently closed its graduate programme, with 'no plans' to reopen it.
SCDC Response: 7
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT?
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "4.01 This consultation is very focused."
This near-doubling of houses on Area 4, (a highly opaque SCDC unilateral choice in itself), the creation of a new town the size of Woodbridge, with no jobs, no train station, poor road connections and requiring the destruction of a beautiful piece of countryside, is being allowed just two months of consultation in a 42- month process, with more to came.
"4.02 The basic principles behind how the houses are distributed remain the same."
Why has there never been an explanation for the two completely different policies applying to the Felixstowe peninsula and to the east of the A12?
"4.04 It is also important to bear in mind that these houses will not all come at once."
Why is this important? We want to know the full impact of these proposals, even if it doesn't worry SCDC.
SCDC Response: 15, 16
3 BACKGROUND
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "3.01 Since 2004, Suffolk Coastal has regularly consulted with..."
This creates the false impression that having consulted, SCDC took notice.
"3.02 3) ...BT research and development at Martlesham Heath...This wider economic role was an additional factor taken into account when the district housing numbers in the RSS were set."
BT is shedding 15,000 jobs this year and only 3% of BT employees live in Martlesham (BT's own figures). The proposal therefore pins its employment for the new town on BT, when there is no concrete connection between local living and local employment. Furthermore, BT has recently closed its graduate programme, with 'no plans' to reopen it.
"3.02 4) ...the RSS also broadly recognises that the quality of much of the Suffolk Coastal countryside, its soils and the wildlife it supports are of national and in some cases international importance"
If this were the case, the Waldringfield Pit SSSI, actually within the proposed site, would get a mention.
"3.03 ...In doing so it has to take on board all of the sometimes conflicting issues - balancing local, regional, and national priorities".
This implies local views were balanced into the mix. They were not.
Three consultations were conducted by SCDC. In February 2007 86% of residents opposed the site, favouring the persistent belief of the locals that a wider distribution of smaller sites was the way forward. The 1050-unit site was 'Area 4' of an unsuitable selection of 5 major areas, which was approved by SCDC with no evidence offered for its suitability over the other sites.
In February 2008 the option of voting for smaller sites was removed from a SCDC consultation, ignoring the 35% who had favoured it previously.
The July 2009 90% objections were registered for the single site, with only one in support (BT's own consultant) recommending increasing housing from 1050 to 2000: yet this was the course adopted.
"3.03 ...maintaining the quality of life currently enjoyed by the local community."
Building a 2000 house new town will so fundamentally change the area as to make this a nonsense.
"3.05 Inevitably, for a plan such as this, not everyone will be happy with what is proposed"
This implies that some people are happy with it, but no evidence is put forward to support this view.
"3.06...The Council would like at this stage to thank all of those people and organisations who have taken the time to comment to date, and whose views have helped shape, and re-shape the Core Strategy to where it now stands."
This implies the views of locals have been listened to. They have not. 90% in SCDC's own consultation oppose this site. One individual supports it: he is BT's consultant.
"3.07...it is therefore important that everyone has the opportunity to comment on this outstanding issue"
In a process lasting 42 months so far, why we have only 2 months to comment, if this is truly the case?
SCDC Response: 1, 7, 9, 15, 17
2 THE CONSULTATION IN BRIEF
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION "2.01 For many aspects other than housing distribution the Core Strategy document has now achieved a measure of support. For this reason this current consultation focuses on changes to the housing distribution element."
No evidence is put forward in this document that the measure of support is so overwhelming as to make the narrow focus justified. Unless you count BT's consultant's support.
"The changes are being put forward specifically to address concerns raised in response to the Preferred Option 12/08, consultation on which finished in February 2009, and also to recognise other changes in circumstances since the content of the Preferred Option 12/08 was formulated earlier in 2008."
This period of nearly two years of changes cannot be compressed into one 'focussed' question.
Housing figures generally: these statistics are all out of date as they take no account of houses built since April 2007. Not even an estimate has been put forward.
"Ipswich Policy Area2 east of the A12 at Martlesham"
It was, in fact, Area 4.
"the strategy of development east of the A12 at Martlesham being in a single location forming a new community, but adopting a dispersed strategy for development in Felixstowe/Walton/Trimley."
Why one policy is good for one area and inappropriate for another, especially as it is the wish of the people expressed in SCDC consulatations, is not explained.
"2.08 The following sections set out the background to the process so far and more detailed information on how the housing distribution was originally drawn up and the reasons for the changes now suggested."
This suggests what follows is a)detailed, b) accurate information, c) creates any usable picture of how the process actually happened, d) that reasons of any weight will be proposed.
SCDC Response: 2, 15
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION The document begins with Natural England commenting on previous plans for the new town as having 'negative impacts on the SPA' 'serious negative impacts on the AONB' and a 'negative impact on the heathland and estuary'. (4.2 to 4.7)
Then SCDC starts to build a case to refute this. It is established at 5.3.17 that visitors to the Deben would increase 'in the range of 2% - 5%'. This might not sound many but later in Appendix 6 both Mick Wright (Site Manager for the Suffolk Wildlife Trust up at Snape) and Nick Collinson (Suffolk Coasts and Heaths) confirm that in their professional opinion a 1% increase would cause harm to their SPA.
Then, at 5.4.2, a crucial standard for driving or walking from a new town to an AONB is established, which will subsequently be frequently relied on.
It is very hard to refute these figures - they are 1km for walking and 8km for driving: evidently faced with any further distances than these, people just won't venture out.
This is based on research in Dorset in 2005, and it is impossible to say how applicable it is to Waldringfield.
Surely the river walk along the Deben might reasonably be expected to make some of the new towners walk a bit further afield? Possibly that 800 extra metres that SCDC says they can't manage?
It then goes to say that if there is no public car park, they won't go there.
There are two things here - the first is that bikes are not mentioned (which calls into question the validity of the original research), and the second is that illegal parking at a destination is a distinct possibility, evidently unheard of by SCDC.
(Please see how a public car park appears and disappears in this document at representation ID 258, and how it used to justify the assertion that no damage will be caused by 2000 new houses less than 2km away from the Deben.)
There is then a conclusion of sorts. At 6.2.18 and 6.2.22 they admit "it is not possible to ascertain that there will be no adverse effect upon the integrity of the...Deben Estuary SPA."
This negative picture is confirmed by 6.2.31: "An allocation of 2000 houses at Martlesham could potentially cause problems to the Deben Estuary, from increased visitor use causing significant disturbance to SPA birds; trampling of water-edge habitat in Martlesham Creek containing a rare snail might also occur, although this would be an impact upon the component SSSI rather than a SPA issue."
This would appear to make a negative recommendation inevitable. But then comes the 'mitigation' that will make everything alright again for SCDC (but not the Deben.)
At 6.2.35 they say "Provided that development is greater than 1km from a site and that accessibility to the greenspace provision is adequate...there is expected to be no new high levels of disturbance [to wildlife].
Briefly, a greenspace is the idea that providing green spaces in the new town, and a country park (7.2.11) north of Martlesham will busy the new towners so much they won't be bothered with coming to the Deben.
However, the next para, 6.2.36, sends the argument in an unexpected direction: "The combination of the allocations at Martlesham with other allocations in Suffolk Coastal and Ipswich will not change this conclusion." Previously this document has busied itself with possible combinations of sites with their possible outcomes, but at this point this assertion is made and no evidence is offered.
Why?
SCDC then builds the mitigation idea:
7.1.1 "The aim of mitigation is to reduce impacts until they no longer have an adverse affect upon the integrity of...sites. The preferred solution is to avoid proposing elements of the plan which would have an adverse effect," which would be fine if that was a full stop, not a comma, i.e. If you don't build a new town in the wrong place, you won't have the problems that go with building a new town in the wrong place.
But SCDC needs to build a new town in the wrong place, so it goes on with the next preferred solution where they "permit the impacts but carry out measures which will reduce the impacts to an acceptable level."
Put another way: we can't build it here properly or appropriately. We'll just have to cover that up as best we can.
The next part is complicated: at 7.2.11 "there may still be some residual disturbance of birds, probably caused by local people engaging in low-key recreational activities on European sites near their homes, such as dog-walking. These people would not necessarily always be attracted to Country Parks."
No explanation is offered for the reason dog-walkers don't want to go to the country parks. Why not? These dog walkers, though, carry the reponsibility for the 1% disturbance Mick and Nick didn't want (7.2.11) - not the new towners.
And then comes a further unsupported conclusion: "This residual disturbance would be an impact referable in particular to the aggregation of smaller provisions across Suffolk Coastal District."
The English here is almost impenetrable. Is SCDC claiming that opting generally for the idea of small site allocation (favoured by 90% of locals in the July 2009 consultation) would cause more disturbance to wildlife than a 2000 home new town?
If so, SCDC has argued this very poorly.
Then a notion with worrying consequences is introduced. It is in several stages. First, at 7.2.12 "Mitigation...requires a programme of ... writing and implementing a visitor management plan for key sites without such a plan, or revising existing plans, to reduce visitor impact."
That is to say, instead of a decision not to build, a management plan is proposed. This is report-speak at its worst.
They then go on to suggest such a plan might include "car parks" and "paths" at the sensitive AONB sites, amongst other things. This completely negates the notion that visitors are going to avoid the Deben because they can't get to it or park there. Now SCDC intends to build them the means to do so.
It goes on with recommendations for wardens, by-laws etc, ending on "a monitoring programme, to determine visitor numbers and allow the impact of the visitor numbers to be identified, throughout time."
Put another way: if you build 2000 houses, so long as you monitor the problems a child could predict, that's acceptable. This is properly called Fiddling While Rome Burns, and this sort of sophistry is an insult.
7.2.13 is a debate as to who should do all this monitoring, ending with asking who should pay for it. Evidently it is expected "that funding should be directly related to housing provision, and at least in part funded for example by a tariff on new housing."
Put another way, locals will fund the majority of a scheme, (along with a small contribution from the developers), to monitor the destruction of their way of life.
This section ends with the statement 8.1.2: "if the mitigation...is implemented...[the] housing policies will have no adverse effect upon the integrity of any...site."
Which is the conclusion of their case against what could be called the 'wildlife' defence - rightly foregrounded by locals.
But incredibly
SCDC then proceeds to claim that there's insufficient evidence to make any of the assertions made above: the evidence is 'poor', 'sparse', 'limited' inconsistent'(9.1.1-3) .
In the event someone points out that SCDC is preparing to build a 2000 home new town on this shaky foundation, they then say at 9.1.4: "This assessment is founded on the evidence base which is available but it is considered that a stronger evidence base would result in a more precise assessment, particularly in respect of the impacts of additional housing provision."
Put another way, 'had we actually got the appropriate evidence, we might have been in a position to actually advise on what we we asked to advise on. As it is, we are waving through an unfounded conclusion instead."
9.2 is a subsection on what was actually needed to do the job properly, and who SCDC thinks they might be able to get to it.
Meanwhile, the assertions that will build a 2000 home new town go unchanged.
(In the appendices there are many details of Sites of Special Scientific Interest. But at no point in any of these documents is there a mentioned of the Waldringfield Pit SSI - which is actually within the new town site itself.)
SCDC Response: 9, 17 Comments noted
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION It is claimed in 6.2.44 that "there [is a] car park at...Waldringfield, within 8km of the indicative housing area..."
It is within 2km. It goes on:
"...The car park at the Deben Estuary at Waldringfield is privately operated for users of the pub and sailing club, and is not available as a starting point for estuary-side walks. Given this lack of parking, it is possible to ascertain that the integrity of the Deben Estuary at Waldringfield will not be affected by the housing allocations at Martlesham..."
The car park, in practice, is available to all for the purchase of a drink during a stay. This whole conclusion is therefore invalid.
To dismiss something as environmentally sensitive as the Deben Estuary on the basis that it is a 'restricted' car park is astounding. Especially when any local knows it to be untrue.
Looking elsewhere in the document, however, it emerges that SCDC thinks there is a public car park in Waldringfield after all.
In 6.2.26 it says "The Deben Estuary near Martlesham is believed to have a low to moderate level of terrestrial recreational activity at present...There is no nearby visitor parking, with the nearest public car parks being in Woodbridge to the north and Waldringfield to the south."
So which is it? This is vital, because unbelievably, the delicate beauty of this wonderful river will be shoved in the trash if some non-local assessors decide the Maybush car park will never ever be used by visitors.
This hopeless mess is SCDC's best effort in preserving an Area of Outstanding Natural Beauty. a RAMSAR and a SSS.
Then there is the issue of building a path so the New Town inhabitants can come straight to the Deben by foot:
6.2.32 "The master-planning of new housing may also include a desire for new footpath links to the estuary. It is therefore possible that visitor recreation activity would substantially increase on the foreshore of Deben Estuary SPA, bringing in high levels of disturbance to what is currently little disturbed and a 'refuge' area for SPAqualifying birds. It is not possible with the current state of knowledge to be able to quantify the new amounts of disturbance or the impact caused. These matters will relate to the location of housing, its distance from the SPA and ease of access to the SPA.
So SCDC is perfectly capable of understanding the disastrous impact of a footpath that hasn't been built yet, but can't make up its mind about the car park giving access to a river walk that is immediately in peril.
With this part of the document so shakily argued, this entire section will have to be redone if it is to convince locals any case has been made.
SCDC Response: 9, 17 Comments noted
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Jonathan Ruffle [181] Submission Agent Respondent ID: 181 ID: 181 ID: SUBMISSION It is claimed in 6.2.44 that "there [is a] car park at...Waldringfield, within 8km of the indicative housing area..."
It is within 2km.
"...The car park at the Deben Estuary at Waldringfield is privately operated for users of the pub and sailing club, and is not available as a starting point for estuary-side walks. Given this lack of parking, it is possible to ascertain that the integrity of the Deben Estuary at Waldringfield will not be affected by the housing allocations at Martlesham..."
The car park, in practice, is available to all for the purchase of a drink during a stay. This whole conclusion is therefore invalid.
To dismiss something as environmentally sensitive as the Deben Estuary on the basis that it is a 'restricted' car park is astounding. Especially when any local knows it to be untrue.
SCDC Response: 9 Comment noted
1 INTRODUCTION
Respondent Name: Jude Ilett [497] Submission Agent Respondent ID: 497 ID: 497 ID: SUBMISSION Dear Sir/Madam,
I would like to comment on the recent changes to the LDF planning policy review. I understand that from the point of view of the district council concentrating on large housing sites for the next five years makes perfect sense (particularly when a change of government next year may move the goalposts yet again). I do, however find it frustrating that decisions on the proposed, smaller development sites are being further delayed. An email I received from the COuncil just over a year ago stated that
"All of the sites submitted to the Council for consideration in the LDF will be published in the Site Specific Allocations & Policies - Issues & Options stage consultation in November 2008 and the period for responding will probably last until early February 2009. The sites are published without any opinion or judgement from the Council however, factual information for example, if in a flood zone, has been included in order to help people form their views on the sites. The next stage will be for the Council to take on board all comments made and progress towards the Pre-Submission stage of consultation on this document. At this point, the Council will then be stating (with reasons) which sites are considered 'preferred' and which are rejected for development - again a full public consultation will happen so that people can express their views on the decisions made."
For those of us who are still awaiting an indication on which of the submitted 400 sites are going to be 'preferred' and which 'rejected', another 5 years in limbo is a depressing prospect. Surely there could be some sort of on-going triage system where someone from the planning department could be tasked with indicating to interested parties those sites which fit the criteria for development, those which definitely do not and those which will need further investigation. Then at the end of the first five years there will be some sort of approved site list for the next five years and those of us who have an interest in specific sites have some sort of resolution after the many consultation periods thus far.
SCDC Response: Comments on sites noted
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Judith Hedges [189] Submission Agent Respondent ID: 189 ID: 189 ID: SUBMISSION I disagree with a + b. 1000 dwellings is still too many to build in Felixstowe. Such growth should be more equitably across the whole of Suffolk Coastal district, in particular around small villages that need to increase their population to maintain essential local services. Felixstowe already has an excellent population size for a viable town. If some shops close in Hamilton Rd that is due to out of town shopping and hopefully a change in people's life styles such that shopping is not a main leisure pursuit. The closed shops can revert to housing. Felixstowe should not be targeted for major growth just because it has a port. It is at the end of a peninsula with a single access road surrounded by AONB. All other SCDC towns + villages have better access. Port related jobs + storage can be spread along the A14 corridor. Retirement towns frequently thrive eg. - Aldeburgh/Southwold. Felixstowe must work at its own niche not to try and become a bustling area of major growth. Youngsters have always spread their wings for work hence improving society's gene pool.
SCDC Response: 22, 24
8 YOUR COMMENTS
Respondent Name: June Everson [362] Submission Agent Respondent ID: 362 ID: 362 ID: SUBMISSION A large development at Martlesham will significantly affect health of residents through pollution. Road systems will not cope with increased traffic - particularly the Orwell Bridge and Waldringfield road.
Sewerage, electricity and water facilities will not cope with such an increase.
BT is downsizing jobs, axing its graduate programme with the future looking worse. Therefore there will be increased commuting with no local work.
An area of natural beauty will be destroyed by the proximity of a new urban developement.
Schools and surgeries would need to be built at the same time as houses as local facilities cannot support extra growth.
SCDC Response: 7, 12, 17, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: K R Palmer [399] Submission Agent Respondent ID: 399 ID: 399 ID: SUBMISSION 1. Summary In this, its latest consultation document, SCDC is putting forward a major change to its already earlier flawed proposal to create a major housing development within the Ipswich Policy Area East of the A12. This will creat a Town the size of Leiston (and capable of becoming even larger than Woodbridge). This is contrary to previous Council policies and will result in the urbanisation of the currently rural area east of the A12 and will swamp nearby communities. I am strongly opposed and for the reasons detailed do NOT consider it justified or better meets the broad strategy for the development in the district. 2 General Comments 2.1 SCDC is putting forward a revised preferred option for a single very large housing development in the Ipswich Policy Area (IPA) east of the A12 and south and east of BT's Adastral Science Park which will permit at least 2000 homes (virtually double the Councils earlier proposal) and, no doubt capable of increasing even further (after all BT has made no secret of its idea to potentially increase that number to 2,500 and, I have even heard it suggested elsewhere, to possibly 3000+ over an extended period). 2.2 Yet this is despite earlier an overwhelming number of public responses to previous consultation exercises indicating that this is not what the local public wants eg:-responses to the 'Issues and Options' document (Feb 2007) show only 14% of respondents supported a single large site option while 86% wanted a multiple site strategy of one kind or another pursued*. -responses to the 'Further issues and options' document (Feb 2008) and 'Preferred options in respect of the area east of Ipswich' (Dec 2008) indicated a large majority against a site east of the A12*. 2.3 Over recent decades SCDC seems to have pursued a policy for the IPA whereby all significant residential development has been restricted to the rectangular area south of the A1214, west of the A12 and north of the A14. The reasons previously given by SCDC for changing that policy for the site east of the A12 are not convincing and even less so when a development of the size now proposed is contemplated. 2.4 The points made above would appear to indicate that SCDC is prepared to proceed with a proposal contrary to the wishes of the overwhelming majority of respondents and which closely mirrors the recent BT planning application for the same area. It begs the question: 'Has SCDC already decided to go down the route of adapting its LDF proposals so that they support the latest BT planning application or one similar and that this latest consultation exercise is simply a matter of satisfying the formalities but in substance is not a consultation at all?' I sincerely hope that is not the case, that the Council will keep an open mind to all representations and will not simply be persuaded by representations made on behalf of BT and its planning consultants. Indeed, I wonder what the public response would have been if the latest consultation document had asked a much simpler question; -'Do you support or oppose the creation of a town the size ofLeiston, larger than either Martlesham or Martlesham Heath and 70% the size of Woodbridge with the capacity for further expansion immediately south and east of BT's Adastral Science Park?' The response from the district, I suggest, would be an overwhelming 'No'. 2.5 Finally in my view the consultation document does not adequately explain why, in the case of IPA, the policy is for all the new development to be concentrated on a single site East of the A12 and the number of homes doubled and yet for Felixstowe, Walton and the Trimleys the precisely opposite dispersed policy is being adopted and the numbers of homes reduced. Is this because the representatives for those areas have been in a better position to argue their case than those representing Martlesham, Martlesham Heath and Waldringfield who have no representation on the body advising the SCDC Cabinet? * source NANT presentation 3/11/09 3. Specific Comments 3.1 This revised proposal will, even more than the earlier one, lead to the urbanisation of what remains a rural area east of the A12. That rural area provides a real buffer to the Area of Outstanding Natural Beauty further to the East of the A12. The propsal will enable an application for planning permission similar to Bt's recent application to be granted and for development to take place almost right up to the AONB boundary. It will inevitably encourage other developments to be pursued. We are already seeing increased demand to permit developments to the west of Felixstowe. SCDC should be establishing a clear policy to prevent the increasing spread of urbanisation along the peninsular between the River Deben and the River Orwell keeping major developments close to the major centres and not just following the A12 and A14 roads. There is little to suggest that any enhancement of the BT Adastral Science Park will lead to a large increase in housing demand for workers on that site. Indeed at present BT is tending to downsize its own workforce requirements. So why a 2000+ homes development alongside it? 3.2 The recent BT planning application provided are a very good insight of what may happen on the proposed site. In no way can that be described as '...creat[ing] a new community/neighbourhood alongside but not overwhelming existing communities at Martlesham. Martlesham Heath and nearby neighbouring villages' (the language used in SCDC's own preferred option para 3.20 of its earlier consultation exercise). As that document further stated (para 3.23) '..the A12 is a significant factor. The option represents an extension of the urban area beyond this major route. Isolation may be the outcome. The area is also close to an Area of Outstanding Natural Beauty as well as areas of wildlife and geological interest...' In fact what will happen is that 2000+ new homes will overwhelm the existing communities. 5,500 people, their, say, 2000+ cars and all the other resources they will need will make an immense difference. The increase from 1050 to 2000+ homes compounds the difficulties. SCDC's own estimates indicate an increase in traffic of 40-50% at peak times. The A12 will become an even greater barrier given that it will need to be 6 and even 7 lanes wide in places, and that is even before any implication of a new Northern Bypass for Ipswich will is being raised in the Ipswich LDF (and not mentioned at all in the SCDC consultation) and increased traffic from an enlarged Felixstowe Port are taken into account! 3.3 The BT style of development will in no way be harmonious with the rural environment and abutting an AONB. It is a major urban housing 'in your face' development that cannot be seen to be blending into the local environment. No extent of tree planting etc will hide 3 and 4 storey housing of the density being contemplated. 3.4 New residents will often have to rely on their cars for transportation given the site's isolation and its separation from other communities by: - the A12 to the west - the Adastral Science Park and MH Business Park to the north - the small local communities served only by narrow country roads to the east and south. 3.5 All in all the updated preferred option proposal for the area south and east of Adastral Science Park will have an enormous detrimental impact for the area and therefore cannot be justified and better meet the broad strategy for development in the district because: - there will be major increases in noise, pollution and social pressures - a greenfield site (where even extraction is subject to planning conditions requiring reinstatement in due course) will be despoiled right up to an AONB - traffic will become a nightmare for all the surrounding communities and aything done to 'improve' the A12 will do nothing to help elsewhere with the impact of 2000+ more cars on many local narrow roads and further afield such as Woodbridge - it will amount to a gross urban intrusion in a rural environment - and will inevitably create undue pressure on infrastructure. 4. Overall We all probably recognise that further development and homes have to be incorporated into the district to some extent but this is neither the best or right way to do it and is contrary to the Council's approach in all other locations.
SCDC Response: 1, 7, 12, 13, 15, 16, 17, 18, 19
8 YOUR COMMENTS Kesgrave High School (Mr Nigel Respondent Name: Burgoyne) [44] Submission Agent Respondent ID: 44 ID: 44 ID: SUBMISSION We understand that secondary provision would be placed under unreasonable strain if 2,000 houses are developed. Unfortunately, the school has not been involved in the decision making process by the Local Authority, and we do not have full dedtails of the Suffolk Coastal District Council analysis of 15 sites for a new school. We belive that three sites were under servious consderation. The Old Felixstowe and Mr Pipes Field sites seem unsatisfactory, inadequate choices, in terms of travel distance for pupils and access. We woule be happy to assist and comment further, but unfortunately we do not have details of the site analysis carried out by David Lock Associates.
We do question the viability of a new school for under 500 students, and to this end we have submitted to Suffolk County Council a proposal for a Hub to serve the High School that would enable us to cope with an additional 300 students. This could be built either at Adastral Park, or perhaps on land adjoining the school site, depending upon planning decisions. We are always keen to discuss options with the Local Authorities at District and County level, but feel we are usually left out of the loop!
We are very willing to be involved to ensure that the long term needs of children in the area are met, and the transition period is eased.
Governors of Kesgrave High School
SCDC Response: Noted
APPENDIX 5 - REVISED SETTLEMENT HIERARCHY Kettleburgh Parish Council (Mr Respondent Name: Trevor Jessop) [206] Submission Agent Respondent ID: 206 ID: 206 ID: SUBMISSION The proposed changes, particularly in regard to Kettleburgh, are justified and reflect the rural nature of 'Other Villages' within the Suffolk Coastal District
SCDC Response: Noted
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009 Kettleburgh Parish Council (Mr Respondent Name: Trevor Jessop) [206] Submission Agent Respondent ID: 206 ID: 206 ID: SUBMISSION The mitigation suggested in Sections 7.1 and 7.2 of the 'Appropriate Assessment' document should be adopted and implemented.
SCDC Response: Noted
THE MARKET TOWNS
Respondent Name: Lesley Beaumont [314] Submission Agent Respondent ID: 314 ID: 314 ID: SUBMISSION Fast tracking the development of Sizewell C must call for housing in the Leiston area to be considered immediately and take priority.
SCDC Response: Noted
THE UPDATED PREFERRED OPTION REPORT JULY 2009
Respondent Name: Lesley Beaumont [314] Submission Agent Respondent ID: 314 ID: 314 ID: SUBMISSION SCDC confused the public in their presentation (Feb 2009) of the LDF Preferred Option by referring to and including diagrams and models of an outstanding planning application (BT) which we were told could not be considered in this consultation of the LDF.
Part of Site 4, as a stand alone development was the least preferred option in a survey of residents. I STILL STRONGLY OPPOSE a large conurbation of housing as opposed to a dispersal of housing throughout Site 4.
Considerable environmental impact will be caused by the building process and increased traffic close to Ipswich Heath SSSI and the River Deben AONB.
SCDC Response: 4, 12, 13, 16, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Lesley Beaumont [314] Submission Agent Respondent ID: 314 ID: 314 ID: SUBMISSION I am opposed to the increase of housing for Site 4 from 1050 house to 2000 house.
I also don't not agree with one large development as it will cause damage and a dramatic change in circumstance for the existing communities and environment.
SCDC Response: 4
THE OVERALL STRATEGY Levington and Stratton hall Parish Council (Mrs Marian Respondent Name: Rose) [442] Submission Agent Respondent ID: 442 ID: 442 ID: SUBMISSION We reluctantly support the revised proposals from SCDC on the increased number of units at Martlesham on the basis that infrastructure services can be more appropriately provided, and the scale of development should enable more 'green' opportunities.
We note the reduction of units in Felixstowe and the potential threat to the economic viability of this locality.
As this recommendation contravenes the Parish Council vision [i.e. Ipswich expanding to the east of the A12] we suggest that all future Ipswich expansion is between the A12 and the current Ipswich town boundary.
The Parish Council has also considered the 4 planning scenarios contained within the revised East of England plan. These contain proposals for even larger increases in residential developments. the Parish Council would welcome your comments on the likely development areas both within the ipswich policy Area and Suffolk Coastal District Council. We would also welcome information on future development areas for business use.
SCDC Response: Noted
IPSWICH POLICY AREA
Respondent Name: Louise Brearey [213] Submission Agent Respondent ID: 213 ID: 213 ID: SUBMISSION This will create a new town in the Suffolk countryside, it is excessive and the infrastructure cannot cope. It will ruin a rural area
SCDC Response: 4, 18, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Louise Brearey [213] Submission Agent Respondent ID: 213 ID: 213 ID: SUBMISSION The increase in housing numbers will have a significant adverse impact on the village of Waldringfield, through increased traffic and loss of countryside. It is in danger of becoming a suburb of the new development. Waldringfield's special riverside facilities are enjoyed by residents and visitors. Waldringfield Sailing Club attracts members from a wide geographical area. The tranquillity of the village will be severely compromised.The environmental impact will be significant. The current infrastructure is completely inadequate for this size of development.
SCDC Response: 17, 19, 20
APPENDIX 5 - REVISED SETTLEMENT HIERARCHY
Respondent Name: M and D Lewis [404] Submission Agent Respondent ID: 404 ID: 404 ID: SUBMISSION I have read all the consultation/discussion documentation available at this stage. My specific interest is some what parochial - proposed change to housing distribution FRISTON parish. However I have tried to balance my views by considering the situation in total.
I might say in doing so I have a far greater appreciation of the complexity of the work undertaken by the planners. In general I feel you should be congratulated on the work done so far. It was never going to be possible to please everybody, either in terms of interest area/subject or residential location.
I should like to comment on the sustainability appraisal of Core Strategy and Development Management Policy document. I offer the following (hopefully helpful) operational suggestions:-
It has become increasingly clear to me that the inadequacy of our highway infrastructure is a major bugbear that adversely impinges on virtually every aspect of live in Suffolk Coastal.
The A14 has become one of the most dangerous and hated routes in the country. The planned development, industrial and housing, in the Felixstowe area will not ease matters. Similarly the A12 is a National disgrace - where else in the country can one find a major trunk road with so many 30 and 40 MPH restrictions and so few sections of dual carriageways? There is a saying (true) that the weather will not cross the A12, I am not surprised, nothing else can!
Many of the significant main development centres identified in the development plan are located either side of these roads. Safe crossing provision is a vitally important factor. Not only because it will reduce unnecessary main road use = traffic density, but because it will improve the local traffic and viability of settlement types. Plus quality of life for all residents of Suffolk Coastal.
Of course this won't solve all planning issues you have highlighted but it would ease or enable a good number of them.
Finally I return to the revised Settlement Hierarchy changes and FRISTON village in particular.
I am pleased to note that Friston has been downgraded from a Local Service Centre to Other Village status. This is entirely sensible and since the February 09 consultation Friston has lost its only public house and the post office provision (2 hours 1 day per week) has been reduced. Further the trend of houses becoming second homes (weekenders) has continued ie less permanent residents.
Many thanks for keeping me on your mailing list.
SCDC Response: 12, 13 Other comments noted
IPSWICH POLICY AREA
Respondent Name: M and R Quantrill [471] Submission Agent Respondent ID: 471 ID: 471 ID: SUBMISSION We are strongly against this large scale housing development near Waldringfield for the following reasons: Loss of agricultural land (cannot afford to loose even one acre.) Traffic congestion and extra lorry movement. Increased traffic coming into the village of Waldringfield with no public parking.
No room in schools for more children...school are already bursting and secondary schools already over subscribed.
Hospital and emergency treatment will be put at risk. More people will dies...... long waits are here already. Dr's surgeries are already overspilling as so are the NHS dentists.
Destruction of our local environment....heath land and wildlife. Beach will be overcrowded and more congestion will occur at the Maybush end causing problems for local people to leave their homes and more difficult for the emergency vehicles to get through. Already a major problem.
Poor quality of our roads. Its already difficult to get in and out of village.
This proposal is sheer madness.
SCDC Response: 13, 15, 17, 19, 20
THE OVERALL STRATEGY
Respondent Name: M Goldfinger [453] Submission Agent Respondent ID: 453 ID: 453 ID: SUBMISSION It is a mistake to create a 'new estate'. Housing should be grown as infill throughout the district. Free up planning on infill projects within existing villages and settlements to keep these alive and reinvigorated.
SCDC Response: 4
THE OVERALL STRATEGY
Respondent Name: M. and S. Hazelwood [306] Submission Agent Respondent ID: 306 ID: 306 ID: SUBMISSION Find whole process of giving comments very complicated. Do original letters from previous consultations still count or only latest comments??? I still have the same objections to any large scale developments but the county is crying our for small developments in many of our small villages. They are gradually losing their schools, shops and pubs mainly due to lack of affordable housing for young families that would breath new life into small communities that are fast becoming breeding grounds for second homes, holiday lets and retirement homes for the rich, all of which destroy the local amenities.
Felixstowe is a 'road to nowhere' and as such can only sustain a town of a certain size and most people feel this size has already been achieved. Many of our services are crumbling under the pressure already with Ipswich Hospital being the most concerning to most people. Many of its services are being transferred out of the county at a time when you are considering bringing in many more thousands of people to the area. This seems to be a recipe for disaster. Should small developments of housing be built all over Suffolk and Norfolk then the distribution over the whole area would, it seems to me be a lot more easily managed. 10 houses being built in every village and town in Suffolk would give you your housing numbers, provide a service to small communities and be welcomed by the majority of Suffolk residents as it would not make a substantial difference to any one area or destroy a vast section of the countryside.
I would be interested to hear your views as to why this proposal has not been put forward and why you think it would not be viable.
SCDC Response: 1, 4
IPSWICH POLICY AREA
Respondent Name: Margaret Cameron [566] Submission Agent Respondent ID: 566 ID: 566 ID: SUBMISSION Which document and sections are you commenting upon?
Updated Preferred Option 07/09: yes
Sustainability Appraisal: no
Appropriate Assessment: no
Section: 6.03 IPA-east of A12, Appx 1, 8.02, Sustainability Appraisal section 2.4 Paragraph: 6.2.35
Are your responses supporting, objecting or generally commenting?
Objecting
If you are commenting upon the Updated Preferred Option 07/09 document, then please indicate concisely whether you feel the changes are a) justified and b) are considered to better meet the broad strategy for development in the district. If you are commenting on the Sustainability Appraisal or Appropriate Assessment documents, please indicate concisely, the nature of your support/objection or other comments (please continue on a separate sheet if necessary).
Extracts from the document are quoted in italics. My comments are in normal type
Summary
I strongly object to the doubling of houses proposed in the Ipswich Policy Area East of Ipswich at Martlesham. The reasons for the change are unjustified. Locating such a large development at Martlesham is out of keeping with this rural area, close as it is to the Suffolk Coasts & Heaths AONB and the Deben Estuary SPA. A new stand-alone community of this size is not needed and will overload local facilities in general but especially the road network. It will also severely damage the local environment.
Comment 1
I found the argument made that 2000 houses are needed to justify providing additional infrastructure and facilities circular. I understand from the RSS there is only a need for 1050 houses. Therefore the proposed number of houses is far too great for the need identified.
Comment 2
6.03 'The evidence suggests that the benefits do indeed outweigh the disbenefits.' This assertion is astonishing. I found very little evidence at all of supposed benefits. Rather, I have identified many serious potential costs, risks and likely negative effects. For example, there will be unquestionably serious damage done to nearby environmentally sensitive areas, especially the wildlife habitats that are, or should be, protected under European legislation.
There are other potential disbenefits, such as urbanisation encroaching upon a Greenfield rural site and landscape, the impact that extra traffic will have on main and narrow local roads, and the potential destruction to the quality of life of several local communities. In addition, I am especially worried, as we all should be, about the substantial increase in pollution and greenhouse gases that would ensue from a building development of the proposed scale and location. To double the housing numbers is surely to double the disbenefits and costs. The transport appraisal is not up-to-date, its methodology is limited and lacks rigour, and it has failed to address several important influences on the road network, such as congestion, pollution and accident risk. I mention the road into Waldringfield, in particular, because I am familiar with it. Because Waldringfield is an attractive location, the road is often congested and dangerous. This would inevitably worsen as a result of a nearby large housing development at Martlesham. This also applies to Newbourne Road.
Comment 3
I have found no reference to the potential benefits of returning this land to its original state as lowland heath after quarrying is complete. Lowland heath is a precious and scarce habitat that needs to be preserved for its own sake and, like the need to conserve farmland, is an increasingly salient consideration at this time of climate change and environmental threat.
Para 6.2.35 ' ... it is unlikely that visitor recreation activity would substantially increase on the foreshore of Deben Estuary SPA at Martlesham, so there is expected to be no new high levels of disturbance.' I find this a staggering assertion and utterly refute it. All the evidence points in the opposite direction.
Comment 4
Several references are made in the document to provide 'mitigation' as a means to limit damage , but what little has been offered by way of mitigation is wholly inappropriate and insufficient.
Sustainability Appraisal document, section 2.4 'There is the additional concern about access to the countryside and proximity to the Deben SPA. Mitigation will need to take place ...' What is offered here, however, is unlikely to be at all successful because the Deben would be an attractive venue to an extra 5000 people living as close as 1.5km away. The Estuary is also environmentally sensitive and extra visitors with dogs will undoubtedly damage the fragile saltmarsh and inter-tidal mudflats.
If you are objecting to any area of the documents, please indicate what changes you would like made (please continue on a separate sheet if necessary)
Before a final decision is made there should be a more detailed and searching comparison of alternative strategies for housing location and numbers, to the large single-site proposal. A strategy for distributing the houses widely and evenly merits serious attention and should be fully assessed as an optimal strategy for meeting the required minimum number of 1050 houses for the district. Such a strategy would meet several objections made to the one proposed, for example, less investment in infrastructure changes and development would be needed. Furthermore, the benefits and costs from the additional housing would be shared amongst several sites and communities.
Signed: Margaret Cameron Dated: 18.11.09
SCDC Response: 4, 8, 9, 10, 15, 16, 17, 18, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Margaret Dunlop [248] Submission Agent Respondent ID: 248 ID: 248 ID: SUBMISSION Dear Sir / Madam This development is far too large for such a rural area and will cause the local villages to loose their individual identity.
SCDC Response: 16
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Margaret Lake [285] Submission Agent Respondent ID: 285 ID: 285 ID: SUBMISSION The area around Waldringfield on the east of the A12 is rural in nature, and beautiful. Waldringfield itself is a timeless but vibrant village with a very popular Public House and very sucessfull Sailing Club. It does not have any public toilets or public carpark. To put 2000 houses so close to this village , already a "Honeypot" will undoubtedly put a huge strain on facilities. At high tide there is very little beach for children to play on. and the congestion on sunny summer weekends is a sight to behold. I have been told that the new householders will not add to Waldringfield's summer problems because there is no public carpark. The Sailing Club members know exactly where visitors park their cars, and sometimes find it hard to park themselves.
There is also the problems of the extra traffic. 1000 householders will not all find employment in walking distance, and how many children will need to be driven or bussed to schools.
In essence I would like to register my objection to the building of this huge amount of housing
SCDC Response: 16, 19, 20
5 HOW HAS THE HOUSING DISTRIBUTION BEEN DRAWN UP? AND HOW AND WHY HAS IT CHANGED?
Respondent Name: marilyn mills [207] Submission Agent Respondent ID: 207 ID: 207 ID: SUBMISSION What would effectively be a new town would spoil this AONB. It is very short sighted to even consider building on precious agricultural land when there will be food shortages in the near future. There is no employment in this area and consequently any new houses would put too much pressure on the local roads.
SCDC Response: 7, 15, 17, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Martlesham Conservation Group Respondent Name: (Mrs Carolyn Smith) [387] Submission Agent Respondent ID: 387 ID: 387 ID: SUBMISSION The over 2000 provision will impact the A12 leading to traffic problems as well as leading to environmental damage due to increased road size. The increased road size is also likely to lead to loss of wildlife sites and loss of wildlife corridors due to squeezing up the road against existing housing and other buildings in Martlesham Heath. The existing level of road kill on the A12 demonstrates that this area is an important wildlife corridor.
SCDC Response: 13, 17
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Martlesham Conservation Group Respondent Name: (Mrs Carolyn Smith) [387] Submission Agent Respondent ID: 387 ID: 387 ID: SUBMISSION The over 2000 provision of housing will lead to increased traffic and noise pollution affecting local residents particularly those close to A12. There will also be increased light pollution and water and airborne pollution + litter arising from the development. This is likely to have a detrimental impact on sensitive wildlife areas such as the SSSI as well as on local residents.
SCDC Response: 9, 13, 17, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Martlesham Conservation Group Respondent Name: (Mrs Carolyn Smith) [387] Submission Agent Respondent ID: 387 ID: 387 ID: SUBMISSION The over 2000 provision for housing in the Martlesham-Waldringfield area will have a detrimental impact on surrounding wildlife. The SSSIs at Martlesham Heath, and Newbourne Springs are likely to be adversely impacted by the proposals due to increased people-pressure and associated impact of domestic pets, particularly cats. Both areas are already attractive to dog walkers. Additional pressure will lead to degradation of the habitat (including pollution from dog waste) plus increased disturbance to wildlife particularly ground nesting birds, silver studded blues, reptiles and small mammals. The wildlife in the AONB and surrounding woodland is also likely to be detrimentally impacted.
SCDC Response: 9, 17
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Martlesham Heath Householders Ltd (Eamonn Respondent Name: OByrne) [355] Submission Agent Respondent ID: 355 ID: 355 ID: SUBMISSION No amount of advance planting or open spaces for dog walkers will compensate for the greenfield land taken up by additional housing and the facilities it necessitates.
The local AONB, SSSI, RAMSAR site and Deben Estuary/Martlesham Creek are all at serious risk.
One does not have to build directly on these areas to destroy them and their wildlife.
The quarry is not 'Brownfield'. It must returned to its original state (Heathland and/or Agricultural).
SCDC Response: 9, 15, 17
3 BACKGROUND Martlesham Heath Householders Ltd (Eamonn Respondent Name: OByrne) [355] Submission Agent Respondent ID: 355 ID: 355 ID: SUBMISSION The claim that Suffolk Coastal regularly consulted with residents and landowners is misleading.
Martlesham Heath Householders Ltd own significant areas of land, yet have not been specifically consulted over proposed changes to housing numbers and distribution.
The woodland and the SSSI owned and managed by MHHL appear to be a blank canvas as far as the Council's planning department is concerned.
MHHL requires urgent written assurance that there are no plans to impose compulsory purchase orders against land owned and maintained by MHHL and by our members.
SCDC Response: Comments noted. There are no current plans in terms of the LDF to make any compulsory purchase orders.
2 THE CONSULTATION IN BRIEF Martlesham Heath Householders Ltd (Eamonn Respondent Name: OByrne) [355] Submission Agent Respondent ID: 355 ID: 355 ID: SUBMISSION Martlesham Heath Householders Ltd does not offer any level of support to these proposals.
MHHL has not been adequately consulted over the changes to the proposed housing numbers, their distribution and impact to our land.
The consultation has been undemocratic while due process has not been followed.
Objections and issues raised by MHHL on previous consultations have not been addressed.
The response in Section 6 is very weak. Conclusions are not backed up by hard data or evidence.
The supporting Ipswich infrastructure document appears rushed, contains inaccuracies and vague assumptions and so cannot be classed as an evidence based document. It lacks substance.
SCDC Response: 1, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Martlesham Parish Council (Mrs Respondent Name: Susan Robertson) [486] Submission Agent Respondent ID: 486 ID: 486 ID: SUBMISSION Consultation on Suffolk Coastal Local Development Framework: Core Strategy: Proposed Changes to Housing Distribution
Please find enclosed Martlesham Parish Council's response to the above consultation, along with Appendix 1 which relates to infrastructure issues. The Parish Council strongly objects to the proposals to build 2000 new houses at Martlesham. It finds no basis in the arguments to merit a change from 1,050 houses in Area 4 to 2,000 houses specifically at the Adastral Park site in the area east of the A12. The Council's previous objections to LDF consultations remain relevant and should be regarded as part of its overall submission. Please refer to the previous submission on the Core Strategy and Development Control Policies Preferred Options (09-64-cs) and Comments on Site Specific Allocations & Policies (09-64-spa) made in March 2009. These documents are attached by e-mail for your reference but not reproduced in hard copy as you will already have them on file.
Martlesham Parish Council is of the opinion that the premature BT planning application has had an undue influence on the SCDC LDF Task Group deliberations leading to this Updated Preferred Options Housing Distribution. Please note that this Council has held two very well-attended public Parish Meetings (over 170 people present at each) in regard to the housing distribution within the LDF. These demonstrated an overwhelming strength of feeling against development of sites in Martlesham to generate 1,050 houses. The argument now that a stand-alone community of 2,000 houses will have minimal impact on the surrounding communities and countryside is flawed and not based on sound evidence. A "more meaningful set of mitigation measures", dependent on developer contribution, is unlikely to prevent such a major development from threatening the local landscape, wildlife, environment and existing quality of life.
HOUSING DISTRIBUTION - UPDATED PREFERRED OPTION 07/09: RESPONSE FROM MARTLESHAM PARISH COUNCIL
In summary - Martlesham Parish Council does not think the changes are justified; nor do they think "that the necessary broad housing strategy for the District will be better met as a result of these changes".
The overall conclusion of MPC is that the BT planning application has had an undue influence on the SCDC task force deliberations. Further, soundly based conclusions, which had been previously published (Preferred Option 12/08) have been overturned without detailed consideration and indeed with a hasty rationale which will not stand close scrutiny.
For the sake of clarity the MPC response that follows adopts the tabular format utilised by SCDC to explain their reasons for overturning their own recently established position. Please refer to Section 6 pages 9-12 of the Updated Preferred Option 07/09 document.
SCDC Comments/Response Felixstowe/Walton and Trimley Villages - proposal to reduce the numbers. Too many houses are proposed for the Felixstowe peninsula. (We do not believe we are best placed to respond in detail to the points made by SCDC in this section. However the rationale in this and the traffic aspect (below) is so weak that we feel compelled to make general comment.)
Martlesham Parish Council Response Having accepted the David Lock study in all its parts SCDC acknowledge that these issues remain. The rationale for mitigating the issues rests on: a) that a number of "regeneration schemes are progressing without the new housing to support it" - a very general assertion which is not evidenced and may have other ingredients giving rise to longer term detrimental impact; b) a decision taken by SCC in relation to a single secondary school option - this without explanation or any indication whether the decision is final/challenged/valid; c) financial crisis and resulting recession having significantly slowed the rate of expansion at the port of Felixstowe. The LDF has a forward view to 2025 by when hopefully the recession and its impact will have become a distant historical lesson. Significantly European and national funding sources continue to maintain massive investment in Felixstowe expansion. Failure to match and follow the expansion may well result in an unsatisfied need for 'local' housing.
The A14 is unable to cope now let alone with increased traffic from the new housing.
It is extremely doubtful that the traffic studies which "indicate that the A14 even with the additional lorry traffic ....will be able to cope with the housing numbers proposed" actually stacks up. Even if this statement is accepted there is absolutely no rational logic to support the statement that "pursuing a dispersed strategy makes it more difficult to project what the impact will be and when it will occur". Whether positioned in Felixstowe or Martlesham the same quantity of traffic will use the A14 and the Orwell Bridge. On the day of writing this response the Orwell bridge was blocked by an overturned lorry and caused major traffic disruption. The increase in traffic will enhance the probability and impact of similar incidents in the future.
Conclusion The Parish Council finds the SCDC conclusion woolly, wordy and lacking in direct evidence or rational justification.
Ipswich policy Area - East of the A12 - proposal to increase the numbers The numbers of houses currently proposed is too great.
The figure of 1,050 homes was a reflection of "the number required to meet the RSS minimum housing figures". No science in this in terms of establishing a "relatively self contained community" merely a number and one that cannot be put forward with any valid justification for the optimum size of a settlement. There is no valid argument here, just a fitting of numbers to circumstances. Further the original 'area 4' was much broader than the currently proposed specific location. This further underlines the Parish Council concerns that the change in housing distribution owes more to the BT planning application than a desire to establish a self contained community.
1000 is insufficient to provide a stand-alone community
(An interesting comment this - was it inserted to provide the vehicle for the SCDC comment which followed or did someone actually make a reasoned case for this statement?) This is the first mention given to the need for a stand-alone community. All previous documents, including those presented to the LDF Task Group in July 2009 and also to cabinet referred to the importance of any new development integrating and forming part of the existing communities. No justification here for the change in policy. Furthermore part of the SCDC rationale for a larger tranche of houses in the area east of the A12 is the existing and proposed employment at the Adastral Park business centre. It is uncertain that with BT downsizing that it would still prove a draw to employment and for some period now Adastral Park has been touted as a technology growth area without much positive response. The case is not made that there will be expansion sufficient to support such a major housing initiative.
Adverse impact on existing communities at Martlesham, Martlesham Heath and Waldringfield
The new community will be separate from the main current residential areas and although the new residents will be able to use many of the existing retail developments it is quite clear that the current infrastructure will be overwhelmed and ultimately swamped resulting in the loss of identity of the surrounding villages. It is surely this which creates the greatest impact and most compelling argument presented by the existing communities. The RSS housing requirement as a whole could be met with a dispersal plan; this proposal renders such an approach impossible.
Unacceptable impact on the neighbouring wildlife and countryside
The statement to the left is demonstrably true in so many respects and the SCDC response is merely a statement of the obvious in its first part "Development on this scale must be undertaken as part of a comprehensive development which places emphasis on mitigating these potential impacts"; in the second part extremely lightweight and of no consequence "This could include significant levels of advanced planting (which means what?); large well managed open areas for dog walkers etc. which would help to lessen the impact on the nearby AONB and estuary" (pretty doubtful really, more likely to impact adversely on AONB as a consequence of greater usage). Of all the SCDC responses this one adds the least to its proposition that the reasons for the changes are justified.
Unacceptable impact on the primary and local road network
The SCDC comments in relation to this, a key component of the development, appear to rest upon size being a determinant in achieving developer funding. Over the next few years, as the country moves out of recession, it will prove difficult for any developer to invest in infrastructure before achieving financial return on house sales. Inevitably infrastructure will require major investment and against a larger development such as that proposed underfunding will prove to have a much greater impact. In addition there is the adverse impact of the increased traffic flows on residents in the proximity of the A12 which include noise, pollution and potential issues with access from the existing residential area to the A12. There is no proposal for mitigation of the noise and air pollution within the SCDC rationale for the increased housing allocation and overall the justification in transport terms is shallow and not evidenced. There are too many poor examples of road infrastructure provision in the 'Ipswich Policy Area', specifically Kesgrave and the A1214, to give confidence that the strategy stands up in this respect. (Kesgrave town planning was carried out with the absence of current financial constraints and yet the outcome is major congestion at peak times on the A1214.) Martlesham Parish Council has considerable concerns relating to the highways infrastructure and none of the published papers have alleviated that concern.
The existing social and community infrastructure cannot cope NB. A more detailed comment on the infrastructure issues is included as Appendix 1 to this response
The "thorough investigation" into the Eastern Fringe infrastructure requirements upon which SCDC relies for the change of policy was not base lined against the potential development of 2000 homes in a single area east of the A12. Even with a smaller baseline of 1050 homes the consultant's report highlighted the need for significant infrastructure investment in dealing with foul waste water treatment, electrical supply, additional police facilities, children's play areas and other recreational needs. It is noted that the subsequent September 2009 Tym & Partners report has underlined the criticality of the wastewater provision which without significant developer contribution will delay development until 2019 at the earliest.
Conclusion
The SCDC conclusion is one sided, limited in scope and adds little if anything to the proposition. It rests again on the presumption that a bigger 'bang' will achieve greater 'bucks' - a poor and ill-conceived hypothesis in these difficult times. No, the case is not made in this hurriedly prepared and insufficiently thought out 'justification' of a major policy change which will have a particularly detrimental impact on a settled community. It is apparent that there has been a serious distortion of the consultation process to achieve a predetermined end.
SCDC Response: 4, 7, 11, 12, 13, 16, 17, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Martyn & Jacqueline Reed [425] Submission Agent Respondent ID: 425 ID: 425 ID: SUBMISSION I wish to register our objection to the proposal for introducing over two thousand housing units, associated business parks and a considerable amount of supporting infrastructure on or about Adastral Park, Martlesham Heath.
As long standing residents of Martlesham Heath over the last 23 years, we do not wish to see the current Village and area destroyed by traffic grid-lock, an unnatural pollution increase and unsustainable employment opportunities leading to social deprivation through imbalance. The proposal, which includes major road changes and a serious impact on social infrastructure, can only be seen as damaging to the area, to its people and to the countryside and natural habitats of wild birds and animals contained within the area.
Please do not go ahead with the Local Development Strategy for the Martlesham Heath and Adastral Park area/conurbation.
SCDC Response: 16, 17, 19
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mary Dixon [380] Submission Agent Respondent ID: 380 ID: 380 ID: SUBMISSION 1. I support the reallocation of housing numbers to the Martlesham Heath area with its various highway links and the reduction of numbers proposed for the end of the Felixstowe peninsula served only by the A14 and the narrow village High Road.
2. However there is no stated recognition of the importance of limiting housing development which might feed vehicles onto the High Road running through Trimley St. Mary, Trimley St. Martin and Walton Felixstowe where many residents live very close to this narrow thoroughfare.
3. I support the use of site 451f (Area 6) in Trimley St. Mary for a modest (80) number of houses to meet local need. At least 30% of this and all developments must adhere to the stated policy of being "affordable".
4. The third phase of development in the Felixstowe and Trimleys area, should only be built if there is a clearly identified need at that time.
Please take into account my previous comments on LDF consultations regarding -: 1. The need to protect green field land of agricultural grade 1 or grade 2 quality for future food production especially in view of possible seasonal rainfall changes and lower land flooding because of climate change.
2. The unacceptability of commercial or housing development on the Innocence Lane farmland.
SCDC Response: 22, 26 Supporting and sites comments noted
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009 Melton Parish Council (Cllr Respondent Name: Geoff Butterwick) [575] Submission Agent Respondent ID: 575 ID: 575 ID: SUBMISSION 5 - Settlemtnt Hierarchy
The revised Settlement Hierarchy continues to designate Melton Village as a 'Key Service Centre', but does, as requested, designate Melton Park as an 'Other Village'. As part of our response to the December 2008 consultation, the parish council requested that the boundaries of 'Woodbridge Town including parts of Melton' and 'Melton Village' be redrawn so as to bring the Playing Field, Burkes Wood and the grounds of Melton Hall & Melton Mead within the area defined as countryside. The parish council believes it has good reason to be wary of the designation of Melton Village, especially in the absence of any published proposals for the revised boundaries of settlements. Revise Table 1 so as to show Melton Village as a Local Service Centre, not a Key Service Centre.
Ensure proposals for revised boundaries of settlements include Melton Playing Field, Burkes Wood and the grounds of Melton Hall & Melton Mead within the area defined as countryside.
7.02 The narrative appears to be at odds with the contents of Appendix 4 Tables 1 & 2 (Updated Distribution Strategy). From these, it appears that there will be:- * a 23% increase in the minimum 'new allocations (greenfield) of 770 to 4,080 almost matched by a 59% reduction in 'small windfall (small brownfield) of 780 to 540; * a 90% increase, of 950 to 2,000, in new greenfield allocation to the 'Ipswich Policy Area', and a 118% increase, of 470 to 870, in new greenfield allocation to 'Market Towns', set against a 37% reduction, of 610 to 1,000) in 'Felixstowe, Walton & the Trimleys'.
We are expected to believe it to be a coincidence that, since the publication of the original Housing Distribution less than a year ago, there is suddenly a good policy reason to double the allocation to the 'Ipswich Policy Area'. It stretches credulity to be asked to believe that this has nothing to do with the two applications made for major development, including an additional 2,000 dwellings, at Adastral Park.
Consultation on the LDF Core Strategy, Site Specific Allocations and Settlement Boundaries has now become so disjointed as to render informed public engagement very difficult.
Revert to the broad form of the strategy consulted upon between December 2008 to February 2009.
7.03 MPC reiterates its objection (originally made to draft strategic policy SP3, especially paragraphs 3.34 - 3.35) for the Area East of Ipswich, which stated "Development 'East of Ipswich' must be seen in the context of the Ipswich Policy Area. Map 1 shows the "Greater Ipswich" agglomeration extending from Barham and Copdock in the west to the borders of Woodbridge in the east. In this context, the district council's preferred option (see 3.20 onwards) of creating a new community "alongside but not overwhelming existing communities at Martlesham, Martlesham Heath and nearby, neighbouring villages" appears optimistic. If the market town of "Woodbridge including parts of Martlesham & Melton) is to remain a separate entity, then development north-east of the current limit of the Martlesham Heath development should be resisted. The wording of the draft policy "not part of the regional centre of Ipswich" is thus disingenuous; what people see, and will see in 2021, is not administrative boundaries, but the extent of the built-up area. Elements of the policy are self-contradictory."
The settlement policy for the area East of Ipswich should be drawn up in a manner co-ordinated with the LDF proposals of Ipswich borough and all the adjoining districts. Any underlying proposal for 'Greater Ipswich' should be explicitly set out.
7.04 MPC objects to the apparent reduction of new housing allocation to Felixstowe/Walton & the Trimleys, if this is to be found by increasing the allocation to new greenfield allocations in the Ipswich Policy Area and Market Towns. The reasons for this change in policy appear to be more an ex post facto rationalisation of the need to accommodate the BT application for major development at Adastral Park.
The settlement policy for the area East of Ipswich should be drawn up in a manner co-ordinated with the LDF proposals of Ipswich borough and all the adjoining districts. Any underlying proposal for 'Greater Ipswich' should be explicitly set out.
7.05 MPC objects to the apparent reduction of new housing allocation to Felixstowe/Walton & the Trimleys, if this is to be found by increasing the allocation to new greenfield allocations in the Ipswich Policy Area and Market Towns. The reasons for this change in policy appear to be more an ex post facto rationalisation of the need to accommodate the BT application for major development at Adastral Park.
The settlement policy for the area East of Ipswich should be drawn up in a manner co-ordinated with the LDF proposals of Ipswich borough and all the adjoining districts. Any underlying proposal for 'Greater Ipswich' should be explicitly set out.
7.06 MPC reiterates its objection (originally made to draft strategic policy SP2 Settlement Policy (inc. Settlement Hierarchy) which stated that, whilst the policy was broadly supported "this ... should not be used as a rigid template - due weight should be given to local circumstances. However, the inclusion of many small villages with minimal facilities in the list of 'Key Service Centres' is questionable, whilst the inclusion of the Trimleys as "Key Service Centres but considered capable of accommodating more strategic levels of housing growth" appears disingenuous. Object to designation of Melton Village as a Key Service Centre. The facts that a significant part of Melton is designated as part of Woodbridge town, together with its proximity to the "Greater Ipswich" agglomeration, make it inappropriate to designate the bulk of the remaining built-up area as a Key Service Centre. The area currently designated as Village should be downgraded to Local Service Centre. Melton Park should be separately designated as an Other Village."
The settlement policy for the area East of Ipswich should be drawn up in a manner co-ordinated with the LDF proposals of Ipswich borough and all the adjoining districts. Any underlying proposal for 'Greater Ipswich' should be explicitly set out.
Sustainability Appraisal The parish council would like to have been in a position to comment on this document, which it understands may contain serious flaws, but has had insufficient time to give it the consideration necessary.
Appropriate Assessment The parish council would like to have been in a position to comment on this document, which it understands may contain serious flaws, but has had insufficient time to give it the consideration necessary.
SCDC Response: 4, 16, 22 The District Council does not agree with Melton Parish Council’s request to become a Local Service Centre due to the number of services and facilities, employment opportunities and public transport links in the parish.
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Michael Atkins [464] Submission Agent Respondent ID: 464 ID: 464 ID: SUBMISSION Waldringfield and its river frontage have a unique quality which should be preserved at all costs. It is an AONB, much loved by sailors and those who value our countryside. There are some 200 houses in the village, and there can be little doubt that the imposition of 2000 - 2500 new houses on its doorstep would destroy the unique qualities of the village. History is full of fatal decisions made by Councillors and Planners which have been regarded as serious mistakes by later generations, and I implore the Plannning Committee to avoid a step which may have an attraction for expediency and convenience, but which will destroy a unique and valuable amenity.
SCDC Response: 17
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Michael Everitt [242] Submission Agent Respondent ID: 242 ID: 242 ID: SUBMISSION The scale of this proposed development is far too large and will dominate the surrounding villages. Currently the area is a pleasant place to live but this development will bring benefits to no one except BT (which is outsourcing jobs so no longer needs extra people and therefore housing in this immediate area). The land should remain agricultural or be returned to that state after the gravel extraction.
The A12 and Orwell Bridge is unable to cope with minor traffic accidents so any increase in traffic levels will result in more congestion.
Housing in the Suffolk Coastal area should be increased using the "pepperpot" approach so all areas grow by the same percentage.
SCDC Response: 4, 7, 13, 16
APPENDIX 5 - REVISED SETTLEMENT HIERARCHY
Respondent Name: michael stollery [31] Respondent ID: 31 Submission 31 Agent ID: ID: SUBMISSION Peasenhall continues to erroneously be shown as a Key Service Centre("KSC").To qualify as a KSC "most or all" of 8 facilities must be provided by that Settlement.Peasenhall can , at best, only provide 4 of these facilities.
Even the attempted fudge of adding on a bit of Sibton to Peasenhall will not improve the position much.Sibton has a pub which then makes the score 5 out of 8 facilities.This is still not " most or all".In any event there is no legal or moral basis for adding on a bit of Sibton to Peasenahll.
SCDC Response: Noted
IPSWICH POLICY AREA
Respondent Name: Miss E Jewell [437] Submission Agent Respondent ID: 437 ID: 437 ID: SUBMISSION We wish to express our dismay at the huge proposed development on the BT site which we consider to be totally inappropriate for the area.
It is far too big and will change the character fo the area completely. It will also mean that there will be no natural gap between ipswich and Melton.
The development would generate far more traffic on the already busy A12 and the other roads in the area are quite inadequate to cope with the increased volume of traffic.
We feel that this large scale development is unnecessary and if more houses are needed in the area then we suggest 10% of those proposed would be more than enough togaether with a small shopping precinct.
We hope that this proposal will be rejected.
SCDC Response: 4, 13, 16, 18
IPSWICH POLICY AREA
Respondent Name: Miss E Lock [438] Submission Agent Respondent ID: 438 ID: 438 ID: SUBMISSION We are strongly opposed to the proposed development, by BT at Waldringfield heath.
We first want to add our signatures to the already numerous ones you have, and for all the same reasons that you must have heard so many times over.
Have you forgotten your motto "where quality of life counts"? Or is BT too big to oppose!!
SCDC Response: Noted
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES Respondent Name: miss fiona whitfield [89] Submission Agent Respondent ID: 89 ID: 89 ID: SUBMISSION Creating a development on the currently green fields near Candlet Road will open the flood gates for further development which will eventually reach the AONB. The wildlife, plant life and establishes trees and ponds will be obliterated forever and turned into an ugly urban sprawl. This development will mark the beginning of the end for the countryside of Felixstowe, Trimley and Walton
SCDC Response: 22, 23
3 BACKGROUND
Respondent Name: miss fiona whitfield [89] Submission Agent Respondent ID: 89 ID: 89 ID: SUBMISSION It has been apparent in council meetings there has been considerable behind the scenes negotiation of new homes in Trimley forced through by the conservative representatives without considering the residence views. The future of the peninsular has been put at risk of turning into a suburban mass instead of tranquil and valuable countryside
SCDC Response: 22
2 THE CONSULTATION IN BRIEF
Respondent Name: miss fiona whitfield [89] Submission Agent Respondent ID: 89 ID: 89 ID: SUBMISSION The number of new homes is still unexceptable and time, effort and resources should be spent upgrading excistingh vacant residents, sustaining current communities rather than creating new.
SCDC Response: 4, 16
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Miss Libby Trim [233] Submission Agent Respondent ID: 233 ID: 233 ID: SUBMISSION "The area East of the A12 was chosen...offering the best all round solution...creating a stand-alone community...well related to a range of employment uses, the primary road network, public transport, other facilities" - Being the "best all round solution" of five options - which the council itself admits weren't "a perfect solution" - doesn't alter the fact that the site is NOT "well-related to the employment uses"etc. Environmental damage alone would be devastating. If none of the options "offered a perfect solution" why wasn't the proposal split into smaller areas? Why insist on the preferred option being a "stand-alone community"?
SCDC Response: 4, 7, 15, 16, 17
8 YOUR COMMENTS
Respondent Name: Miss Libby Trim [233] Submission Agent Respondent ID: 233 ID: 233 ID: SUBMISSION "Will ensure that the broad strategy that you have already commented, and which has achieved a large measure of agreement" - I do not think this is an accurate statement. There are no statistics to qualify it. There is strong opposition, not agreement, in Waldringfield.
SCDC Response: 1 Noted
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Miss Libby Trim [233] Submission Agent Respondent ID: 233 ID: 233 ID: SUBMISSION "The traffic studies which have been done indicate that the A14 ... will be able to cope with the housing numbers proposed." - This is contradicted by the EERA Newmarket to Felixstowe Corridor Study which stated that demand on the Orwell Bridge is forecast to increase and "30%... in peak hour will not actually be able to flow through the link because of congestion." Moreover, those figures didn't take into account the extra proposed housing.
SCDC Response: 12
5 HOW HAS THE HOUSING DISTRIBUTION BEEN DRAWN UP? AND HOW AND WHY HAS IT CHANGED?
Respondent Name: Miss Libby Trim [233] Submission Agent Respondent ID: 233 ID: 233 ID: SUBMISSION The "opportunities" would come from BT, which is cutting 15,000 jobs and has closed its graduate programme. Moreover, only 3% of the company's employees live in Martelsham, indicating no concrete connection between employment and living locally.
SCDC Response: 7
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Miss Libby Trim [233] Submission Agent Respondent ID: 233 ID: 233 ID: SUBMISSION "In deciding where new development should go, it should respect the quality of the local environment" and "protection should be given to wildlife and to the landscape, particularly those areas that are designated as being of national and international importance" - a plan for 2,000 homes to be built on heathland and either on or within a kilometre of SSI, RAMSAR, AONB and SSS sites directly contravenes these two policies.
"That housing and jobs should be provided in tandem" - BT is cutting 15,000 jobs this year and has closed its graduate programme.
"We should look first to re-developing old "brownfield" sites before looking to identifying new greenfield sites" - Planning permission for the quarry stipulates a return to greenfield status
"The road, rail and other public transport networks should be capable of accommodating the traffic and journey requirements that new housing inevitably brings with it" - An extra 2000 households would put severe strain on the existing infrastructure
"New housing should allow integration with existing communities but at the same time should respect and maintain the character of individual settlements and communities" - 2,000 new homes are not in keeping with a rural Suffolk village
SCDC Response: 9, 7, 11, 15, 16, 17
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Libby Trim [233] Submission Agent Respondent ID: 233 ID: 233 ID: SUBMISSION "The area has lower negative impacts on landscape quality and public amenity overall than other potential alternatives" - There's no doubt that smaller, more considered developments would have far less of a negative impact than a stand-alone 2,500 home plan in an AONB.
"A larger scale development...has the opportunity to provide for a more meaningful set of mitigation measures ... to limit the impact of development on the nearby AONB and nature conservation interests of the estuary." - why? That suggests that current commitment to these measures isn't already "meaningful" because the area is too small which raises questions about the council's commitment to these issues, even aside from this plan. It's paradoxical to assert as positive the idea that a larger scale site with a more detrimental impact would lead to better measures to limit detrimental impacts.
SCDC Response: 4, 16, 17
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Libby Trim [233] Submission Agent Respondent ID: 233 ID: 233 ID: SUBMISSION I am writing to object to the LDF housing changes.
The recent increase is a big change in what has been a long process so far but we have been given a disproportionate time (two months) to respond.
The council members themselves disagree on the fundamental area of housing distribution policy.
Plans for a previous planning application (C/05/04930) have already been refused. This plan was much smaller. 2000 new homes would have a detrimental effect on the local infrastructure and services and is entirely incompatible with an Area of Outstanding Natural Beauty and SSI.
The potential local employer, BT, is cutting 15,000 jobs this year. Indeed, just 3% of BT employees live in Martlesham. This disproves the theory that there would be any connection between living and working locally.
The potential local employer, BT, is cutting 15,000 jobs this year. Indeed, just 3% of BT employees live in Martlesham. This disproves the theory that there would be any connection between living and working locally.
SCDC Response: 1, 7, 11, 17
KEY SERVICE CENTRES
Respondent Name: Miss Louise Fortescue [69] Submission Agent Respondent ID: 69 ID: 69 ID: SUBMISSION I am writing to object to the greenfield site at Saddlemakers Lane, Melton, being designated as a possible site for large scale housing &/or commercial use. The land adjoins the conservation area & as such should be given equal status in protecting Melton from the steady, creeping sprawl of housing development, which over the years has already led to Melton merging with Woodbridge. Any development will have a considerable negative impact on the immediate rural & conservation area with noise & light pollution, increased traffic & loss of wildlife habitat. Once built upon, country side is lost forever. It would also begin the creep of development to merge Melton village with Melton Park & Ufford. I would like to be informed at the next stage of this process.
SCDC Response: Site comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Point 4. The proposed development will remove the natural barrier protecting AONB and wildlife sites from noise and light pollution and general disruption.
Proposed developments are on Greenfield and agricultural land with proximity to (and in view of) wildlife, AONB, RAMSAR and SSSI sites.
Open areas and farmland are needed to halt the decline of farmland birds in the UK and to maintain biodiversity as acknowledged by DEFRA, Natural England, the RSPB and the National Trust.
Developing this Greenfield and agricultural land will inevitably destroy more trees and hedgerows, increase pollution/carbon and will be detrimental to the local wildlife.
SCDC Response: 9, 17
THE OVERALL STRATEGY
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION 7.02 states 'The location for such a community remains at Martlesham although the location is specified as to south and east of Adastral Park'.
This acknowledges that the development is not really in the Ipswich area Major Centre, with Martlesham Heath Village on the far Eastern fringe, and bounded by the A12.
It is an extension across the boundaries of the A12, beyond Martlesham Heath Industrial area and into greenfield land.
SCDC Response: Noted
IPSWICH POLICY AREA
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION 7.03 This wants to integrate 2000-3500 development with the much smaller Martlesham Heath, which will be unable to keep its identity.
Other sections want to expand the housing to this 2000-3500 to create a standalone community.
The sudden selection of this area for a new town with more than double the housing allocation has not been justified.
A new town of this size in this area was not identified as needed during the previous consultations. The infrastructure, employment and volume of land are not there to support it.
SCDC Response: 4, 7, 16, 20
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION 5.17 It is not true that increased housing will have the least impact in this area. Martlesham Heath was not designed to be used for either access to (or as a through route for) neighbouring developments.
The proximity of this new development and increased dwellings make this a real issue. The trees, woodland and open lands will be damaged by development of pathways, cycleways, roads, increased traffic levels, noise and pollution.
This will adversely affect residents close to any new or expanded routes.
Those on routes used frequently such as to schools could experience a great increase in traffic, litter and damage.
SCDC Response: 16, 17, 19
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Eastern Fringe Infrastructure - Fire: This section is not complete. There is no evidence to support the assumption that "the need to use these hydrants would be infrequent". Something this serious should be evidence based and this assessment is not.
New areas of wood/heathland will be exposed to fire risk by an influx of residents. A fast response will be needed possibly to more than one area in the locality.
Increased high density, high rise housing will need to be assessed for impact on water volume, pressure and numbers of response units to evacuate these types of structures.
SCDC Response: 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Eastern Fringe Infrastructure Study 11.14 - Water Supply
This part of the supporting document is incomplete, stating that no significant requirements are identified. But until statistics from relevant organizations back-up this statement of no impact with increased housing, then this just means that there may be issues - they are just not yet defined.
Studies show that the East is one of the driest regions, least able to cope with increased water demands as we move into a future with an unpredicatable climate.
Rainfall varies yet no consideration is given to additional storage capacity for the wetter season.
SCDC Response: 20
3 BACKGROUND
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION 3.01 Consultations took place but only as a tick in the box exercise.
Views expressed by Martlesham/Waldringfield residents are not addressed. Section 6 merely brushes over the concerns and issues. The supporting documents lack substance.
Local parish councils and residents did not express a need for a large new town or for a single site development. This was the least favoured option. However developers would like and requested a single easy to develop Greenfield site to maximise profit.
The process has been very complex and out of reach to many without access to the internet. Publicity has been inadequate for the severity of the proposals.
SCDC Response: 1, 4
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION 5.10 this falsely states that this approach has been generally supported, but for the East of Ipswich site at Martlesham Heath:
The local environment and wildlife areas are being threatened and not being respected.
Building is directed to Greenfield for profit and also agricultural land for ease.
Facilities do not already exist and are at capacity, and space and justification is limited for new ones.
There are serious traffic issues and issues with road expansion.
Local character is not respected and will not be maintained as the local villages are swamped by the new town.
There are no visible plans for new or sustained employment.
SCDC Response: 7, 11, 12, 13, 16, 17, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Point 2. There is no evidence to suggest that benefits of increased housing outweigh any of the numerous disbenefits.
No benefits are identified and the disadvantages increase in severity with the increased numbers, resulting in complete urbanisation of local villages and more severe traffic impacts.
The Ipswich infrastructure supporting document has large gaps and relies heavily on unquantified developer contributions of land and money.
Numerous statements say that no issues have been identified yet with water, gas, waste, ambulance, fire, police - yet there is no evidence to show that these aspects have been investigated with the relevant bodies.
SCDC Response: 16, 20
HOUSING DISTRIBUTION FELIXSTOWE/WALTON AND TRIMLEY VILLAGES
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION 5.19 The approach is inconsistent.
These concerns are extremely valid, however, they were also expressed by Martlesham Heath and Waldringfield residents but have been ignored.
So there appears to be some bias against these views when expressed by residents close to Adastral site, who had no representation on the relevant planning committees.
Just because the original proposals were flawed and far too many houses were proposed for Felixstowe (which also has AONB areas to protect) does not mean that a new town is now required at Martlesham.
SCDC Response: 1
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Eastern Fringe Infrastructure - Policing: This section of the infrastructure support has not been completed. It acknowledges that with increased development, crime will increase and states that the developer will have to pay for some type of increased facilities. However it has not identified or quantified this any further. There is no detail of the potential impact on the local communities or any estimates of what will be needed to address this.
SCDC Response: 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Point 5 Traffic. The BT Planning Application Travel Plan indicates that the majority of employees do not live locally. With these precedent, it is unlikely that the majority of the new housing will have even one yet alone all inhabitants working locally. With 2-3 cars per household making trips to work, school, shopping, evening classes etc. there will be significant additional traffic on the road and out-commuting. This has not been given due consideration and until realistic traffic statistics are re-evaluated, especially in light of this additional housing allocation, the infrastructure plans remain flawed.
SCDC Response: 11, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Point 4. The size, density and height of the new increased proposals for development already indicates that it will be impossible to blend in with or screen from the local (quite flat) Heathland and nearby SSSI and AONB. Landscaping is a critical part of a proposal for a new town squashed between villages and an AONB and estuary, yet the Ipswich infrastructure document 10.128 states that "There are no particular issues attached to this provision" and it is hoped that the developer will propose and provide suitable landscaping. This is not acceptable for an AONB and lacks any substance.
SCDC Response: 17, 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Eastern Fringe Infrastructure 11.15 Waste Water is not addressed fully. Surface water and drainage is not even considered, yet increased surface areas are being concreted over. Potential erosion effects on the Deben estuary and flooding of AONB and SSSI sites has been ignored. There is no back-up from the relevant body that it is feasible to expand or replace the current waste facility at Woodbridge which at times cannot cope. No evidence is provided of the impact or cost of a new plant on the existing site (funded by the developer again).
SCDC Response: 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Point 3. The justification for a Secondary School appears forced as there is already difficulty fitting enough housing on the land to trigger the need. High rise apartment blocks boost the dwelling numbers but are less likely to need secondary schools. A school on the Adastral site if identified would reduce the value of a significant piece of land that could be used for housing so other greenfield sites are being proposed -which will generate even more traffic and impact this consultation. Local schools bollard access roads, shifting the parking problems onto nearby areas as experienced in Martlesham Heath.
SCDC Response: 20 Comments on schools sites noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Point 4. The size, density and height of the new increased proposals for development already indicates that it will be impossible to blend in with or screen from the local (quite flat) Heathland and nearby SSSI and AONB. Landscaping is a critical part of a proposal for a new town squashed between villages and an AONB and estuary, yet the Ipswich infrastructure document 10.128 states that "There are no particular issues attached to this provision" and it is hoped that the developer will propose and provide suitable landscaping. This is not acceptable for an AONB and lacks any substance.
SCDC Response: 17, 20
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION 5.10 The Ipswich Eastern Fringe Infrastructure Study expresses a preference for a single Greenfield site at Martlesham, in the hope that the increased profit will pay for the required facilities and infrastructure. This is not sustainable, ethical or in line with these or government guidelines. This land is not only Greenfield but an important buffer zone to local SSSI, AONB and ES designated land. See SN/SC/1387-"Public authorities will be so desperate for houses to be built that they will allow more development on greenfield sites. The Government has resisted any watering down of brownfield targets"
SCDC Response: 7, 15, 17, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Point 5. Traffic A12/A14 Traffic analysis is flawed and needs revisiting. Access onto the A12 is crowded at peak times and will be further impacted by increased housing. A14 and Orwell Bridge capacity problems are already in the public domain and traffic queues on the A12 south at peak times. Road widening, traffic lights and queuing will increase local noise, stress and pollution and impact on neighbouring houses with possible health concerns. Artist impressions show a 7 lane road, flattened banks and ripped out hedges as visual and noise screening is removed and replaced with flat grassland.
SCDC Response: 11, 12, 13
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY?
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION 5.12 Adastral park appears to be the sole main employment centre mentioned for the Adastral proposal, yet the BT Planning Application states that any new jobs will be provided by new companies, not BT. There are currently no guarantees of significant numbers of new companies or jobs. The plan also states that the new companies, hence the new jobs will not be for local people as these companies will bring their own staff. How does this plan help address local housing needs if the housing is intended for the employees of the new companies who bring their own employees?
SCDC Response: 7
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich - Conclusion: This cannot have been written by anyone with any knowledge of the local area. The larger the development, population and infrastructure, the more serious the consequence for the AONB sites. With a larger population and even less green space, it will be less probable that any mitigation will be successful in preventing its destruction and erosion. The supporting documents do not provide any evidence that there is less impact on this landscape than any of the alternatives. They raise some serious issues and again, suggest the magical 'mitigation' but with no substance behind it.
SCDC Response: 7, 17, 20
BASE REQUIREMENTS
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION 7.01 These figures are due for revision and there is no justification that a new town is needed in the Martlesham Heath area. The Martlesham Area - including the mineral extraction site (which should be returned to its original state) is not brownfield, and includes AONB, RAMSAR and SSSI, yet this countryside is bearing the threat of a new town of up to 3500 houses plus associated facilities.
SCDC Response: 2
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Point 3. This study constantly implies that our countryside is brownfield and low grade agricultural, therefore development will not impact us. This is not true, and is only the view of a committee who do not live here or appreciate the landscape. The condition that land should be returned to its original state after the mineral extraction must stand, and not be allowed to be broken. Increased intensity in the extraction to push the timescale should also not be permitted as it will impose increased noise, pollution and disruption locally and to wildlife.
SCDC Response: 15, 17
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION 5.09 Few comments were received on the settlement hierarchy but this means that the implications were not fully publicised, not that the proposals were well received. Martlesham Heath is counted as a major centre on the fringe of Ipswich. It is bound by the A12, so has a semi-rural setting on the edge of the countryside. However now Martlesham Industrial Area/Adastral is proposed as an extension of the Ipswich fringe, Martlesham Heath will lose its semi-rural character and becomes lost in a general urban sprawl. Waldringfield is a local service centre and will lose its identity as well.
SCDC Response: 16, 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Point 3. The strategy here is again confused. The community is considered standalone when it suits the purpose to promote the increase in house numbers. However, as the new town is so much larger than the adjacent villages and will swamp them, then integration has to be considered, yet this is somewhat forced. The new town will turn these villages into just a through route for a much larger estate to reach either recreational areas or other towns, thus destroying the character of the current villages.
SCDC Response: 16, 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Point 4. The constant use of 'mitigation' does not address the potential irreparable damage to AONB and wildlife. As green areas decrease there is increased usage of those remaining. The Martlesham Heath SSSI (not public land) is already suffering extra usage, fire damage and excessive dog fouling. As SSSI land this is irreplaceable. Increased damage, erosion, wear and tear, litter, vandalism, dog fouling will all need consideration. Where is the funding for full time people to restore the AONB, or to keep people out of what remains when it becomes the only mitigation available to save it.
SCDC Response: 9, 17
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Point 1. This states that 1050 houses would be an overgrown estate, is this an acknowledgement that even at 1050 it is too large to blend with the nearby villages and the AONB. 2000-3500 new houses must be very overgrown -a complete new town? This method of consultation is not sufficient to select the location of a new town, especially one that is not even centrally located, is on the edge of an estuary and AONB and will swamp the local villages and country roads to the extent that they are fully urbanized and no longer semi-rural.
SCDC Response: 1, 16, 17, 18
2 THE CONSULTATION IN BRIEF
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION 2.05-6 The area between Ipswich and Martlesham Heath has already been subject to extensive house building, almost joining Ipswich to Martlesham and beyond. Bad planning has lead to a line of development protruding East of Ipswich towards the A12, and now a bizarre proposal to extend this across the A12 boundary and squash in a new town. Yet, this rather constricted piece of greenfield land between Martlesham Heath, Waldringfield, and up to the edge of an AONB and along the Deben estuary is not the right size or location for all of the housing and required infrastructure/facilities.
SCDC Response: 4, 16
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT?
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION 4.02 This statement is not true in the case of Martlesham and Waldringfield. Employment is currently limited with no guarantee of expansion or new employers relocating there. Services and facilities are at capacity and new ones would be needed. However, the only land is the local Greenfield land, and this land near Adastral adjacent to the AONB in itself is too constricted between current villages and the Estuary/AONB, and not large enough to accommodate a complete new town with facilities.
SCDC Response: 7, 21
2 THE CONSULTATION IN BRIEF
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION 2.02 I object to the proposal for large scale housing development and urbanization of the Martlesham/AONB area. The directive to comment only on the change in distribution has compromised the whole process. This directive appears to be an attempt to limit the views expressed and to stop people from raising serious concerns expressed in the previous consultations again. These concerns appear to have been largely dismissed to date and need addressing fully - which this consultation will not now accomplish. Strategic documents are changing in parallel and confusing the process further.
SCDC Response: 1
2 THE CONSULTATION IN BRIEF
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION 2.01 It is misleading to say that there is a 'measure of support' to these proposals as there is not actually any substantial evidence to support this. This 'support' is defined in section 5 as being merely inferred from the fact that only a 'few comments' were received on areas other than the housing distribution. There were and still are multiple consultations in parallel and due to time constraints and complexity of the whole process, people have responded mainly to the housing distribution as a priority. A lack of comment in other areas is not evidence of support.
SCDC Response: 1 Other comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Ipswich Point 5. Local traffic.
Increased housing will just exacerbate the load on local roads.
Roads to Waldringfield, Newbourne and other nearby villages are characterful country lanes and should remain so - but how - with over 5000 potential new residents adjacent?
The local country lanes link villages and are lined by old trees and hedges. They will inevitably have their character destroyed if the plan is for them to become another widened suburban road lit by streetlamps.
Wildlife will not stand a chance.
The new housing will be followed by screams of congestion, speeding, safety, litter, more traffic lights ...
SCDC Response: 18, 19
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT?
Respondent Name: Miss Margaret Wilson [143] Submission Agent Respondent ID: 143 ID: 143 ID: SUBMISSION Many serious issues are exacerbated by this redistribution but not addressed by the Ipswich Infrastructure document-
Load on A12/A14/Orwell Bridge/local roads Environmental impact on AONB/SSSI/Deben Estuary Waste/surface water Land - can enough houses be forced in to justify new facilities Where will this secondary school and facilities be located
Traffic - cannot be addressed by a few taffic lights and the Compulsory Purchase of land belonging to Martlesham Heath residents to:
Widen A12 to 7 lanes Widen Martlesham Heath entrance Destroy woodland owned and maintained by the residents to build a bridge and widen footpaths so that the new town can use the village as a throughroute.
SCDC Response: 11, 12, 13, 17, 19, 20, 21
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: miss mariah skellorn [140] Respondent ID: 140 Submission 140 Agent ID: ID: SUBMISSION this area would not be a stand alone area. it would rely on the existing facilities. employment would not be at adastral park this is nonsense, as 5% of BT's workforce currently live within walking distance of Adastral park. New sewage systems would be needed and this has not been planned for. the changes to the roads would be significant and would cause a great deal of disruption. this area would become extrmeely conjected. the public transport palns are no where near sufficient.
SCDC Response: 16, 18, 20
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY?
Respondent Name: miss mariah skellorn [140] Submission Agent Respondent ID: 140 ID: 140 ID: SUBMISSION I completely object to the distrubution of the housing. You are dumping all the houses in one environmentally delicate area for your own convenience. You have no regard for the necessary protection of this area.
SCDC Response: 4
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT?
Respondent Name: miss mariah skellorn [140] Submission Agent Respondent ID: 140 ID: 140 ID: SUBMISSION I do not think that the reasons for the increase in the numbers of housing are justified. In your consultation just one person suggested that the numbers be increased and your decision has been led by this as he happens to be an associate of yours (David Lock Associates). This is completely corrupt.
SCDC Response: 4, 16
SMALL WINDFALL PROVISION - REDUCE PROVISION FROM THIS SOURCE
Respondent Name: miss mariah skellorn [140] Submission Agent Respondent ID: 140 ID: 140 ID: SUBMISSION Why reduce this provision for new housing? It is the most sustainable method of providing new housing, as it causes the least impact for any one area of land. 'Peppermill' developments have proved the most popular option according to the feedback that you have published from your initial consultation.
SCDC Response: 4
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: miss mariah skellorn [140] Submission Agent Respondent ID: 140 ID: 140 ID: SUBMISSION I completely object to any number of homes on this site due to it being greenfield countryside. Building any number of homes here alters the character of this ANOB/ SSSI beyond repair. There is little evidence that the public support this massive increase in the housing numbers. I think the figures were 2% in favour of any development there at all.
SCDC Response: 17
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Miss Mary Johnson [224] Submission Agent Respondent ID: 224 ID: 224 ID: SUBMISSION I object most strongly to the proposed scale of the new housing. I accept that some new housing, with a good proportion of it affordable and/or suitable for single occupancy will need to be provided to meet the natural growth needs of Felixstowe but these huge numbers are not required for Felixstowe - they must be designed for mass inward migration, to which I object. Any new housing must be built on brown field sites and within current boundaries of Felixstowe, Walton and Trimley and not extend beyond. Welcome a dispersed approach but only as and when needed.
I object to any use of food producing agricultural land for development. (This is in any case against Government policy) As a country we need to retain and extend our food producing capabilities - we are in a perilous position already being only able to produce around 30% of our needs. Our peninsula is good quality land and must be preserved. It is wicked folly to think of building over it. The monetary ambitions of Trinity College - selling our prime food producing land for building houses, or worse, warehouses and supermarkets - must be thwarted. It appears to have no concern for the area or the people who live here and couldn't care less how our environment is ruined, or how our quality of life, health and well-being are destroyed.
The land around the peninsula is part of its setting and it attraction to day visitors and tourists - an important part of our economy and must be preserved. It is no good enhancing the attractiveness of the town and seafront but allowing the destruction of the surrounding natural area. People come to enjoy the whole experience - which includes the wildlife and country walks - precious also to those who live here.
It is unlikely the port expansion will lead to a requirement for a lot of new labour - much port work is becoming mechanised - and many of the associated jobs in offices will be created at a distance - they do not need to be on site. Over-reliance on any one employer is to be avoided and it should not be allowed to spoil Felixstowe's attraction as a tourist destination - just as likely to grow in importance as the port - and in a more sustainable and diverse way. Anyway, people who work at the dock do not all choose to live in Felixstowe. There are currently around 400 vacant dwellings so it is not because of lack of availability.
I object to the Core strategy in relation to Felixstowe (and the surrounding area). Felixstowe is NOT a major centre - ( it is not the CENTRE of anything but a peninsula! ) it is a town like Wodbridge but with less access options. There is only one way in and out - an overcrowded road, linking to a bridge already at 98% capacity. To deliberately artificially increase the size of the population in an area at the end of a peninsula is stupidity.
In the last 40 years felixstowe has had 4 or 5 estates built and I believe that that is enough of growth developments - now it should be only small scale brown field devlopments. Felixstowe is large enough - any larger it will lose it's identity and quality.
I would request the Core strategy in relation to housing be rethought. Spreading the new housing across the whole district would enable small communities to remain viable, helping to keep open their school, shops, pubs and other facilities. That the big developers won't like this approach should not be a consideration. Let local builders do it - thereby helping Suffolk's economy and jobs. Then young people can remain where they grew up, support elderly relatives (as people remaining in their own homes is SCC policy) building social capital and developing vibrant communities and local economies.
SCDC Response: 4, 22, 23, 24, 26, 27
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Saskia Johnson [369] Submission Agent Respondent ID: 369 ID: 369 ID: SUBMISSION Objection to the Local Development Framework
Dear Sir,
I am writing to disagree with the proposed development of 'Adastral New Town.' As a young person aged fourteen I don't really know the full politics of the situation but I still have my opinion. Firstly, I think that all of our lives will be made a misery by the amount of congestion that will be caused by all the cars; it is bad enough as it is. Secondly, I don't believe that the current infrastructure of our area can cope with a major housing development, as in water treatment works and electricity supply. Thirdly, I believe that the site proposed for development is valuable green space and good quality farmland that our community enjoys. Lastly, it is my generation of people that will have to clear up the mistakes you make.
SCDC Response: 13, 17, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Miss Sonya E. Burrows [528] Submission Agent Respondent ID: 528 ID: 528 ID: SUBMISSION Dear Sirs
I strongly object to the new proposal to increase the number of houses allocated to the Ipswich Policy Area and I object strongly to the entire allocation of 2000 houses being built on the one site at Martlesham next to Adastral Park for the following reasons:-
Environmental concerns - The plans for the area would cause irreparable damage to the distinct landscape character of the area. The Parish has strived to maintain a countryside feel to the whole of Martlesham which reflects our Suffolk Sandlings heritage which would be ruined by the proposed housing area and the necessary supporting infrastructure, eg. the loss of the well vegetated banks on either side of the A12. The diversity of wildlife would also suffer. The proposal would also increase the light pollution of the area.
The LDF seems keen to create a new community but this would in fact create a completely separate and isolated community effectively far from the rest of the Martlesham. This could be detrimental to the social cohesion that is essential to community life and activities which enhances the lives of residents and improves community safety. It would also mean that many of the facilities that will be needed will not be easy for residents of the rest of Martlesham to use and vice versa.
Traffic and Highways - adding 2000 houses will require extensive changes to the A12 (at least what BT proposed in their planning application) which in turn will have a large adverse impact on the residents of Martlesham with more traffic volumes and congestion which in turn could lead to traffic safety issues. In particular the residents of Martlesham Heath will have even more problems entering or leaving the only two access points (i.e. the BT and Tesco roundabouts). Increased traffic and congestion will also increase air and noise pollution. The road alterations needed will also have a devastating effect on the appearance and character of the entire area as mentioned earlier.
One of the justifications for the LDF proposal is that it will provide housing close to jobs. In practice if this development were to go ahead the houses would be occupied by people from anywhere who happen to be looking for a new home at the time and are just as likely to work elsewhere as is proved with Martlesham Heath where many residents work elsewhere. Being further out of Ipswich (a far bigger employment centre than BT) there could be more commuting traffic on existing roads to other parts of Suffolk, especially the A1214 and Foxhall Road both of which have heavy traffic which causes problems for drivers leaving side roads. New homes will also house extended family groups, many not working in the immediate area.
Public infrastructure and facilities - The LDF documents provides a list of what is thought to be needed but if a development of this size is to proceed in any way then there must be compulsion to provide all of the necessary facilities at the beginning or early on. Providing all of this infrastructure will also have an adverse impact on the area over and above that of the 2000 houses. For some infrastructure requirements this impact will have a serious effect on other parts of Martlesham away from Adastral Park (eg. providing foul sewerage facilities, extra upper school places, electricity supplies etc.). Of particular concern is that SCDC infrastructure studies have been carried out with conclusions in the LDF document without the promised consultation on the infrastructure appraisals.
Sports fields - a small but important issue is that the LDF documents appear to repeat the wrong assessment of public sports fields available for public use in Martlesham. If this is the case then the amount of space needed would be much greater because it seems that they may have included the Police HQ and Woodbridge Town FC, neither of which are publicly available.
If this development goes ahead Martlesham will be a very large village of almost 12000 people, only Felixstowe and Kesgrave will be larger! Martlesham will lose it's identity as a distinct semi-rural community, a key factor for people choosing to live here and a characteristic appreciated by all residents, and become an urban sprawl with no clear focal points.
SCDC Response: 7, 13, 16, 17, 18, 19, 20
8 YOUR COMMENTS
Respondent Name: Mr Barry Scowen [332] Submission Agent Respondent ID: 332 ID: 332 ID: SUBMISSION I have lived in Martlesham since 1962 and seen developements ie Black Tiles and The Heath turn the original Martlesham into a well balanced community now to be ruined by the overdevelpement of dense housing,a major highway leading to bottle necks in both directions,the ruination of woodland and the established embankments cuasing both noise and light pollution to those already enjoying the relative peace and the unique enviroment which is Martlesham.This is just a profit making exercise forr the developers and a way of obtaining more council tax for Suffolk Coastal Council.
SCDC Response: 17, 19
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mr & Mrs D A Hann [105] Submission Agent Respondent ID: 105 ID: 105 ID: SUBMISSION I object to the Core Strategy in its entirety as it affects Felixstowe, Walton and the Trimleys. Apart from a small number of affordable homes for local needs, the rest should be distributed across the district to minimise infrastructure costs and maximise sustainability of smaller communities.
SCDC Response: 4, 22
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr & Mrs Penn [195] Submission Agent Respondent ID: 195 ID: 195 ID: SUBMISSION Dear Sir Re the plans for BT's 2000 homes & hotel at Adastral Park, we would like to OBJECT VERY STRONGLY to this development for the following reasons. 1. Traffic congestion for another 2000 homes and hotel in this area would be catastrophic, causing many problems on an already very busy A12 and busy location. The costs to improve the road layout would be astronomical. 2. The local schools are already oversubscribed and have no room for expansion. 3. IPSWICH HOSPITAL & Local GP surgeries are already stretched & would not be able to cope with such a large influx of people to the area. 4. The Sewage System in this area is already unreliable & again great cost would be involved to rectify this to take another 2000 homes etc. 5. We have also been given to understand that the ELECTRICITY SUPPLY for this area is already at and above its limit, and BT have already installed their own generators to be able to cope. 6. It will be an eyesore and detrimental to the beautiful countryside and wild life in the area. 7. It will have a devastating impact on the environment, especially in the Deben Estuary + designated wetland site. 8. THE PARK HOME SITE. Where elderly residents live in safety, peace, and quiet would be very vulnerable to vandalism and noise from people using the footpaths around the area, to gain access to the Local Supermarket. 9. This huge development would put severe strain on already stretched resources from Local Police and emergency services, 10. It would destroy the area around Waldringfield. This area already becomes congested particularly in the summer time, and the single track road in places would be unable to cope with the extra traffic, especially with no public car park at Waldringfield. 11. The amount of Homes, Hotel etc, will exacerbate climate change far quicker, than if it were left to be beautiful countryside and farmland which the local community enjoy. 12. The homes will not be needed to create jobs. Only 3% of the work force at Adastral Park live within a mile so 97% of new residents are likely to be employed further afield, putting more pressure on roads. 13. BTs proposed destruction of a greenfield site, violates several policies in the local plan, which seeks to safeguard the landscape quality of character of the countryside. 14. Any New Community on this scale in this area would become isolated.
SCDC Response: 7, 9, 13, 17, 18, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr & Mrs R.J. & N. Jessup [201] Submission Agent Respondent ID: 201 ID: 201 ID: SUBMISSION I think the amount of development east of Ipswich has already been excessive and the proposed housing beside the BT building will mean a loss of amenity to everyone, locals and tourists alike, including you. For God's sake, leave some wild bits. Don't concrete everything. Leave somewhere for the flowers to grow, to hear the birdies sing!
SCDC Response: 17, 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr A Crawford [81] Submission Agent Respondent ID: 81 ID: 81 ID: SUBMISSION Core Strategy of Local Development Framework and Proposed Changes to Housing Distribution
Area East of Ipswich. No.4 Area South of Old Martlesham/east of A12. Consultation period -23/Sept/2009 to 18/Nov/2009.
There are a number of observations I want to have recorded, namely: 1. I believe the present procedure is flawed as the target number of houses has doubled for the Area 4 from the original 1050 to 2000. This demands that all the original areas; Area 1; Area 2; Area 3; Area 4 and Area 5 now need to be revisited & reconsidered from scratch and the 2000 should be shared out between these areas as was the practice in the Felixstowe / Trimley areas as shown in David Lock Associates survey. To be consistent the same policy should be applied over the whole of Suffolk. 2. If, unreasonably, it is decided that the "bundle" of 2000 houses for Area 4 is selected; then I want to know why SCDC is wanting to join Ipswich with Woodbridge and the effect that this new township is going to have on Woodbridge? "This bundle," as described by Andy Smith, we understand, will have retail shops; a café; including a possible supermarket; hotel; a pub; a takeaway; community facilities; primary & secondary schools and recreation areas. I want to see the reports which show what impact all these facilities will have on Woodbridge commerce! 3. On 16th June 2009- Trinity Park- SCDC announced a changed target of 2000 houses for Area 4 which was discussed within the Task Group. SCDC Planning Officer Stephen Brown stated "that these additional houses would have little or no impact on the Village of Waldringfield." This cannot be correct as the 'Maybush' Inn in Waldringfield already caters, on a Summer Saturday or Sunday, for 800 covers. The Waldringfield Sailing Club has some 600/700 members and of these some 80 / 90 are local residents. As Waldringfield has only some 250 houses and only approximately 450 residents; you can see from these figures the effect that this huge number of visitors has on the foreshore with as many as 124/138 cars per hour coming up and down Cliff Road. The settlement of Waldringfield is recognised as being a honey pot' or 'beauty spot' and 'water sport' centre and helps to generate tourist related jobs. Why should the residents of the 2000 houses in Area 4 be immune to the Waldringfield attractions? Stephen Brown's arguments do not hold water! 4. The impact of the current visitors mentioned above is already having a huge detrimental effect on the foreshore, saltings and seawalls on the River Deben at Waldringfield. These are covered by AONB; SSSI and RANSAR sites which the SCDC states it protects. You cannot add large numbers of potential visitors who live only a mile & half away and still say the SCDC is protecting this fragile unique foreshore and it's flora and fauna! The final development will be on the border of the AONB and this is against government policy. 5. It must be remembered that as recently as June 2005, both SCDC and BT fought an application by Peter Brown who wanted to create a static holiday caravan site for 122 Log Cabins in first application, reduced to 64 in second application, and these would have been directly opposite the proposed site for the houses in Area 4. In fact these houses will be closer to Waldringfield than the log cabins! The inspector turned down this application for Log Cabins on the grounds that the impact on Waldringfield would be unacceptable. [P08/1955 linked to P08/1915 & C04/-494.] 6. Much emphasis was placed on present areas which might provide future employment, among these was 'the Adastral Park at Martlesham'. British Telecommunications Ltd., and their agents David Lock Associates, would love you to believe this! The fact is that BT is sacking 30,000 employees; has stopped its graduate intake; and has asked staff to take a salary reduction! BT shares tell the real story of this former giant. There is no guarantee this company will survive in the future with the strength it has had in the past. Anyway the location of Research & Development, and production is moving to the far East. Confidence in Adastral Park is shown to be pretty low, especially after London University withdrew from the Park and went back to London. Are you really suggesting both jobs and houses should be built on the strength of this? The fact is that there is much more job potential in Area 5 than Area 4. 7. There is no supporting evidence for the assumption that Adastral Park will generate the jobs SCDC are relying on. This is an outdated myth. Quite the contrary, the people who will be living in Area 4 will be commuting to other areas around Ipswich thus helping to clog the road network. 8. It is false to represent the area SW of Adastral Park as being a 'brown site' as the contract with Bretts requires them to restore the Waldringfield quarry back fit for agriculture, which therefore makes it a 'green site' [see Minerals & Waste Development Framework - April 2007. Site 2.] 9. How can any major house development, and this is a township, be contemplated when the infrastructure is so poor? * ROADS - A12 - must rank as being one of the worst roads in Britain with it's high accident rate and rush hour delays close to the Adastral Park at Martlesham. There are already 'possible queuing' notices as you approach the A12/A14 [Nacton] roundabout. When Felixstowe Docks cannot work due to high winds or strikes, the truck stacking arrangements come into play and make the situation so bad that it takes one hour to go from the Foxhall roundabout to the A14/A12 [Nacton] roundabout. When the Hutchinson [UK] Port Ltd., Felixstowe new dock development is completed it will add some 300 extra container journeys a day onto the A14 and A12 roads and it must be remembered that volumes are low now due to the recession. Is the SCDC suggesting we should add to this already overcrowded road system? I understand that there is a recent transport assessment report which has identified the section on the A14, between A12 exit near Nacton over the Orwell Bridge to the A12 London turn off, will be over the design capacity after Hutchinson dock at Felixstowe is completed and traffic delays are to be expected. [Stage 1 will be in operation in September 2010.] £13.75 million will be needed for road improvements. * TRAINS - Area 4 could not be in a worse location for connections with the rail network. * WATER - the fact is there is not enough water in this area being one of the driest parts of the UK. Anglian Water confirm this and say a significant sum of money will be required to provide water and sewage. * ELECTRICITY - EDF Energy have confirmed it is already under pressure and will not be able to cope with any additional demands unless there is an upgrade to the grid and this would need £5.5 million. * HOSPITALS - Ipswich Hospital NHS Trust - If the suggested number of houses is seriously being considered, then why are the services in this hospital being withdrawn? Is this the best joined up thinking you can produce?
Summary - LDF - Area 4 - Objection to 2000 house build. See accompanying letter 24th October 2009
* Flawed procedure! Doubling Area 4 to 2000 houses demands revisit to all other areas. * New township - shops; hotel; etc will affect Woodbridge commerce. - Report required! * AONB, SSSI & RAMSAR sites will be adversely affected. [See my letter] * Settlement of Waldringfield also adversely affected. [See letter] * In June 2005 - Inspector has already turned down holiday cabins in similar area. [P08/1955 linked to P081915 & C04/0494] because of its effect on Waldringfield. [See letter] * Infrastructure - A12 - near Adastral Park - already has major problems. [See letter] - A14 - has stacking congestion - will have massive increase when Felixstowe dock development is complete. [See letter] - Water - This is the driest area of the UK - supply critical. - Trains - Could not be worse for connections. - Electricity - Already under pressure. - Ipswich Hospital - being downgraded.
* Adastral Park - poor future employment prospects - BT sacking 30,000, no graduate intake, etc.. R & D, & production moving to far East. * Area 4 - not a brown site!
SCDC Response: 1, 4, 7, 9, 11, 12, 13, 16, 19, 20
THE MARKET TOWNS
Respondent Name: Mr A.W Dunn [468] Submission Agent Respondent ID: 468 ID: 468 ID: SUBMISSION Let me start with your document presentation. It offers a complete disregard for Real English, a garbled and poorly presented set of statistics and is obviously designed to exclude constructive comment from the general public. In short, a typical junior civil servants mish-mash. PAGE 1. Concise answers. a) - No. b) - No. Considering the allocation for Leiston it appears that no thought has been given to the likely expansion of Sizewell Power stations. Any employment will be transient. The pressure on local infrastructure *(Roads, Schools, Police, fire, Retailing, Health) will be unsustainable. Previous Sizewell projects have left Leiston as a social backwater, and will again. WHAT CHANGES TO MAKE = If it is reasonable to inflict such a large increase of housing into an essentially rural area, you must address areas of sustainability which you have not yet considered. This now raises the question - who are you? Page 4, Para3.05, states clearly that ".. the final say on the matter will rest with the Independent Planning Inspector.." appointed, no doubt, by an unelected government quango. I would suggest that Suffolk Coastal D.C, myself, and the neighbours dog, have no influence whatsoever over the outcome of this so called "consultative document", and that the whole exercise has been fabricated to conform with Political Correctness. Any right thinking person would recognise that Leiston can not maintain the proposed development of over 200 more homes during the foreseeable future.
SCDC Response: 1, 4 Other comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Alan Krailing [322] Submission Agent Respondent ID: 322 ID: 322 ID: SUBMISSION I would suggest that the impact of a quarry and a development of 2000 homes can be in anyway comparable. A development of this type will become a permenant feature of the landscape whilst a quarry would be a time limited feature and will have a far more significant visual impact.
SCDC Response: Noted
IPSWICH POLICY AREA
Respondent Name: Mr Alan Krailing [322] Submission Agent Respondent ID: 322 ID: 322 ID: SUBMISSION I feel that a development of this scale at this location would be wholly inappropriate. The development encroaches in to open countryside and would undoubtably detract from the neighbouring AONB. Infrastructure in terms of transport, and amenity is also inadequate and will impact negetively on surrounding communities such as Woodbridge and Waldringfield.
SCDC Response: 11, 17, 18, 19, 20
2 THE CONSULTATION IN BRIEF
Respondent Name: Mr Alan Sexton [239] Submission Agent Respondent ID: 239 ID: 239 ID: SUBMISSION 2.06 Why is a large development Ok for Martlesham but smaller dispersals thought more appropriate for Felixstowe
SCDC Response: 15
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY?
Respondent Name: Mr Alan Sexton [239] Submission Agent Respondent ID: 239 ID: 239 ID: SUBMISSION
5.12 The proposed development at Martlesham does not support these priciples
SCDC Response: 4, 16
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mr Alan Sexton [239] Submission Agent Respondent ID: 239 ID: 239 ID: SUBMISSION
5.10 The proposed development at Martlesham would appear to go against the majority of these principles
SCDC Response: 4
HOUSING DISTRIBUTION FELIXSTOWE/WALTON AND TRIMLEY VILLAGES
Respondent Name: Mr Alan Sexton [239] Submission Agent Respondent ID: 239 ID: 239 ID: SUBMISSION
5.19 Why have the key concerns been recognised for Felixstowe but totally ignored for Martlesham
SCDC Response: 15
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Alan Sexton [239] Submission Agent Respondent ID: 239 ID: 239 ID: SUBMISSION 5.17 There has been no evidence to support Martlesham as the best solution. There are no specific requirements as to what is required to "manage the problems" or what would be an "acceptable level" to the existing population
SCDC Response: 4, 16
3 BACKGROUND
Respondent Name: Mr Alan Sexton [239] Submission Agent Respondent ID: 239 ID: 239 ID: SUBMISSION 3.02 What evidence is there that 25% of housing requirements will be needed in Martlesham area to support population, employment trends etc
SCDC Response: 3, 4, 16
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Alan Sexton [239] Submission Agent Respondent ID: 239 ID: 239 ID: SUBMISSION Surely the detailed work setting out the infrastructure requirementsand costs should be completed BEFORE agreeing to such a massive development at Martlesham
SCDC Response: 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Alan Sexton [239] Submission Agent Respondent ID: 239 ID: 239 ID: SUBMISSION 6.2 Where is the proof that benefits outweigh disadvantaged 6.3 How can bringing 5000 to a small area mitigate the impact of visitors 6.5 How can the doubling of houses to 2000+ have more benefit than 1000
SCDC Response: 4, 16
IPSWICH POLICY AREA
Respondent Name: Mr Alasdair MacLeod [331] Submission Agent Respondent ID: 331 ID: 331 ID: SUBMISSION I have addressed my concerns to specific bullets in the document, however, they may apply in a wider context and it is my intention that they be considered both addressing the specifics of a bullet point and also to other relevant areas of the document.
General: A reassessment of the housing demands on the area is expected in 2010, this development should be delayed until this reassessment, or the reassessment brought forward. Traffic analysis appears to have been overly narrow and a more thorough analysis is required.
== 5.10 == I (and my family) object to the development East of A12 as it does not comply with the housing distribution principles set out in 5.10
* Any new or improved infrastructure should be provided in advance of or in parallel with new development; This development does not provide new schools from the outset and will add massively to the strain on local primary schools in Martlesham Heath and Kesgrave. It has been stated that financial assistance will be provided to local High Schools. However, Kesgrave High School, the local High School has already stated that they have grave concerns about this development and, irrespective of funding, cannot expand to meet the needs. A new High School, built from the outset, should be added to the proposal to alleviate the load on Kesgrave High School as it cannot meet the expected demand. The distance between local schools and the development will add greatly to rush hour traffic congestion. This development does not put in place the necessary amenities and road infrastructure in advance of the development. It does not put in place the necessary infrastructure in a way that can meaningfully be called "parallel"
* We should look first to re-developing old "brown field" sites before looking to identifying new green field sites The majority of this site is countryside and would not be considered brown field by any general definition. The public would take brown field to mean existing building and industrial sites - this development will be on agricultural land. The quarry was granted planning approval on the condition it be re-instated to it's previous condition and cannot be treated simply as brown field
* The road, rail and other public transport networks should be capable of accommodating the traffic and journey requirements that new housing inevitably brings with it; This site will become an Ipswich commuter suburb (see my comments below - about the lack of employment at Adastral Park) there are no rail links, roads are the only route. Both private road vehicle and public transport will put a great strain on the road system, especially into Ipswich. There is no evidence that the road and public transport networks can accommodate the traffic. SCDC traffic forecasts are heavily qualified and I believe cannot be treated as reliable. Further traffic analysis is required.
* New housing should allow integration with existing communities but at the same time should respect and maintain the character of individual settlements and communities; This development will swamp the local communities and is not in any way in keeping with the character of surrounding communities. It is a high-rise, high-density development, unlike the surrounding area and does not fit with the surrounding communities. It does not respect the character of the surrounding communities and will erode, not help maintain, their character.
* In deciding where new development should go, it should respect the quality of the local environment; This development will drastically reduce the quality of the local environment. The area being developed is currently agricultural and woodland with some quarrying - which is to be re- instated to it's previous condition once quarrying finishes. This development will be high-impact and transform countryside into a city-scape of high-density urban housing. It does not respect the quality of the local environment and in fact will drastically reduce the quality of the local environment. See my comment about the impact on Martlesham Heath private land below.
* Protection should be given to wildlife and to the landscape, particularly those areas that are designated as being of national and international importance; This development does not protect the landscape, it imposes: - High-visibility, hi-rise housing in a country setting - It urbanises a large area of what is currently countryside - This will drastically change local species habitat, favouring urban species and pushing out local wildlife. It will be damaging to the wildlife and landscape.
* That housing and jobs should be provided in tandem; Adastral Park cannot be considered an area of employment growth. BT (by far the main employer) has a history of moving work previously conducted at Adastral Park out of the UK It is undertaking a drive to reduce its headcount, including reducing employment at Adastral Park, this started before the current recession and cannot be ascribed to the short term economic outlook. In fact, the headcount reduction has been such that entire buildings have been freed up, allowing the Police to move on-site, I am told the Police are also cutting back. Other employers at Adastral Park employ low numbers and do not present significant employment opportunities The hotels and other proposed amenities do not constitute a significant source of employment This development does not provide housing and jobs in tandem. The major employer in the area is reducing headcount.
* Building on high quality agricultural land should be avoided as far as possible. This development will build on agricultural land and land which is being quarried I understand that the quarry's planning permission was on condition that it be re-instated to agricultural land Other approaches can be taken that avoid this wholesale replacement of agricultural land with high-density settlement.
== 5.12 == The development does not meet the objectives laid out in 5.12; in fact it runs counter to them.
* To provide new housing where it will support new employment provision and has the optimum opportunity for providing new and improved infrastructure to support it; This development will not support new employment provision, it assumes Adastral Park as an area of employment growth but in fact employment in the Adastral Park site is falling.
* Limiting any adverse impact of new development on existing communities, countryside and wildlife This development will put intolerable strain on existing schools, medical provision and other amenities It will have a huge impact on the countryside and wildlife. The high-rise, high density, nature of the development will have a detrimental impact on the countryside and wildlife. It will encourage urban species and push out species that favour the countryside The new footbridge would create a new route that effectively terminates on private ground. This will impose higher maintenance costs to the owners and encourage a higher loading on the Martlesham Heath amenity ground than it was intended to support.
* To provide a high quality, sustainable living environment for all residents, new or existing This development is out of keeping with the area and other communities It will reduce the quality of the Martlesham Heath area and the high density will not provide a high quality environment to its residents. My comments about the footbridge equally apply here.
SCDC Response: 4, 5, 7, 9, 10, 11, 15, 16, 17, 18, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Allan Ripley [480] Submission Agent Respondent ID: 480 ID: 480 ID: SUBMISSION Dear Sir, I am writing to complain about the proposed expansion of Martlesham by building another 2000 houses. Martlesham has already been allowed to grow too large. This proposal will turn it into a town, and part of our open countryside will be lost forever. More land will be lost providing schools and other amenities. The road into Ipswich is already clogged due to all the new building at Kesgrave, and is subject to delays at certain times of day. The link road from the A14 over the heath to the Black Tiles roundabout has become a race track and will become much more dangerous with higher levels of traffic. I urge you to preserve Martlesham as a rural village.
SCDC Response: 4, 16, 17, 18, 19
APPENDIX 5 - REVISED SETTLEMENT HIERARCHY
Respondent Name: Mr and Mrs Alan Pitt [336] Submission Agent Respondent ID: 336 ID: 336 ID: SUBMISSION Table 2,appendix 5, shows most new development to be directed to major centres and market towns and surely Martlesham Heath is neither ! 5.10 Public transport networks should be capable of coping with traffic , journey requirements that new housing brings...Where is the evidence that it will ? Surely an argument for load/pepper potting approach to where new houses go ? New development to respect quality of local environment...HUGE impact and danger to AONB , where is the respect ? Protection should be given to wildlife ,landscape of national importance;An arguement for NOT building a large development at Adastral Park. Schools wouldn't cope.
SCDC Response: 4, 16, 17
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mr and Mrs E and K Horn [302] Submission Agent Respondent ID: 302 ID: 302 ID: SUBMISSION I object to the Core Strategy in its entirity as it affects Felixstowe, Walton and the Trimleys. Apart from a small number of affordable homes for local needs, the rest should be distributed across the districts to minimise infrastructure costs and maximise sustainability of smaller communities.
SCDC Response: 4, 22
IPSWICH POLICY AREA
Respondent Name: Mr and Mrs J Wade [439] Submission Agent Respondent ID: 439 ID: 439 ID: SUBMISSION Do you want to know how to destroy a village like style of living?
Answer: Let SCDC and BT develop a new town of 2000 plus houses, plus commercial units, plus a school and a hotel. there are numerous commercial units standing unoccupied in the Anson Road - Gloster Road area so why build more.
Just think 2000 homes equates to approximately 4000 plus people, possible 2000 plus cars, destruction of the countryside, wildlife in the area will disappear and more residents will put extra strain on all services causing problem access across the board.
The A12 was recently reported to be one of the worth roads in the country so it seems logical to make it even worse with convoys of construction vehicles, road works, roundabout alterations etc leading to major traffic problems. The infrastructure will not be able to cope with a new development that will finish up twice the size of Martlesham Heath.
All that being taken into account "Joe Public"s views will not be considered. BT and SCDC have the money and clout to steamroller this proposal through regardless of public opinion.
SCDC Response: 1, 13, 17, 18, 19, 20
IPSWICH POLICY AREA
Respondent Name: Mr and Mrs J. K Ramsay [478] Submission Agent Respondent ID: 478 ID: 478 ID: SUBMISSION We wish to record our strong objections to the revised LDF issues by the Council on the following grounds:
1. The Suffolk Coastal Council has failed to provide any tangible justification for this revised plan. Reliable sources within Ipswich Council have informed us that Ipswich is awash with empty developments so much that even planning applications for brownfield sites in central Ipswich are being refused until such time these empty developments are filled with people. Clearly there is no demand for this type of development. Set against the background there is no evidence of demand fo housing in this area.
2. BT's (the applicant for planning permission) own statistics fail the proposal. They estimate that out of 2000 homes fewer than 500 residents may be employed locally. Leaving the shortfall to commute. This indicates a serious flaw in the proposal.
3. Poor commuting links. Current bus and rail services are inadequate to service this level of activity.
4. Poor infrastructure. 2000/3000 homes mean minimum of 5000 cars. Given the poor commuting facilities, an extra 5000 cars will cause much increased congestion on the A12 in particular the already crowded Brightwell roundabout. The affect on surrounding minor roads will have a devastating impact, not only on road congestion but also pollution, and the environment.
5. The proposal will be a monstrous blight on the aesthetics of the area and the Environment. The BT proposal borders an Area of Outstanding Natural Beauty (AONB) and is currently agricultural land, in line with the surrounding area which also borders an AONB. We have been regular visitors to the area and have become accustomed to the beautiful sight of open countryside as we turn off the Brightwell roundabout for Waldringfield. Clearly the proposed 'mini town' will wreck this and forever scar the environment and profoundly change the whole balance for good. The current villages of Newbourne and particularly Waldringfield are already overrun by cars at regular times in the year. What would be the effect of a further 2000 homes on the doorstep? It is obvious - the wholesale destruction of these villages and their important local aesthetic. It is difficult to estimate what future generations would say to this in judgement on the actions of the COuncil responsible.
6. Is Adastral Park a world class facility?? BT have claimed that this development is key to the Park's future as a world class centre for technology and innovation. This already exists - in Cambridge. It is doubtful in extremis if this wholesale destruction of the countryside will attract world class research companies when the Cambridge Science Park already exists and is expanding. There is nothing evidenced by BT application to suggest that this park can achieve the critical mass necessary to attract such companies.
7. Underlying land use section. The original plan (Area 4 LDF), was, for approximately 1000 homes situated in a much smaller area. This plan itself was subject to rigorous objection and debate. And then what happened? BT put in its application for 2000 homes, and then what happened? The Council changed its mind and effectively doubled the housing in the LDF by reducing the plan for Felixstowe which does have the infrastructure and amenities and attractions to support this type of development. The clear conclusion could thus be drawn, in the absence of evidence to the contrary, that it is BT and not the council who are running local affairs. This does not reflect well on the council. There was clearly no recognition in the original LDF plan for such an area as is proposed in the BT application. No satisfactory reason for such a radically revised conclusion has been put forward by the council. In the absence of hard evidence to support such a revised conclusion it is difficult to avoid the aforementioned conclusion of a powerful local employer (tha largest?) having undue influence.
8. Demand management. Reflecting on the first point made, the LDF should be drawn up not in response to future government targets which in themselves are questionable but to actual demand. Where current employment and future targets in employment has caused shortages in housing stock in a particular area then a case can and should be made for projected developments. Currently BT along with other major corporates is shedding staff, so the opposite is the effect - acres of bland housing with minimal occupancy. There is a wider question here - Is there a defined need evidenced by demand for this LDF and shouldn't the council be raising this a s a valid question for government??
It is hard if not impossible to find any justifiable grounds for this revised plan. Rather than engaging in a responsible debate on housing demand, it is very easy to reach the conclusion that this is no more than a council tamely following a cynical money making exercise being orchestrated by BT with a total disregard for both the environment and its local population.
SCDC Response: 3, 7, 11, 13, 17, 18, 19, 20
IPSWICH POLICY AREA
Respondent Name: Mr and Mrs L Snowdon [446] Submission Agent Respondent ID: 446 ID: 446 ID: SUBMISSION We wish to register our opposition to BT's planning proposal on the land between their existing site, Adastral Park and Waldringfield Heath. Our reasons are as follows:
1. At present this land is designated as Greenfield, with the quarry being required, under the terms of their planning permission, to be returned to a Greenfield site when the mineral extraction license expires.
2. Increased traffic on the A12 and A14 which will also increase with the expansion of Felixstowe Docks. The minor roads surrounding the proposed development would be unable to cope with the extra traffic.
3. The access to the proposed development would appear to be fairly limited and with the suggested changes to the A12 layout the likelihood for major traffic delays is inevitable. Even with the present layout, this layout is often featured on traffic reports as being a place to avoid!
4. increased noise and pollution. It is highly unlikely that many of the residents would work at Adastral park.
5. From the existing published plans, it would appear that BT's planning consultants are trying to cram in as many new properties and residents as possible. To do this they are suggesting multi-storey housing areas, which is not in keeping with the local area. 6. This proposal, and the one at Trimley, will place additional strain on the supply of services, e.g. water, electricity and sewage. We gather, for instance, that Alton Reservoir is barely able to cope with existing supply area east of Ipswich and Felixstowe.
7. It has recently been suggested that an Ipswich Northern bypass be seriously reconsidered. In conjunction with this it should be possible to meet the new housing target by locating SMALL blocks of development along this new route, rather than just one or two oversize areas.
SCDC Response: 4, 7, 12, 13, 17, 18, 19, 20
IPSWICH POLICY AREA
Respondent Name: Mr and Mrs P Woodhead [458] Submission Agent Respondent ID: 458 ID: 458 ID: SUBMISSION Re the proposed development at Adastral park, we strongly object on all accounts. The number of houses is not acceptable, the traffic impact is of major concern, even though they propose new roads it will not be the solution. All in all it will be a catastrophe. please please do not let this happen for us or our future generations.
SCDC Response: 4, 11, 13
THE OVERALL STRATEGY
Respondent Name: Mr and Mrs Pratt [570] Submission Agent Respondent ID: 570 ID: 570 ID: SUBMISSION I am writing regarding your plans to build 2000 new homes at Martlesham and wish to state that I do not approve. It will have a huge impact on the local environment, in fact changing it so drastically that it will no longer be the place that we have known and loved. I am concerned about the infrastructure, how will the road, hospitals, doctors and schools cope? I t cannot be acceptable to drastically change a local environment to this extent. I do believe that housing is needed but should be distributed amongst all local areas and villages to so lessen the impact.
SCDC Response: 4, 16, 17, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Andrew Bailey [254] Submission Agent Respondent ID: 254 ID: 254 ID: SUBMISSION Dear Sir/madam
I am writing to you to express my very strong disapproval of the proposed revisions to the number of houses proposed to be built in the Martlesham heath, up from 1050 to 2000. I have already corresponded to you previously on this matter, which I hope you still have on record but even more so now, at the last consultation point. Therefore my objections that I made previously as far as I am concerned still stand, however I will briefly outline them again.
1) No sufficient provisions made to deal with the significant increase in road traffic in the immediate area, namely a minimum of 2 cars per household on average.
2) No adequate provisions being made for schooling.
3) Ever since I moved into the area over 9 years ago, there has been talk of the technology corridor, in all that time nothing has really happened, in fact there has been a scaling down of BT's operations in particular, with no sign of that changing. No work in the immediate area means that more people will have to travel to a place of work. Quite frankly, Grange Farm, Kesgrave is a good example of how a development on this scale in reality does not work satisfactorily.
4) Not enough thought into local services and the impact the scale of a development of this scale will have on the existing infrastructure.
5) Not to mention the devastating impact that a green field development on this scale will have on the environment and its wildlife.
6) I realize that this level of housing is going to be a necessary evil, but you should seriously consider downsizing the developments to smaller developments in more distributed areas.
I trust that you will take seriously my objection to this particular development, mainly due to its ridiculous scale which would effectively create a new town rather than a new community. Developments of this type are completely out of character for our county and indeed our village and need to be stopped.
SCDC Response: 4, 7, 13, 17, 18, 19, 20
8 YOUR COMMENTS
Respondent Name: MR Andrew James [343] Submission Agent Respondent ID: 343 ID: 343 ID: SUBMISSION It is clear that there are huge concerns about the capability of surrounding infrastructure and access routes. The numbers are unfeasibly large and, also, there is suspicion that this is a BT plan that we are being led into rather naively. Without demonstration of the necessity of these buildings, the capability of the access roads and the protection of the local rural beauty spots and treasures, I cannot see benefit to the area from this plan.
SCDC Response: 17, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: mr Andrew Moore [287] Submission Agent Respondent ID: 287 ID: 287 ID: SUBMISSION Your system of commenting/ supporting and objecting is not robust so I have failed to log Objection previously. Please add to my comments already made that I object to any increase from the 1050 homes proposed on the Adastral Park site, due on Traffic pressures and those on the delicate infrastructure of the area.
SCDC Response: 16, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: mr Andrew Moore [287] Respondent ID: 287 Submission 287 Agent ID: ID: SUBMISSION The road system in the Martlesham area , although adequate and to a very good standard when built in 1977, is no longer adequate. This is due to the dramatic increase of traffic which accesses local business , the Grange Farm new town and more general traffic moving through the area for access to Suffolk in general and the Ports of Gt Yarmouth and Lowestoft industry. To heap more demand on the road system without wholesale changes, relief roads underpasses etc would make life intolerable living alongside the bottleneck A12.
SCDC Response: 13, 14, 19
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: mr Andrew Moore [287] Submission Agent Respondent ID: 287 ID: 287 ID: SUBMISSION I believe that Felixstowe has to be regenerated. It is a super Town but it needs a cash injection to reenergise the Town and seafront Fresh housing with a range of prices from 1st time buyers to the luxury end would bring prosperity. Roads would need to be improved to lessen the impact on the existing communities. Developers need to pay a greater proportion of this cost and the planning mistakes of Grange Farm Kesgrave used as model of how not to build.
SCDC Response: Noted
7 THE UPDATED PREFERRED OPTION 7/09 HOUSING DISTRIBUTION SUMMARY
Respondent Name: mr Andrew Moore [287] Submission Agent Respondent ID: 287 ID: 287 ID: SUBMISSION It is understood and accepted that new housing is required and that there are communities dying because of unaffordability of housing required by young people to buy in the area where they have grown up. If the study outcome has concluded that the new housing stock should be spread throughout Suffolk and is the best option, why have the SCDC planners decided on the opposite view. Perhaps it is more lucrative and less hassel to have one . project, than have to deal with many smaller proposals. I therefore object to the single site approach.
SCDC Response: 4, 16
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: mr Andrew Moore [287] Submission Agent Respondent ID: 287 ID: 287 ID: SUBMISSION The prospect of increasing the proposed Adastral Park development from 1050 to 2000 or even 3000 homes and in filling the countryside which acts as a natural buffer between the communities seems to be out of proportion and wholly unacceptable. The numbers of residents proposed is such that all the services Water, Sewerage Gas, Electricity , telecoms and Road Access would have to be radically changed and extended. This pressure on the local community would be intolerable. The recreational and quality of life in the area would suffer greatly.
SCDC Response: 17, 18, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Andrew Pitcher [40] Submission Agent Respondent ID: 40 ID: 40 ID: SUBMISSION In the FAQ section
6. Why are so many houses proposed at Martlesham (east of the A12) and why has this changed? you state, "Aspects such as highway capacity etc can be managed subject to the necessary developer contributions without causing unacceptable disturbance to the area." With 2000 new houses, what evidence do you have which supports this? What happens if there is no "developer contribution" - does that mean highway capacity cannot be managed so the development cannot go ahead?
SCDC Response: 11, 12, 13, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Andrew Pitcher [40] Submission Agent Respondent ID: 40 ID: 40 ID: SUBMISSION Dear Sir/Madam
Firstly, I object to the idea that this consultation is just on the "updated housing distribution" since I have seen no evidence that objections to the first consultation have been addressed. I think the changes would be extremely detrimental to Martlesham Heath in particular and the whole area in general. There will be greatly increased traffic, noise, and pollution on the A12, A1214 and Foxhall Road. Also, there will be more pressure on already oversubscribed schools and on health and emergency services. It would result in further urbanisation of our countryside and pressure on AONB. Martlesham Heath would lose its identity as a successful modern village. I don't think it's fair to put so many new houses in one place. Spreading the build across the region to make more villages viable in terms of schools, buses and Post Offices seems to me a more sustainable approach. Thank you.
SCDC Response: 1, 4, 13, 18, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Andrew Pitcher [40] Respondent ID: 40 Submission 40 Agent ID: ID: SUBMISSION I write to object to the plans to build more houses in the Martlesham area. With regard to the question "Why are so many houses proposed at Martlesham (east of the A12) and why has this changed?" you state that "The land to the east of the A12 is considered, [...] the most sustainable and to offer the most potential benefits of the areas within the Ipswich Policy area upon which the Council consulted on in February 2008. That is not to say that it is perfect nor met with universal approval."
The implication here is that a significant number of respondents did indicate approval. May I see the evidence for this? You go on to say that "the area east of the A12 offers the best opportunity to develop a new stand alone community." This is merely your opinion and should be stated as such.
You state "Inevitably, for a plan such as this, not everyone will be happy with what is proposed." This seems to imply that most people are happy. May I see the evidence for this?
With regard to employment, BT has been winding down the research work it does at Martlesham Heath for several years. The LDF should be based on up-to-date figures regarding the number of staff it employs in the Ipswich area. Also, more than 10 per cent of BT staff work from home.
You state in separate parts of the same document that "New housing should allow integration with existing communities but at the same time should respect and maintain the character of individual settlements and communities" and that
"The area East of the A12 was chosen as the Preferred Option as offering the best all round solution to meeting the objectives set out above, creating a stand-alone community but well related to a range of employment uses, the primary road network, public transport and other facilities and having the least impact on other individual communities." Please explain how "integration" and "stand-alone" are to be achieved at the same time.
With regard to transport, drivers experience considerable delays now. With such an increase in development, clearly it will get worse. More traffic lights on the A12 will have a huge impact on the whole region.
Andrew Pitcher
SCDC Response: 1, 7, 13, 18, 19
THE MARKET TOWNS
Respondent Name: Mr Andrew Stewart [29] Submission Agent Respondent ID: 29 ID: 29 ID: SUBMISSION I am strongly opposed to Green Field sites being considered around Leiston. I would have thought that with Sizewell C on the horizon we should not be considering any extra housing in and around Leiston.
Sizewell's emergency plan would struggle to cope with Leiston the size it is at present without making it any larger. The plan has the Police allocating Iodine Tables to the residents of Leiston in the event of an incident, making Leiston any larger will make this even harder and therefore less safe.
SCDC Response: 4, 13
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Anthony Greathead [104] Submission Agent Respondent ID: 104 ID: 104 ID: SUBMISSION To state that "no pressures on the household waste recycling centre are identified as a result of the predicted growth" is ludicrous.
SCDC Response: 20 Other comments noted
8 YOUR COMMENTS
Respondent Name: Mr Anthony Greathead [104] Submission Agent Respondent ID: 104 ID: 104 ID: SUBMISSION The proposed changes are NOT justifed, nor will they ensure that the broad strategy will be better met as a result.
SCDC Response: Noted
IPSWICH POLICY AREA
Respondent Name: Mr Anthony Greathead [104] Submission Agent Respondent ID: 104 ID: 104 ID: SUBMISSION This is a nonsense. How can you take a very individual, design-award-winning community in Martlesham Heath, plaster onto it an even bigger development, and call it integrated without destroying the very essence of what made Martlesham Heath unique in the first place ?
SCDC Response: 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Anthony Greathead [104] Submission Agent Respondent ID: 104 ID: 104 ID: SUBMISSION There seem to be numerous references to people walking their dogs, as if this was the only recreational activity that mattered. Perhaps more truthfully it will become the only activity capable ot taking our minds off the incessant noise, traffic, and blighted skyline this monstrosity of a development will engender if it is allowed to go ahead.
SCDC Response: 17, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Anthony Greathead [104] Submission Agent Respondent ID: 104 ID: 104 ID: SUBMISSION I object to the council's argument (point 5 in para 6.03) that the impact of doubling the number of homes is limited. To then go on to argue that the doubling is in some way justifiable on the basis that it will help secure the necessary funding to ensure infrastructure upgrading is done to a good standard beggars belief. This is all gobbledygook and the use of circular argument. In the subsequent point 6 the council refer to an appreciation of the increased pressures on the area. It needs far more that. What about detailed modelling and clear evidence?
SCDC Response: 20
STEP 3 PRODUCE A HOUSING DISTRIBUTION STRATEGY BASED ON THE PRINCIPLES SET OUT ABOVE, WHICH MEET THE REGIONAL REQUIREMENTS AND COMPLY WITH NATIONAL PLANNING POLICY GUIDANCE.
Respondent Name: Mr Anthony Greathead [104] Submission Agent Respondent ID: 104 ID: 104 ID: SUBMISSION The proposal to double the number of houses at Martlesham fails the tests set out in bullets 4, 5, 6, and 7 of para 5.10 in that transport networks will not be capable of accommodating the increased traffic, nor will housing respect and maintain the character of the Martlesham communities. In short the proposal will overwhelm Martlesham, Martlesham Heath, and Waldringfield. Furthermore, the proposal will neither respect the quality of life of the local environment nor provide protection to wildlife and landscape.
SCDC Response: 11, 12, 13, 17, 18, 19
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Mr Anthony Greathead [104] Submission Agent Respondent ID: 104 ID: 104 ID: SUBMISSION I see very little objective evidence to support the bald statements made regarding sustainability. With doubling of housing in SP20 East of Ipswich, how can the policy be said to be only marginally less sustainable? Whilst statements of intent (Appendix 1) to "minimise need for motor vehicles, upgrade foot and cycle paths... etc" are linked to a positive effect on peoples' health, this is pure supposition. Will the occupants of the expanded housing shun personal vehicles and walk/cycle/bus everywhere? Of course not ! Doubling the housing can only be detrimental to existing communities.
SCDC Response: 7
8 YOUR COMMENTS
Respondent Name: mr anthony Shakespeare [211] Submission Agent Respondent ID: 211 ID: 211 ID: SUBMISSION I object strongly to the way this site is deliberately difficult to object. The number of houses proposed for this site is ridiculous, the scale is out of balance and character with the area. new proposal sneaked in without due consultation. This is easy option for council without necessary forethought to consequencies. No local councillors were on committee making decision,strange that Felixstowe councilors were there to veto their site How is A12 to cope, already overladen at peak times. These homes will be near neighbours to Foxhall Rd tip, with wind in that direction!! Traffic solution plan needs amendment BT position incorrect!
SCDC Response: 1, 4, 13, 16
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Antony Gifford [323] Submission Agent Respondent ID: 323 ID: 323 ID: SUBMISSION As a regular visitor to the area with friends and family in Martlesham and Waldringfield i am staggered that the greenfield site at Adastral is being considered for any houses let alone this expanded proposal. The whole scheme only makes sense to BT as landowners, it is something that the authorities and people of Suffolk will regret allowing for years if it progresses. Suffolk Coastal need to go back and find a better solution rather than choose one of five they have concluded all raise problems.
SCDC Response: 4, 16
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Barry Scowan [529] Submission Agent Respondent ID: 529 ID: 529 ID: SUBMISSION I have been a resident in Martlesham since 1962 and seen it develope via the Black Tiles area and of course Martlesham Heath into a wonderful well balanced community,which with the latest proposal will change the area in all recognition - for the worse.What was once an area with reasonably busy A12 sometimes slightly chaotic depending on the time of day will now become a massive highway leading nowhere exept to a bottle neck in which ever way you travel.The whole area will suffer both noise and light pollution.Trees and embankments will come under the plant and machinery.
SCDC Response: 13, 17, 18, 19
5 HOW HAS THE HOUSING DISTRIBUTION BEEN DRAWN UP? AND HOW AND WHY HAS IT CHANGED?
Respondent Name: Mr Barry Slater [581] Submission Agent Respondent ID: 581 ID: 581 ID: SUBMISSION Darsham Parish Council are strongly of the view that Darsham should be moved up the settlement hierarchy to a Key Service Centre. I believe that view will be expressed again in their response to the current round of LDF consultation.
In addition to its church and village hall, Darsham's facilities include a main-line railway station, a petrol station with large general store, a farm shop, a pub, two roadside cafes and a number of significant places of employment (e.g. tile works, tyre centre, care home, removals business). There is also a large static and touring caravan site and outstanding planning permissions for a small 'boutique' hotel and a 40 bedroom motel.
It seems to me their case is overwhelming.
However, I am happy to have it fed in as a consultation response from me in its own right.
In which case I had better add a restatement of my own strong view that 210 new allocations across 23 key service centres (and nothing at all for local service centres) over the 15 years envisaged in the LDF is ludicrously inadequate for the organic and incremental growth which rural communities - such as those I represent - need in order to thrive and survive.
For rural communities this is a pressing sustainability issue for which the arguments are too well rehearsed for me to need repeat them here.
I think the allocation to key service centres should be substantially increased and that there should also be a perhaps smaller but significant allocation across local service centres. Discussions locally would indicate this is a view shared by my parishes.
I understand the arguments in favour of concentrating development where there are jobs, schools, public transport etc. - i.e. in existing larger centres of population - and that government will be looking for that in the LDF. However, I also think this argument underestimates the strength and scale of the rural economy. Moreover I believe that requirement can still be met with a substantially larger rural allocation than the present 210.
Pease receive the above as a response to the consultation.
SCDC Response: 4, 27
THE UPDATED PREFERRED OPTION REPORT JULY 2009
Respondent Name: Mr Brian Farrow [136] Submission Agent Respondent ID: 136 ID: 136 ID: SUBMISSION Consultation on the Updated Preferred Option 7/09 Housing Distribution Summary
1. These latest proposals suggest that houses and commercial facilities could be built on Site 451g at the back of Treetops amongst others in the area separating Walton and Trimley. Surely we can ill afford to build on grade 1 and 2 farmland when the population is increasing rapidly and the price of bread and other related products is rocketing due to the growing use of cereals for bio fuels?
2. The proposal to link Walton High Street and Candlet Road to service the proposed new residents and businesses in the area separating Walton and Trimley can only be a disaster wherever the link is sited. Candlet Road is already at capacity in the morning and evening and is often at a near standstill at these times now.
3. If approved, residents and businesses in the proposed areas would need direct access to the A14 not Candlet Road. Without a flyover at the Dock Spur roundabout, the proposed link road would have to be somewhere on the Trimley side of the Dock Spur Road.
4. Building on areas 451g and 451i across the road would cause sewage disposal problems. It is well known that houses in Hawks (not Hawkers, the name used in the document) Lane are at the extreme end of the of the Felixstowe sewage system and there are often traffic problems when the sewage system fails and clearance work takes place at the large access point in the middle of Walton High Street.
5. Personally I am concerned that if houses and businesses are built on Area 451g, access may be considered via Gulpher Road and Treetops. The Gulpher Road junction with Walton High Street is very narrow and can be virtually blind when cars and vans are parked on the footpaths on both sides of the junction. Illegally parked vehicles just inside Gulpher Road also make turning into the road dangerous.
6. Through traffic in Treetops would not only increase the traffic but also make the road more dangerous especially at the top end where there are two sharp bends, one to the left and another to the right within a few yards of one another.
SCDC Response: 22, 26
HOUSING DISTRIBUTION FELIXSTOWE/WALTON AND TRIMLEY VILLAGES
Respondent Name: Mr Brian Ranner [77] Submission Agent Respondent ID: 77 ID: 77 ID: SUBMISSION I object to the Core Strategy in its entirety as it affects Felixstowe, Walton and the Trimleys. Apart from a small number of affordable homes for local needs, the rest should be distributed across the Suffolk Coastal District to minimise infrastructure costs and maximise sustainability of smaller communities. Most villages in the District would welcome extra homes to keep villages alive.
SCDC Response: 4, 22
3 BACKGROUND
Respondent Name: mr charlie ballam [271] Submission Agent Respondent ID: 271 ID: 271 ID: SUBMISSION I challenge the requirement for this many houses in this area. Is it valid to use predictions assuming continual growth, logic tells me that at some point the demand will level off. Before sanctioning a huge increase in housing stock wait until the demand is proved.
SCDC Response: 3
LOCAL SERVICE CENTRES
Respondent Name: mr charlie ballam [271] Submission Agent Respondent ID: 271 ID: 271 ID: SUBMISSION Flexable village boundaries will mean more houses in areas where they needed.By carefully selecting these communities can be enhanced.
SCDC Response: 4
THE OVERALL STRATEGY
Respondent Name: mr charlie ballam [271] Submission Agent Respondent ID: 271 ID: 271 ID: SUBMISSION To place all the development in one or two 'new town' areas will spoil the surrounding villages. It does not help these villages it swallows them up and their atmosphere is ruined. Smaller develoments, in the right area will be of benefit to local environment.
SCDC Response: 4, 18
SMALL WINDFALL PROVISION - REDUCE PROVISION FROM THIS SOURCE
Respondent Name: mr charlie ballam [271] Submission Agent Respondent ID: 271 ID: 271 ID: SUBMISSION If there are small infill site to be taken up, surely use these first. Then see if you still have a numbers problem. There could easily be another credit crunch for examble that will prove your predicted figures to be wrong. Do not try to fix the problem before it arrives. If you still need more homes then allow some building around villages, just outside the current various village envelopes.
SCDC Response: 3, 4
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: mr charlie ballam [271] Submission Agent Respondent ID: 271 ID: 271 ID: SUBMISSION It just seems to ridiculous that BT can drive this whole process. They have some land and want to make a bit of money. Lets build a whole new town on it! However they want more so they use the argument the town will not be viable, OK so lets build a bigger town. This is just an easy solution for the planners. We all know this corner of Suffolk is overcrowded now and no amount of 'careful management' will reduce the load on the infrastructure.
SCDC Response: 16, 20
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: mr charlie ballam [271] Submission Agent Respondent ID: 271 ID: 271 ID: SUBMISSION As stated in 5.17 'no one site provided the perfect solution' - then surely this means that the 'standalone town' is the wrong approach. The majority of people have to drive some distance to their employment, this 'new town' will put an intollerable strain on the transport network. Much better with the peperpot method of development dispersal, this way people will have a chance to live nearer their employment. I know this will be more work for planners but why not get it right rather than go with the imperfect solution?
SCDC Response: 4, 7, 16
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT?
Respondent Name: mr charlie ballam [271] Submission Agent Respondent ID: 271 ID: 271 ID: SUBMISSION As with my previous comment, by putting all the houses in one place we create many problems, by spreading the same number of houses around lots of villages we will benefit the smaller villages by making them more viable. For example schools which have dwindling numbers might close but with smaller developments these same schools will be more viable. Another example would be shops. This then will mean less bussing of children and less driving to superstores miles away.
SCDC Response: 4
3 BACKGROUND
Respondent Name: mr charlie ballam [271] Submission Agent Respondent ID: 271 ID: 271 ID: SUBMISSION I seriously doubt the figures that predict these high numbers of homes will be required. There has to be a finite limit, we just cannot go on building more and concreting more. A new town on this scale will not be needed and smaller infilling will be less impact on the countyside and more beneficial for the smaller villages around this area.
SCDC Response: 3
IPSWICH POLICY AREA
Respondent Name: Mr Christopher Allen [48] Submission Agent Respondent ID: 48 ID: 48 ID: SUBMISSION I strongly objection to a secondary school being considered for Old Martlesham. Main Road traffic already exceeds pre-bypass levels and Martlesham Roundabout access is already problematic. Old Martlesham already has to contend with Primary School and 'rat-run' traffic; adding extra traffic from this School would result in residents being trapped during school pick-up and let-down times. Also, it is inevitable that adjacent Common Land (and protected wildlife) would be 'damaged' during lunch breaks. Why should (predominantly older) Suffolk Coastal residents suffer to benefit a new (and unwanted) Ipswich Borough mini-town? Build the school there if it is needed!
SCDC Response: 11, 13, 17 Other comments noted
HOUSING DISTRIBUTION FELIXSTOWE/WALTON AND TRIMLEY VILLAGES
Respondent Name: Mr Christopher Goldsmith [390] Submission Agent Respondent ID: 390 ID: 390 ID: SUBMISSION Felixstowe is a town that has a thriving major employer (minimally impacted by the global recession), it can sustain significant housing growth and should aim to attract additional employers associated with the docks. As there are signs the global recession is now easing, it is not unreasoanble to assume growth (and therefore employment) at the port will start to grow and therefore Felixstowe should be a key target area for a significant proportion of the local growth i.e closer to 2000 of the proposed new homes as originally intended.
SCDC Response: 22, 24
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Christopher Goldsmith [390] Submission Agent Respondent ID: 390 ID: 390 ID: SUBMISSION Why if this is 'East of Ipswich' is it focused on Martlesham? the issues raised regarding other proposed areas equally apply to Martlesham Clogging up the A12 and overloading local services in Martlesham is not an accpetable proposal, housing should be distributed via pepper potting.
SCDC Response: 4, 13, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Christopher Goldsmith [390] Submission Agent Respondent ID: 390 ID: 390 ID: SUBMISSION Too larger developmnet for area Infrastrucutre cannot cope, transport, power, employment, doctors, schools.... Impact on surrounding countryside is unnaccetapble. Insufficient growth in local employment to support this number of new homes. smaller standalone community on BT proposed site would be more accpetable.
SCDC Response: 4, 7, 16, 17, 19, 20
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Mr Christopher Hann [132] Submission Agent Respondent ID: 132 ID: 132 ID: SUBMISSION I am objecting to the proposed new development on the land adjacent to adastral Park, Martlesham Heath. My objections are that I feel it is going to lead to increased traffic congestion, pollution, a drain on local resources such as schools, doctors, hospitals etc. It would be a great shame to built on green belt land which currently divides villages of Martlesham Heath and Waldringfield. Yet another huge housing development is going to spoil the countryside. I don't see why we need so many new houses as BT and other employers and cutting staff not recruiting staff.
SCDC Response: 3, 4, 7, 16, 17, 19, 20
Respondent Name: Mr Colin Archer Submission Agent Respondent ID: 384 ID: 384 ID: SUBMISSION Summary I strongly object to the increase in IPA housing numbers, which will make all the disastrous impacts of the proposed new town at Adastral Park even worse. This totally inappropriate development will urbanise a beautiful rural area and have an overwhelming impact on local communities, the road system and the environment. It is neither close to centres of employment, nor transport hubs has no local support and the whole aim seems to be to legitamise the revised housing allocations so that they dovetail completely with BT's planning application - a very bad case developer led planning strategy.
Section 1.02 "No decision will be taken in respect of individual sites submitted to the Council until the Core Strategy has been all but agreed". With the possible exception of very small scale, uncontroversial developments, no decisions should be taken until the Core Strategy has been fully adopted, i.e. has passed the independent examination stage. Sections 2.0, 4.01 & 8.02 "Comments are now sought solely in respect of these limited aspects of the Updated Preferred Option 7/09", "This consultation is therefore very focused" The public have not been given sufficient opportunity to use the new evidence (that has only been made available since the previous consultation, as listed in Appendix 1) to inform their comments on anything in the LDF other than these 'limited aspects'. Policies and strategies that were formulated before this evidence became available cannot be changed now that the evidence is available, and that there is no justification for denying the public the opportunity to comment on the broad strategy and policies in the light of evidence that has only appeared since the previous consultation. Section 3.05 "... not everyone will be happy with what is proposed" This is true! In fact there has been an almost unanimous rejection of the proposed strategy by people living in the affected areas of the IPA and the Colneis peninsular. For example, in the Preferred Options consultation an analysis of individual responses to SP3 (Strategic Policies, Ipswich) reveals that 2 respondents supported the policy and 86 objected to it. The implication of this argument is 'whatever we do, someone will be unhappy, so we can ignore public opinion'. This is simply not true - there are other strategies (e.g. dispersed housing across the whole district) that would almost certainly be less unpopular than the one proposed. Section 5.09 "The main concerns related to the area East of Ipswich and Felixstowe/Walton and the Trimley villages where the bulk of the new homes are proposed. It is essentially in response to these issues that the original housing distribution strategy is now proposed to be revised." The implication of this is that the updated housing distribution (i.e. an increase in the IPA allocation from 1,050 to 2,000 houses) is in response to the concerns of the public. In fact it is exactly the opposite of what the public said in response to the previous consultation, in which the overwhelming majority objected to the concentration of 1,050 houses in one place. Section 5.12 "... the broad scale and distribution of development has evolved and refined over time as a result of public consultation" The decision to concentrate the housing distribution in the IPA into one large site was taken in complete opposition to the results of public consultations. For example, the February 2007 Issues & Options consultation produced the following result: * Option 1 (1 large site): 14% * Option 2 (2 or 3 large sites): 51% * Option 3 (a number of small sites): 35% However, in the following consultation (February 2008, Further Issues & Options), one of the questions was "Is your preference for one area of growth only or for more than one?" ('more than one' presumably means up to 5). Option 3 was totally ignored, despite the fact that it got more than double the support for option 1. Where was the opportunity to choose a large number of small sites? No figures were provided for the answers to the quoted question, no mention was made of the responses to this question in the Task Group's discussion, and the many arguments presented by the public in this and later consultations, in favour of a distributed allocation have been consistently ignored. The final decision to go for one large site is easily the least popular. Section 5.17 "None of the five options considered offered a perfect solution" This is a gross understatement - they were all appalling. However, the need to decide between them could have been avoided if a distributed housing strategy had been chosen. As it was, the decision to go for Area 4 (East of the A12) was made by applying the criteria in a completely biased way, conjuring up non-existent 'advantages' and ignoring Area 4's many disadvantages. The 'advantages' are non-existent, and the choice of Area 4 is therefore fatally flawed. Section 5.19 "All of these options however were rejected in favour of a Preferred Option dispersed strategy of "organic and evolutionary growth". No explanation has ever been given for the inconsistency between this decision in Felixstowe and the opposite decision in the IPA. The well argued and valid points supporting distributed housing in Felixstowe (LDF Core Strategy Preferred Options, §3.45) apply equally to the IPA. Section 6 SCDC's responses to many of the public's comments are totally inadequate. Many important points have been lost in the summaries, and many of the responses fail to deal with the real issues.... Section 6.03 Felixstowe/Walton and Trimley Villages Comment 3: "The A14 is unable to cope now let alone with increased traffic from the new housing" Response: "The traffic studies which have been done indicate that the A14 even with the additional lorry traffic which will result from the port expansion will be able to cope with the housing numbers proposed". Assuming this refers to Suffolk Coastal District Council Local Development Framework Housing Allocations Proposed Strategy Transport Appraisal, Sept. 2009, this document is seriously flawed (see comments on Appendix 1). Even if these flaws are ignored, the document says: "It is expected that the impact at the A14/A12 junction will be significant, and therefore a mitigation scheme will be required to ensure this does not have a detrimental impact on the operation of the junction." (§7.7) A major bottleneck on the A14 is the Orwell Bridge. This is not considered in the Transport Appraisal, but it is in the EERA Newmarket to Felixstowe Corridor Study, which says: "Demand on the Orwell Bridge is forecast to increase in the future. The Highways Agency, in the A14 Girton to Felixstowe Congestion Study, forecast that the stress level on the Orwell Bridge will increase to 0.90 in 2009 and 0.98 in 2014. The Highways Agency East of England Transport Model indicates that, by 2021, daily traffic volumes may have reached 76,000, representing a stress level in the order of 1.12. In the morning peak period, the model forecasts an eastbound "demand" flow of over 4,400 pcus, compared to an "actual" flow of 3,400. This suggests that over 30% of the demand in the peak hour will not actually be able to flow through the link because of congestion." (§4.18). "When the CRF (Congestion Reference Flow) is reached (i.e. a stress level of 1.0), hourly traffic demand is likely to exceed the maximum hourly throughput of the link, with the result that traffic flow breaks down with speeds varying considerably, average speed drops significantly, and the sustainable throughput is reduced and queues are likely to form." (§4.17)
The problems described above do not take account of the extra traffic due to the proposed 2,000 and 1,000 houses in the IPA and the Felixstowe area respectively, or the possible port expansion. Ipswich Policy Area - East of A12 Comment 1: "The numbers of houses currently proposed is too great." Response: "To reduce the numbers would mean not meeting RSS requirements as well as resulting in a development which was little more than an overgrown housing estate" The numbers could easily be reduced by re-assigning some of the allocation to the rest of the district (where there is a large identified need for affordable housing), thus keeping the total the same. Dispersal of the allocation over many sites would not result in an 'overgrown housing estate'.
Comment 2: "1,000 is insufficient to provide a standalone Community" Response: No mention is made of the rather telling fact that only one respondent made this comment - David Lock, on behalf of BT, the owners of the land in question. The many comments questioning the need for a new standalone community have been ignored.
SCDC's support for this position is in stark contrast to the arguments previously used to justify a single site of 1,050 houses, which apparently was needed to create a sustainable community. No mention had been made previously that 1,050 would not be enough. No explanation has been given as to why 1,050 houses were considered sufficient to create a sustainable community in 2008 but now 2,000 are needed. Did the planning officers get their sums wrong (by a factor of 2)?
Response: "A larger allocation provides the basis for a significantly improved range of community facilities" This is a self-justifying, circular argument: 2,000 houses are needed to justify providing the facilities, but the only reason the facilities are needed is to service the 2,000 houses! According to the RSS, a genuine need only exists for 1,050 houses - if this number were built, and they were dispersed over the IPA or better still throughout the rest of Suffolk Coastal, the need for new facilities and infrastructure would be far less (and the cost to the taxpayer less).
Response: "The evidence suggests that the benefits do indeed outweigh the disbenefits." (Disbenefit is presumably a new jargon word being used to make it sound less harmful.) No justification is given for this conclusion. What evidence? What supposed benefits? No evidence of genuine benefits has been provided, but there are many disbenefits: * Urbanisation of a rural area * Destruction of local communities * Impact of additional traffic on the roads * Damage to environmentally sensitive areas nearby, and the wildlife they protect * Increase in pollution and greenhouse gases * And many more....
Comment 3: "Adverse impact on existing communities at Martlesham, Martlesham Heath and Waldringfield" Response: "... but which triggers the need for additional infrastructure, particularly secondary education ..." Even 2,000 houses are insufficient to trigger the provision of a new secondary school (according to Future Secondary School Provision Alternative sites Assessment IPA, "Demand for one new secondary school would normally be required for 5,000 new homes" (§3.2.3)) Even taking into account the existing shortfall, a new school will not be justified (see comments on Appendix 1).
Response: "It also offers the opportunity to better mitigate the potential impact of visitors and residents on the neighbouring countryside and estuary ..." It is perverse and illogical to argue that more houses will have a lesser impact, even with 'mitigation'.
Response: "The lie of the land in the proposed area, coupled with the fact that much of the land involved either has been or is scheduled to be used for mineral extraction, is such that the degree of the disbenefit from damage to the landscape, loss of agricultural land and the like from the increased size of this allocation is limited, ..." (The disbenefit word again!) This ignores the fact that the mineral extraction is a temporary situation, with planning permission conditional on the land being returned to its original state when the extraction has finished. Building in this location actually means the loss of agricultural land, or more accurately lowland heathland, which it was within living memory (pre-1960s for most of it). Lowland heathland is a scarce habitat which should be conserved and re-created: "In areas that support lowland heathland, there should be a presumption in favour of re-establishing heathland on derelict land or land that has been used for mineral extraction." (UK Biodiversity Action Plan). Comment 4: "Unacceptable impact on the neighbouring wildlife and countryside" Response: "Development on this scale must be undertaken as part of a comprehensive development which places significant emphasis on mitigating these potential impacts." 'Mitigation' is a word that is grossly overused in this document. Doing the wrong thing, then insisting that mitigation is put in place to lessen the impact is not a sensible strategy. No amount of 'mitigation' will be able to undo the damage created by such an enormous and inappropriate development. This damage will be made far worse by doubling the number of houses. Twice the number of houses means twice the number of people, dogs, cats, cars, boats, etc, as well as twice the amount of noise, light pollution, car exhaust pollution, sewerage waste, water consumption, etc., and therefore twice the amount of impact on the neighbouring wildlife and countryside. The response that the impact on the neighbouring wildlife and countryside can be overcome is contradicted by SCDC's own Appropriate Assessment: "Any development is likely to bring additional pressure to any of the sites of European interest, however the area near Martlesham identified as a "preferred option" could have particularly negative impacts upon the Deben Estuary SPA/SSSI" (SCDC Core Strategy Appropriate Assessment, Appendix 4) An extension to the sewerage treatment works at Martlesham is admitted as necessary and this is even closer to the RAMSAR and SPA/SSSI.
Comment 5: "Unacceptable Impact on the primary and local road network" Response: "However the impact of 2,000 homes as opposed to 1,000 on individual junctions etc when linked to new and improved transport infrastructure is limited but will help to secure the necessary developer funding to secure these upgrades to a good standard" How can the impact of 2,000 homes as opposed to 1,000 be 'limited'? 2,000 homes will have roughly double the impact of 1,000 homes: twice the number of car journeys and twice as much traffic congestion. This is confirmed by comparing the figures in the two Transport Appraisals (Aug 2008 and Sept 2009): person trips per hour for the total dwelling allocation are 1087 (970 houses) and 2240 (2,000 houses) - an increase of 106%. (Aug 2008: Table 8, Car Driver, Total Trips figures: 555 (am) + 532 (pm) = 1087. Sept 2009: Table 3.2, Scenario1, Car Driver, Total Trips figures 1143 (am) + 1097 (pm) = 2240) (see comments on Appendix 1). In either case, upgrades to road junctions, etc would presumably be proportionate to the increase in traffic. Surely developer funding to 'secure these upgrades to a good standard' can be demanded no matter how many houses are proposed. A dispersed housing policy would avoid having to do any major upgrades, because the traffic impact would be much more diluted. The argument that securing developer funding to pay for changes that are only needed because of the new housing, is (as with the general point about infrastructure) a self-justifying, circular argument. They will not pay for another Orwell Bridge or Northern by-pass. If this new town were not built, the developer funding to widen roads, etc would not be needed. The Transport Appraisal says: "The combined impact of the allocations to the east of Ipswich and the Market Towns will have a considerable impact on this difficult junction [the A12/ A1214 Junction]." (§7.5.2) and: "the impact on the local road network, in particular the A12, is unavoidable and considerable improvement would be required at a number of A12 junctions to preserve existing service levels" (§4.5.1). Both these quotes support Comment 5. Conclusion: "Consideration should be given to an alternative housing distribution" Response: The response to this comment fails to address the issue; it is simply a repetition of responses to comments 1-6, and suffers from the same failings. An 'alternative housing distribution' means distributing the houses over several (or even better, many) small sites, instead of one large site. It doesn't mean having to find another large site capable of accommodating 2,000 houses, which is the implication of the sentence: "The area has lower negative impacts on landscape quality and public amenity overall than other potential alternatives" Section 7.01 "Allocations are expressed as minimum figures consistent with the approach of the Regional Spatial Strategy - The East of England Plan". Although the East of England Plan figures are indeed minima, this only means that SCDC is free to exceed them in the LDF if it wishes. If the LDF figures could be treated as minima, it would make a farce of the whole enterprise of strategic planning - nobody would know even approximately how many houses will actually be built! The figures provided in the LDF are not minima, they are the actual numbers that SCDC's strategy requires to be built. There is no justification for specifying the LDF figures as minima, to be exceeded by developers if they so wish.
The comment of GO-East on SP18 is "We suggest that the allocations are expressed as a range rather than a specific number to ensure the policy is sufficiently flexible", which at least has the merit of specifying the limits to the housing numbers. It also implies that GO-East view the 'specific number' as an actual figure, not a minimum, because they see it as being not sufficiently flexible, whereas if it were a minimum, it would be infinitely flexible. Section 7.02 "The location for such a community remains at Martlesham although the location is specified as to south and east of Adastral Park" This is a much more precisely specified location than in the previous version of the LDF, which says: "The area of search for housing sites will extend in a "half collar" around the employment area at Martlesham Heath, including BT at Adastral Park. Opportunities for sites include within Martlesham village, on the old Felixstowe Road, the sand quarries east of Adastral Park and the farmland north of Waldringfield Road." (LDF Core Strategy, Preferred Options, §3.21) No reason has been given for narrowing the 'area of search' to the south and east of Adastral Park. In fact the opposite has happened - the advantage of a wider search area previously given has been removed: "There is also the ability to separate the area into distinct sections, thereby giving the opportunity to phase the development and also not to rely on one landowner" (Future Location Of Strategic Housing Growth In The Ipswich Policy Area, §4.3) [our emphasis]. There is only one landowner in the location to the 'south and east of Adastral Park': BT.
It is therefore difficult to avoid the conclusion that the LDF Core Strategy is being written to dovetail precisely with BT's planning application, C09/0555. (The new housing number, 2,000, is also exactly the number in the BT planning application). Instead of plan-led development, we now seem to have a BT-led planning strategy!
"Allocations at Key Service Centres to meet local needs and affordable housing provision" This allocation falls far short of meeting the need for affordable housing in rural areas, which is currently running at 2,722 homes per year in Suffolk (Delivering affordable housing in rural Suffolk, Ian Tippett Babergh's Strategic Housing Manager, 9 October 2009). Section 7.03 "An allocation of 2,000 new homes be made at Martlesham". There is no justification for doubling the allocation. There is no identified need for the extra 950 houses. All the problems created by a 1,050 house development will be made much worse by a 2,000 house development.
"... integrate the development into the remainder of the Martlesham community, ..." It is difficult to see how this new development will be integrated into the Martlesham community when it is divided from Martlesham Heath by the A12 and several BT office buildings and car parks, and from Old Martlesham by the Martlesham Heath Business and Retail Park.
There seems to be confusion over whether the new community will be integrated or self contained. The quote above suggests the former, whereas "It is of sufficient size to provide a relatively self contained community" (§6.03, IPA Comment 1) and "the opportunity to provide for a more self contained development" (§6.03, IPA Comment 3) suggest the latter. Is it intended to be integrated or self- contained? Section 7.06 "The target will be 330 new homes overall of which 1 in 3 will be affordable ones". Why is this target only mentioned for Key Service Centres? It should apply to all the areas: "There is a need for affordable housing across the district" (LDF Core Strategy, Preferred Options, §7.06) We wouldn't be so cynical as to suggest that the reason there is no mention of this target for the IPA is that BT doesn't want to have their profits reduced by having to provide 1 in 3 affordable homes, and that SCDC are acquiescing in this. The target of 1 in 3 affordable homes should be clearly stated as applying to the whole of the district, including the IPA. Section 8.02 "... the broad strategy that you have already commented, and which has achieved a large measure of agreement ...". The broad strategy hasn't achieved anything like a 'large measure of agreement'. The only 'large measure of agreement' that has been achieved is that it has been almost universally opposed by local residents in the IPA and Felixstowe. Appendix 1 Suffolk Coastal District Council Local Development Framework Housing Allocations - Proposed Strategy Transport Appraisal - September 2009 It is admitted that: "... much of the analysis has been qualitative and partial ..." (§8.7), and that there were many restrictions to the study method: * no new survey work * no new transport network modelling * no consultation * no iteration or optimization * no detailed traffic data available * a large range of uncertainties * calculations largely based on 2001 census data (i.e. 8 years old) (§1.3)
Yet despite all these problems, "no over-riding concerns have been identified" (§8.7) The Transport Appraisal may have failed to identify any over-riding concerns, but that is a failing of the document rather than because there are no causes for concern....
The Transport Appraisal misses out several major impacts on the road system: * the Orwell bridge (see comments on §6.03, Felixstowe/Walton and Trimley Villages Comment 3) * the A12/Barrack Square roundabout. Why was this omitted? It is the central junction into Martlesham Heath and onto the A12 from the proposed site, and is likely to take a large proportion of the traffic. * the road into Waldringfield. This is often congested. It is single track in places, with no pavements or street lighting. The residents of the proposed new town are very likely to visit the attractions of Waldringfield, which has the only beach on the river Deben between Woodbridge and Felixstowe Ferry, a popular riverside pub, the river itself with its boating possibilities, and many attractive footpaths along the Deben Estuary mud flats and surrounding countryside. The road cannot be widened, so it is inevitable that congestion will increase further with 4,800 people living 1.5 km up the road. * the use of Newbourne Road (from the Waldringfield Heath crossroads to the Red Lion at Martlesham) as a rat-run to avoid congestion on the A12. This is already happening, but with the extra traffic and the introduction of traffic lights on the A12 (with consequent delays), it will inevitably get much worse.
There doesn't seem to be anywhere in the Transport Appraisal that says what assumption is being made about the percentage of working householders who will have jobs at Adastral Park. (This is important because the lower this percentage is, the more commuting will occur). It does say: "Scenario 1, which accommodates 2,000 houses on Site 4, directly adjacent to a key employment area, would put employment opportunities and homes together and make travel to work by non car means a more realistic option." (§4.5.1). Also: "the sites proximity to Adastral Park allowing more trips to work to be made by other modes" (§3.2). Both of these statements ignore the evidence... The evidence strongly suggests that the people who will live in the houses will be a completely different group from those employed in the area. Currently, only 3% of the employees at Adastral Park live within 1 mile of their work (according to the BT Planning Application C09/0555, Travel Plan, §5.11), and, since this is not due to a shortage of housing in the area, this percentage is unlikely to increase significantly with the new housing. It is therefore likely that at least 97% of the working residents of the new housing estate will work further afield. Adastral Park is a long way from the major sources of employment in Ipswich Town Centre and Ransomes Europark, with poor public transport links to the former and none to the latter. Trends in home working will make it even more likely that the future employees at Adastral Park will not live nearby. BT has also recently declared that their workforce is being reduced not increased, and in fact some businesses are currently pulling out of the area. Previous employees who have been subject to redundancy have either managed to obtain jobs elsewhere e.g. London or Cambridge or in fact remain unable to find a new job. Many of these unemployed do not show in registered unemployed figures as they are been forced to take their pensions early in order to survive. New businesses will be welcomed to the area however there seems an excess of business space available and many prospective employees already here. Where will these new householders work? Presumably they will commute off site.
The 5 scenarios used in the Updated Transport Appraisal do not make sense. All 5 scenarios consider the impact of 2,000 houses in the IPA (Table 2.3). So there is no straightforward way to answer the question "what is the impact of 2,000 houses at Adastral Park, compared with 1,050?" Scenarios 2-5 are totally unrealistic - SCDC's argument for 2,000 houses is that they all need to be in the same place (to "provide the basis for a significantly improved range of community facilities"). If 1,050 are located at Adastral Park what possible reason would there be to add an extra 950 to one of the other sites? These scenarios (2-5) are not mentioned anywhere else in the LDF documents, or in any of the other evidence documents.
Estimated peak hour person trip generation for proposed allocations East of Ipswich give a minimum of 2240 trips per day (this assumes the rush hour peaks last an hour each, and there is no extra traffic during the rest of the day, so it is obviously an underestimate). This is an increase of 106% compared with the corresponding figure for 970 houses (see table below) - more than double. (Why was 970 used rather than the actual housing proposal of 1,050?)
Person Trip Generation for Site 4 (East of Ipswich) (person trips per hour for the total dwelling allocation) AM PM Total 970 houses in Site 4 (Aug 2008, Table 8) 555 532 1087 2,000 houses in Site 4 (Sept 2009, Table 3.2, Scenario 1) 1143 1097 2240 Nowhere in this document is road safety mentioned. The important question: 'how will the increase in housing numbers affect the frequency and seriousness of road accidents?' is not asked, let alone answered. Future Secondary School Provision: Alternative Sites Assessment Ipswich Policy Area "Demand for one new secondary school would normally be required for 5,000 new homes. However, given existing shortfalls in the area, this figure has been discounted by 1,500 homes. In addition, the potential development of Adastral Park would lead to approximately 2,000 new homes." (§3.2.3) How is the figure of 1,500 for existing shortfalls arrived at? It certainly does not agree with the figures given in §3.2.2: Even if the shortfall is 1,500 homes, added to 2,000 new homes this would still only give 3,500 homes, 1,500 less than the 5,000 the report states are needed to justify a new secondary school. And even if 2,000 houses + the shortfall were sufficient for a new school, the full 2,000 will not be provided until 2025, so we will have 15 years before the new school is justified. Where will the secondary age pupils living in the proposed new town be educated in the meantime? "Development on any of the alternative sites could potentially lead to an adverse impact on the landscape and loss of biodiversity." (§4.2.5) We strongly agree with this statement. The obvious conclusion is that they should not be developed. "Environmental and other constraints at Adastral Park and Site 6 are considered to be surmountable with appropriate mitigation measures, including landscaping." (4.2.9) See the earlier comments on mitigation. Doing the wrong thing, then insisting that mitigation is put in place to lessen the impact is not a sensible strategy. "there is a risk that the Adastral Park development will create a community which is considered separate from the existing neighbourhoods of Martlesham and Martlesham Heath" (§4.2.32) There certainly is this risk, which is another reason for not developing it. This is already the fate of Martlesham and Martlesham Heath despite many attempts to try and unite the communities over many years. Sustainability Appraisal "The sustainability of the new policy is higher than the previous version ... Concentrating development in the IPA is considered a more sustainable strategy" (§2.2) 3 reasons are given to justify this conclusion: "i) The employment offer in Ipswich is larger and more diverse than elsewhere in the District..." But the proposed site at Adastral Park is the furthest of the original 5 options from Ipswich, and has poor public transport services to the main centres of employment in Ipswich Town Centre and Ransomes Europark. "ii) There is the opportunity to create sustainable settlement(s) with distinctive identity with smaller readily distinguishable villages, neighbourhoods and communities within the larger area." There is no reason to believe (and no evidence supplied) that the one large settlement proposed will be any more sustainable than several smaller settlements. Why does this argument not hold in Felixstowe, where the choice was to disperse the housing? How do the current proposals promote "smaller readily distinguishable villages, neighbourhoods and communities within the larger area"? We already have these - the building of a 2,000 house new town will overwhelm several of them, making them less 'readily distinguishable'. "iii)Public transport provision and foot and cycle paths can be upgraded and promoted to minimise the need to use private motor vehicles with the major service centre of Ipswich nearby." This could and should be done anyway. It is unlikely that many people will switch from driving to cycling into Ipswich town centre, which is 7 miles away. Even if the promotion of public transport and cycling is successful, there will still be many more car journeys resulting from a 2,000 house development than a 1,050 one (more than double in fact - see comments on Transport Appraisal).
"The new policy is marginally less sustainable due to additions of land abutting Adas
SCDC Response: 1, 4, 7, 8, 10, 11, 12, 13, 15, 16, 17, 18, 19 See policies DM1 and DM2 regarding affordable housing
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Colin Davies [163] Submission Agent Respondent ID: 163 ID: 163 ID: SUBMISSION I am writing to object to the proposed development of land adjacent to BT. This will completely change the local environment which currently is a succesful combination of housing and a rural outlook. In addition the local infrastructure already struggles to cope at peak times and this situation will be exacerbated by the new development by BT. Even after taking into account the proposed changes to the infrastructure the advserse effects on the existing residents of Martlesham Heath will be immense.
SCDC Response: 4, 16, 17, 18, 20
8 YOUR COMMENTS
Respondent Name: Mr Cyril Saunders [357] Submission Agent Respondent ID: 357 ID: 357 ID: SUBMISSION 2000 new houses! Oh dear! Is it worth writing this as I feel that this is a done deal (like Police HQ). However my objections are as follows: 2000 new houses = 3000 people at a guess. Where are the new residents coming from and where will they work? Who will pay for sewers/roads/electricity & gas? Roads - how many? Schools, shops, bus service and then there is the hospital already catering for too many people - extra police - I could go on but just as another thought - would this not kill off Woodbridge as a very nice town! No doubt most of the above questions have already been raised, and I hope that some person somewhere says 'NO' to this foolish 'NEW TOWN' to be built on Gree Fields. Yours not very hopefully, CM Saunders
SCDC Response: 16, 20
APPENDIX 4 - BREAKDOWN OF UPDATED DISTRIBUTION STRATEGY
Respondent Name: Mr Dave Green [145] Submission Agent Respondent ID: 145 ID: 145 ID: SUBMISSION As previous representations, 2000 houses has a step change impact on the existing infrastructure and communities. 420 students is too many for existing schools but not enough for a new High School. Existing road infrastructure has to be changed significantly (lights on the A12 instead of the roundabouts), more traffic down the windy Foxhall Road and will be an overall disbenefit to existing communities due to congestion and increased road noise. Pressure on the AONB will be significant. Better to distribute the housing developments more evenly ('pepper potting').
SCDC Response: 4, 17, 19, 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Dave Green [145] Submission Agent Respondent ID: 145 ID: 145 ID: SUBMISSION Fact - Kesgrave High School is full NOW (please consult with the Head teacher Mr Burgoyne - he has NOT been properly consulted). Same for Farlingaye. 420 students is not enough for a new High School but far too many to try to squeeze into the 2 existing high schools. 200 might just be accommodated (1000 houses).
SCDC Response: Noted
IPSWICH POLICY AREA
Respondent Name: Mr Dave Green [145] Submission Agent Respondent ID: 145 ID: 145 ID: SUBMISSION As previous representations, 1000 houses is probably acceptable in terms of small impact on existing infrastructure (2 high schools, road infrastructure and impact on AONB). An increase to 2000 (with potential for many more in the plans) is a step increase in the impact on the local communities around and demands big changes to existing infrastructure, On secondary education, 2000 houses is too many new students for existing schools but not big enough for a new secondary school. Far better to share the load around the whole East of Ipswich area.
SCDC Response: 4, 18, 20
THE OVERALL STRATEGY
Respondent Name: Mr Dave Green [145] Submission Agent Respondent ID: 145 ID: 145 ID: SUBMISSION As previous representations, I object to the strategy on the basis that is goes against your own overall principles in the Settlement Hierarchy (e.g. 5.06 and 5.10). An increase from 1000 to 2000 (and potentially more in the plans I have seen) will have a huge impact on existing infrastructure and destroy the existing community and rural feel to the whole area. 1000 house would be accommodated with existing infrastructure (including secondary schools and existing roundabout layout) and not impinge too much on the environment and nearby AONB. 'Pepper potting' strategy is my preferred solution to the overall housing need.
SCDC Response: 4, 16, 17, 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Dave Green [145] Submission Agent Respondent ID: 145 ID: 145 ID: SUBMISSION I disagree with the logic of the council response to 3. Demand for secondary education will be about 420 students - not enough for a new school but an intolerable (impossible?) load on Kesgrave and Farlingaye High Schools. How a huge single development mitigates impact on the environment/AONB is beyond me - the best way is to spread the houses more thinly around the whole area ('pepper potting'). We are already well served for public transport - funding for new will just increase congestion and overall there will be a DISbenefit in this are for Martlsham residents due to congestion.
SCDC Response: 4, 13, 17, 19
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Dave Green [145] Submission Agent Respondent ID: 145 ID: 145 ID: SUBMISSION As commented in paras above, my main objection is that putting a significantly larger number of houses actually contradicts your overall strategy and policy on new housing development. I could accept 1000 as having a manageable impact on existing infrastructure (roads, transport, environment including AONB and secondary schools) but 2000 (and potentially many more) goes over the line and will have a HUGE impact on these. It may have least impact on other communities in the area but not Martlesham!
SCDC Response: 4, 17, 20
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mr Dave Green [145] Submission Agent Respondent ID: 145 ID: 145 ID: SUBMISSION I support the general thrust of the housing strategy in paras 5.09 and 5.10. That public transport and road should support new housing - 2000 houses won't and will introduce a huge impact on the infrastructure. Same for 'respect for the character of existing communities and quality of the local environment'. The increase to 2000 (and potentially more) will have a HUGE impact on these. The new 2000 house proposal goes against the strategies & policies!
SCDC Response: 17, 18, 20
STEP 1-THE SETTLEMENT HIERARCHY
Respondent Name: Mr Dave Green [145] Submission Agent Respondent ID: 145 ID: 145 ID: SUBMISSION 5.06 states that 'in relation to housing most new development is to be directed towards major centres and market towns with VERY much smaller scale development at the Key and Local Service Centres'. Martlesham Heath is NOT a major centre centre or market town!
SCDC Response: 4 Other comments noted
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr David Beaumont [209] Submission Agent Respondent ID: 209 ID: 209 ID: SUBMISSION Considering...Suffolk Coastal District Council Local Development Framework Housing Allocations - Proposed Strategy Transport Appraisal - September 2009 : Addendum Rev.3
The credibility of this report as "evidence" is brought into question by the omission of a major road junction in all the traffic flow diagrams.
Figures 1-28 showing "traffic flow" topology seem to omit a major junction between G and H.
The missing junction just happens to serve the main entrances to BT Adastral Park and Martlesham Village, a known congestion point and one that will be greatly exacerbated with the LDF proposed developments for that and the surrounding areas.
Both the report and the addendum do not take into account the need for "free flow" of emergency traffic e.g. ambulances, fire services and police.
This requirement is especially important to the Police with their Suffolk HQ located near junction G.
"Free flow" of traffic is also becoming extremely important now that Regional Health Authorities have INSISTED that emergency heart patients in Suffolk have to travel to Cambridge, Essex or Norwich instead of a facility at Ipswich.
The report only speculates on traffic flow and doesn't consider the size of vehicles (i.e. a flow unit could be a moped or a container lorry) consequently the study has little bearing on resulting traffic congestion caused by any new development of 2000+ homes near Adastral Park.
This flaw should have been identified when plans were drawn up for a traffic light control at junction G. As in reality, junction G regularly becomes congested when a container lorry has to stop ON the roundabout and thus stops any vehicles coming off the roundabout heading into Ipswich on the A1214 (until the lights change again).
SCDC Response: 13, 13
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr David Beaumont [209] Submission Agent Respondent ID: 209 ID: 209 ID: SUBMISSION Considering... Suffolk Coastal District Council Local Development Framework Housing Allocations - Proposed Strategy Transport Appraisal - September 2009
The validity of this report is FLAWED.
By the report's own admission the findings are based on 9 year old data, no new modelling, and a "large range of uncertainties" and yet it then goes on to state that the findings are "robust".
This is a JOKE.
In the last 9 years Kegrave and Purdis Farm developments have expanded to completion and added greatly to the traffic flows on adjoining and neighbouring roads, causing heavy congestion.
Is this the same modelling system that has been discredited in reality by the aborted traffic controlled junction at A1214/Ropes Drive (Kesgrave)?
It has clearly been designed to support SCDC's "preferred option" as it discredits the use on Site 5 (land north A14 and west of A12) as unsuitable for a site for 1050 new homes due to its lack of amenities.
The same could be said of the land near Adastral Park, PART (not the whole) of Site 4. Both sites, if developed, offer easy access via sustainable transport links to local employment centres of Adastral Park and Ransomes Europark respectively.
The main difference between the two sites is that Site 5 has easy access to both A12 and A14 as well as access via the under utilised Felixstowe Road, whereas Adastral Park only has access to the regularly congested A12.
Furthermore, the development of Site 5, instead of the Adastral Park part of Site 4, may well ease congestion on the A12 at Martlesham.
SCDC Response: 10, 13
THE MARKET TOWNS
Respondent Name: Mr David Beaumont [209] Submission Agent Respondent ID: 209 ID: 209 ID: SUBMISSION The LDF update infers that new homes should be provided in the Leiston area during Phase 3. Considering that it is highly probable (backed by Government) that Sizewell "C" will built as soon as possible then surely the housing will be needed in Phase 1.
Construction of Sizewell "C" will increase "heavy load" traffic on the A12 and increase the likelyhood of regular congestion at highway "pinch points", like the A12 at Martlesham, early in the LDF scoped timeline (2012+).
Any modification of the A12 at Martlesham during this period will be intolerable to local residents and road users.
SCDC Response: 4, 13, 14
6 THE COUNCIL'S RESPONSE & REASONS FOR PROPOSED CHANGES TO HOUSING DISTRIBUTION
Respondent Name: Mr David Beaumont [209] Submission Agent Respondent ID: 209 ID: 209 ID: SUBMISSION The current financial downturn has affected all industries.
SCDC reasons the Port of Felixstowe growth is declining so fewer houses are needed in the area.
From July 2009 BT Adastral Park Martlesham has reduced its research staff from over 900 in year 2000 to about 150 today.
Recently UCL left Adastral Park and graduate recruitment has stopped. BT is contracting at Adastral Park and proposing a "science park" with partner companies. If BT leaves it is likely those companies will leave.
It is illogical for SCDC to propose 2000+ new homes near Adastral Park when staff numbers are reducing.
SCDC got its preferred option wrong at the start and continues to "pluck at straws" to justify its decision. It has consistently flouted informed local opinion in the Martlesham and Waldringfield areas.
These communities have never opposed "organic and evolutionary" housing growth and have welcomed sympathetic industrial expansion and repurposing of Adastral Park. Yet SCDC continues to ignore it own historically well founded planning principles, of no major housing development east of the A12.
SCDC makes great store of the doctrine of "sustainability", this being a fundamental requirement by the EU and yet it is unproven that everyone working at Adastral Park will live and stay within the new housing and recreational development and not add to the local traffic congestion.
Surely it would be more "sustainable" if SCDC insisted within the LDF that any new development of Adastral Park should, by design, be sustainable and almost self sufficient in energy and other resource usage.
It would make more sense for Adastral Park's expansion plans to incorporate generation of its own energy and waste disposal needs rather than placing a burden on the existing neighbouring communities.
BT is proudly boasting its "green credentials" by building "wind farms" to provide its energy needs where ever possible but this has not been proposed for Adastral Park. This idea would make perfect environmental sense as wind farms are low impact on the surrounding land (e.g. AONB, SSSI, etc.), are temporary (unlike permanent housing) and allow for existing uses (recreation and farming) to coexist.
SCDC Response: 4, 7, 24 See also DM24 Sustainable construction
5 HOW HAS THE HOUSING DISTRIBUTION BEEN DRAWN UP? AND HOW AND WHY HAS IT CHANGED?
Respondent Name: Mr David Beaumont [209] Submission Agent Respondent ID: 209 ID: 209 ID: SUBMISSION In 5.18 an independent study (David Lock) proposed a distribution of 1660 new homes but it was rejected by public demand who wanted "organic and evolutionary growth" instead.
A similar sentiment for "organic growth" was demanded by Martlesham and surrounding villages but this was ignored by SCDC.
In 5.17 there is NO mention of an independent study being commissioned for the Martlesham area yet it shoulders the burden of 2000+ new homes.
Was SCDC afraid of an independent review or did it think it didn't need one as BT had an outstanding planning application provided by David Lock?
SCDC Response: 15
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr David Beaumont [209] Submission Agent Respondent ID: 209 ID: 209 ID: SUBMISSION Ipswich Eastern Fringe - Telecommunications
Considering Telecommunications the SCDC states that existing facilities are adequate. This is a FALSE premise as the nearest ADSL exchange (Kesgrave) is near to capacity and the distance to the proposed new housing is greater than desirable in order to provide the government's target Broadband Access Speed of 2 Mbit/s for all users by 2012.
Currently Martlesham Heath, which is nearer to the exchange than the proposed new housing development, can only obtain ADSL broadband access speeds of up to 1Mbit/s, usually much lower.
SCDC Response: Noted.
1 INTRODUCTION
Respondent Name: Mr David Beaumont [209] Submission Agent Respondent ID: 209 ID: 209 ID: SUBMISSION The LDF draft includes much conflicting, misleading and missing detail. Vague LDF policy statements (see 5.10) like "New housing should...respect and maintain the character of individual settlements and communities" are contradicted by proposing a 2000+ house development right next to existing smaller communities of Martlesham Heath, Waldringfield and Brightwell. Any new infrastructure requirements will mean sacrifices by the existing communities of land, increased traffic stress, increased noise, air and light pollution. Is this what SDCD means by low or no impact on existing communities? SCDC has confused the public on what should and should not be considered.
SCDC states that the public consultees should only consider the LDF and not any outstanding planning applications. Yet at recent SCDC 'drop in' roadshows outlining the LDF proposals to the local public, details of the BT planning application were on view and offered as an example of proposed housing and the A12 road modifications.
The whole process has been confusing to the public and as a consequence the consultation results may be "skewed" by SCDC ignoring any comments on the LDF that are related to BT's planning application.
There are statements in the document where assumptions seem to be made to support the SCDC's argument for its proposal without evidence to back up the assumptions. One such example, in 3.02(2), states that "young people are leaving home earlier" when the media have been reporting that the current social trend is that dependants stay in or return to their family home because of the expense of living on their own. This trend rather than requiring more homes actually means that it is more likely existing homes have to accommodate more cars and traffic flow is increased in the existing communities.
SCDC Response: 1, 19
1 INTRODUCTION
Respondent Name: Mr David Beaumont [209] Submission Agent Respondent ID: 209 ID: 209 ID: SUBMISSION Comments made in my previous response (Feb 2009) to LDF Preferred Option, when considering the development of 1000+ new houses on agricultural land south and east of Adastral Park (Martlesham), still haven't been addressed by the SCDC's new LDF update. In fact my criticisms are even more relevant and the problems and issues even more severe with the SCDC's proposal to increase the development to 2000+ houses. When did Site 4, which would have absorbed 1000+ houses in an "organic and evolutionary" manner acceptable to the local communities, get condensed into the fields abutting Adastral Park? When BT asked!!!
To reiterate my original response to the last public consultation (Feb2009) see below:-
SP2 - Settlement Policy New Housing 1) I object to the Council's Preferred Option site 633 & 693 (originally referred to by the Council as "Site 4") for a large single housing development (i.e. 1000+ houses) east of the A12 adjacent to the already established industrial area of Martlesham Heath.
Reasons: a) Whilst I support BT's repurposing of Adastral Park site 644 for affiliated business employment I do not agree with the co-siting of a large housing development. The justification is questionable as: i) BT staffing levels are contracting and even though 4000 staff may be registered on site, large numbers are transitory, many are teleworkers working from home or work away from site. The concept of workers living near their work environment is counter to 21st century thinking in the "hi tech" community, a concept that BT actively promotes. ii) A large number of BT staff do not live near Adastral Park, in fact it is human nature to strike a work/life balance and not live near your place of work. Furthermore, these well paid professionals are more likely to be attracted larger, executive homes is smaller communities. iii) BT is an independent company constrained by a fiscal policy which is forever changing so there are now guarantees that the site would ever be completed in the manner proposed because of financial constraints and expediency. b) A new large housing development east and south of the BT Adastral Park will be isolated from the rest of the nearby communities (see Spatial Strategy 3.23). Furthermore any such large conurbation will almost form a "doughnut" of housing surrounding and industrial complex which is far from attractive. c) I don't see how the area south and east of Adastral Park is any less attractive than that area northwest of A14/A12 junction (see Spatial Strategy 3.19.iv) as variations in rural landscapes need to be preserved to get a balanced mix of aspects. d) Increased traffic at 'rush hour' and during holiday periods is likely to cause gridlock. Any plans to introduce traffic light controlled junctions at "Tesco and BT roundabouts" will increase the possibility of gridlock. This has been proved by the reversion of a discredited "controlled" roundabout to a "non- controlled" status at the junction of the A1214 and Ropes Drive, Kesgrave allowing a better traffic flow. e) The A1214 is a major artery linking Martlesham and Ipswich and is already heavily congested, particularly at "rush hours", with school, park and ride, emergency services and bus traffic. Furthermore this route which has no easy scope for expansion suffers from frequent flooding in heavy rain. f) Increased traffic on the A1214, A12 and Foxhall Road will hamper emergency services and the Police. g) Increased load on existing schools (particularly on the overloaded secondary schools), health centres, social infrastructure and recreational facilities. h) Increased social unrest as more people are compressed into an area that originally attracted the existing residents for its balance of housing and rural surroundings. i) Martlesham is currently regarded by residents and surrounding communities as balanced mix of "new rural housing" and a key service area with the A12 separating the two functions. This was a key design philosophy for the development of Martlesham Heath. However if a large housing development did occur in this area then this perception would change to the detriment of both existing residents and new residents. The area bounded by Bell Lane, A1214. Foxhall Road and Waldringfield would become a urban sprawl: this point has already been made in The Times newspaper (31st Jan 2009, Business Section on the development of Ipswich) when talking about the development of BT Adastral Park, quote "Innovation Martlesham, named after the suburb of Ipswich"
2) I do support small developments of housing in some of the identified development areas within what was originally referred to by the Council as "Site 4".
Reasons: a) Martlesham will be contributing to Council's requirement for new housing. b) This policy will stimulate overall renewal of traffic and social infrastructure by organic growth rather than a disruptive "big bang" approach. c) New residents will more easily integrate into the surrounding communities.
3) I object to sites 765 & 769 being considered for housing development as this will affect the viability of the already established RSPCA facility in Martlesham. This facility is now the only such facility in Norfolk and Suffolk.
4) I support the development of a "new village" similar in style to Martlesham Heath Village for a larger development of housing north of the A12/A14 crossover between Straight Road (off Felixstowe Road) and the A12 (originally referred to by the Council as "Site 5"). This proposal lends itself to some imaginative thinking for a sustainable village environment. However this site does not seem to be identified as a development area in the current Preferred Option, so site 490 may be suitable but not as attractive.
Reasons: a) It is ideally located between the two industrial sites located east of Ipswich, namely Nacton Europark and Martlesham Industrial Estate (i.e. BT, Jewsons, etc). Furthermore a new low rise community office development is already completing construction near the site. b) It has an excellent road link (Old Felixstowe Road) to the Seven Hills Interchange (A12/A14) to the east and to the Sainsbury Roundabout at Warren Heath in the west. c) Faster sustainable rail transport links with Ipswich and Felixstowe centres can be achieved by the introduction of a station/halt at Nacton, thus easing road congestion. d) The use of this site for new housing will 'spread the load' of housing in the East of Ipswich and therefore spread the resulting traffic congestion which is already overloaded at the A12/A1214 junction, A1214 Martlesham/Kesgrave link, the A12/Foxhall Road junction and the Foxhall Road. e) Furthermore this site will also 'spread the load' on infrastructure such as schools, health centres, social and recreational facilities. f) It has easy access to the Sustrans and other cycle routes for access to Ipswich, Woodbridge and Felixstowe as well as the two Industrial areas previously mentioned. g) The actual building of the development will be less disruptive to major transport links and businesses than one sited in the Martlesham area. h) The Suffolk Showground would not be affected and it would make good use for a derelict site (the old Hollies Sports Ground currently owned by Suffolk Showground) which is only used for overflow car parking a few times a year.
SCDC Response: 1, 4, 7, 13, 16, 18, 19, 20
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Mr David Beaumont [209] Submission Agent Respondent ID: 209 ID: 209 ID: SUBMISSION Section 2.2.3 page 5
This is an incomplete assessment due to the omission of "Ipswich Heath [Unit 2] SSSI" in the assessment report.
This is an important SSSI site that is currently in decline but being improved by the local community under guidance from Natural England.
This SSSI site will be further jeopardised by the increase in noise, air and light pollution which will result in the increase of traffic congestion on the neighbouring A12 at Martlesham and adjacent roads.
SCDC Response: 9
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr David Beaumont [209] Submission Agent Respondent ID: 209 ID: 209 ID: SUBMISSION I STRONGLY OBJECT to an increase from 1050 houses to 2000 houses in PART of Site 4 at Adastral Park.
I previously OBJECTED to 1050 houses being built in single conurbation and favoured dispersal throughout the WHOLE of Site 4. My previous objections have not been addressed.
We are supposedly in a democracy where the majority of local opinion is upheld. In previous consultations a single large conurbation at Site 4 was the LEAST supported option and yet SCDC ARE IMPOSING A DIKTAT on the population by pushing forward with THEIR (not the public's) Preferred Option. SCDC's motivations are questionable.
Just so there is no confusion in SCDC I will list some of the reasons for my objection to a large housing development East of A12, near Adastral Park AGAIN:- 1)The existing infrastructure (e.g. road network, health centres, schools, recreational facilities, drainage and energy provision) cannot support a single large concentration of homes at Adastral Park. Furthermore any attempt to improve such infrastructure at Adastral Park will cause untold damage to the environment.
2)The Martlesham A12 and adjacent roads of A1214, Foxhall Road, Waldringfield Road, Gloster Road, Anson Road, Martlesham Main Road and Eagle Way are congested at times already but a new single development of 2000 homes at Adastral Park will cause traffic chaos, possibly GRIDLOCK at peak times.
Any attempt to alter the road junctions to traffic light controlled junctions will cause even greater traffic congestion and any attempt to widen the A12 at Martlesham will mean compulsory purchase of land, unacceptable disruption in the build process and only result in "bottlenecks" elsewhere.
SCDC's so called traffic study evidence to support their Preferred Option is USELESS as it is based on a reassessment of 2001 traffic data and the report itself states there are a "large range of uncertainties".
3) It will cause damage to the protected ANOB, SSSI and historical sites near to Adastral Park.
4) It will cause increased noise, air and light pollution to the existing, mainly rural, communities.
5)It will urbanise the existing communities who will lose the identity to become part of the urban sprawl of Ipswich.
6)It will increase the likelihood of flooding due to "run off" from larger areas of hard landscaping, roads, etc.
SCDC Response: 1, 4 13, 17, 18, 19, 20
IPSWICH POLICY AREA
Respondent Name: Mr David Carruthers [267] Submission Agent Respondent ID: 267 ID: 267 ID: SUBMISSION Dear Sir/Madam
Housing Distribution - Updated Preferred Option 7/09
Please find below my two objections (A and B) to the current proposals. I have tried the online system but have problems uploading....and I seem to have difficulties getting Outlook Express to recognise all the text. Hopefully it will be legible! I shall also send a hard copy by post.
Yours sincerely
David Carruthers
OBJECTION A: To 7.03 Ipswich Policy Area - East of the A12
SUMMARY
The development of 2000 houses and associated infrastructure on this exposed, peripheral site would be poorly related to the established built up areas of Ipswich and seriously detrimental to the character and appearance of the adjacent countryside including the AONB. It would conflict with the smaller scale and ex- urban or rural character of the nearby settlements of Martlesham Heath, Martlesham and Waldringfield and would overwhelm those communities. The possibilities of potentially less damaging (and no less sustainable) alternative sites for the 2000 houses (or of dispersal of the increased housing allocation) have not been adequately explored or consulted upon.
FURTHER DETAILS OF OBJECTION
1) Visual impact and relationship with existing development and the countryside
The Government 's four aims for sustainable development as set out at paragraph 4 of PPS1 include (inter alia):
- effective protection of the environment.
Paragraph 17 of the same document states that:
The Government is committed to protecting and enhancing the quality of the natural and historic environment, in both rural and urban areas. Planning policies should seek to protect and enhance the quality, character and amenity value of the countryside and urban areas as a whole. A high level of protection should be given to most valued townscapes and landscapes, wildlife habitats and natural resources. Those with national and international designations should receive the highest level of protection.
At present, the eastward expansion of residential Ipswich is well contained by the A12. Martlesham is a separate, village based settlement, Waldringfield is an outlying village within the AONB and Martlesham Heath is a modern "village" well screened from the A12 and presenting a soft edge to the suburban development with low density and building heights and abundant landscaping.
The commercial development on the east side of the A12 is also largely well screened and low scale apart from the BT Tower and Orion complex which reads as a landmark set well back within open countryside. The A12 links the area of open countryside to the to the south of Martlesham Heath with the countryside to the north (beyond the A1214 roundabout) and, although Martlesham Heath and the industrial estate are visible, they do not significantly interrupt the flow of countryside or the feeling of being beyond the edge of built up Ipswich. The minor road to Waldringfield is the gateway to the AONB at this point and is largely rural in character.
The site selected for the 2000 houses is beyond the extreme edge of development in the vicinity and is very exposed to view from the A12 and the Waldringfield road due to the lie of the land and the lack of established woodland to screen it. The proposed allocation and eventual development of 2000 houses and associated infrastructure would transform this area visually, because of the size and scale development and the urbanising effect of associated road works. Development here would be more noticeable than on many of the other potential sites within the IPA because the site is so peripheral and is so easily visible from two roads, one a major route and the other an access to the AONB. Landscaping would take many decades to establish and even then would not disguise the fact that a wide open, undeveloped site has become a massive housing estate.
I cannot accept the statement in "The Council's Response to the Preferred Option 12/08 Consultation and Reasons for the Updated Housing Distribution" that :
"The lie of the land in the proposed area, coupled with the fact that much of the land involved either has been or is scheduled to be used for mineral extraction, is such that the degree of the disbenefit from damage to the landscape, loss of agricultural land and the like from the increased size of this allocation is limited, and overall is less than that resulting from other potential locations." The lie of the land actually makes the site very prominent indeed and mineral extraction consents are almost always covered by restoration clauses in any case. There is no evidence that alternative locations for the 2000 house allocation have been seriously considered and they have certainly not been consulted upon.
In fact, development to the north of Foxhall Road (south of Grange Farm) would be far better related to the established built up area of Ipswich. It would be visually contained by the established woods to the south of Foxhall Road and far less prominent from the A12 corridor and, unlike the east of A12 site, it would have little or no impact on the entrance to the AONB. It is very difficult to see any justification for "jumping" the A12 with such a large scale development when there are still potentially well contained undeveloped sites remaining to the west of it.
I consider that the assignment of the entire Ipswich Policy Area housing allocation to this one exposed and peripheral site close to the AONB, whilst other, less damaging sites could be found, is contrary to the conservation aims of PPS1.
2) Effect on communities
The preferred strategy for the Ipswich Policy Area as originally planned was for development at the eastern end to:
"create a new community/neighbourhood alongside but not overwhelming existing communities at Martlesham, Martlesham Heath and nearby, neighbouring villages."
The proposed Strategic Policy SP3 acknowledges that Martlesham and other outlying villages (even Kesgrave) are settlements in their own right and "not part of the regional centre of Ipswich." That is entirely right; Martlesham and Martlesham Heath are relatively loose knit, low density village style communities beyond the main built up area of Ipswich. Waldringfield, also nearby, is an outlying village.
The proposed amended allocation would be totally out of scale in relation to even the largest of those existing communities and the development would inevitably overwhelm them by reason of its huge physical presence and the substantial new demands on local road space, services and amenities (any improvements or new provision would always lag behind the demand). It would represent a fundamental change to the character of the neighbourhood from being semi rural to being decidedly urban, and would seriously diminish the quality of life for existing residents.
I recognise the fact that development to meet RSS targets has to go somewhere, that the IPA is a logical location for a substantial amount of it and that, wherever it goes, existing local residents are likely to feel disadvantaged. However, the current scheme to put all of it in a single location where the existing communities are discrete settlements roughly half the size (or much less) of the proposed development seems to show a complete disregard for the particular character of this part of the IPA and how that character might best be sustained in an LDF context .
Martlesham Heath, Martlesham and Waldringfield all function very well as communities and have an excellent "sense of place" despite being so much smaller than the proposed 2000 unit allocation. I cannot see any truth at all in the Council's suggestion (Response to the Preferred Option 12/08 Consultation) that a doubling of house numbers is necessary to provide community facilities or a sense of place. It is simply not borne out by the facts as represented by established communities right on the doorstep.
3) Failure to seriously consider or consult on alternatives
Paragraph 4.38 of PPS 12 states that:
The ability to demonstrate that the plan is the most appropriate when considered against reasonable alternatives delivers confidence in the strategy. It requires the local planning authority to seek out and evaluate reasonable alternatives promoted by themselves and others to ensure that they bring forward those alternatives which they consider the LPA should evaluate as part of the plan-making process.
Paragraph 43 of PPS1 states (inter alia)
Community involvement in planning should not be a reactive, tick-box, process. It should enable the local community to say what sort of place they want to live in at a stage when this can make a difference. Effective community involvement requires an approach which:
- enables communities to put forward ideas and suggestions and participate in developing proposals and options. It is not sufficient to invite them to simply comment once these have been worked-up;
All of the public consultation about potential alternative sites was done in the expectation that around 1050 houses would be allocated to the IPA. When it was decided to double the allocation, the additional houses were simply assigned to the "preferred" site (which was, apparently, by no means the most popular with consultees). There would appear to have been no serious consideration given to alternative sites for the additional 950 houses (or the combined 2000) and there has certainly been no consultation on that particular issue. The second "half" of the proposed 2000 is just as significant in terms of planning issues as the first and would logically have warranted re-consultation on potential alternative sites and strategies.
The sites to the north of Foxhall Road were clearly found to "have many advantages over the alternatives" at the Preferred Options stage and would have merited reconsideration and further consultation in the light of the dramatically increased house numbers. The possibility of dispersal of the increased number of houses would also have merited further consultation, and I note that for the Felixstowe area "organic and evolutionary growth "" over a mixture of sites" has been considered a sustainable solution. Surely, if that solution could be made to work in Felixstowe it could also be a potential option in the IPA.
I think that the Council has failed to "to seek out and evaluate reasonable alternatives promoted by themselves and others" and to allow "the local community to say what sort of place they want to live in at a stage when this can make a difference" in this instance.
The current re- consultation exercise, with its very "focussed" remit is effectively only inviting people to comment once proposals "have been worked-up" On that basis I feel that the participation arrangements fail to meet the requirements of PPS1 and PPS12.
4) Sustainability Issues
I have to accept that I am not in a position to challenge the details of the Sustainability Appraisal but, from the matrix on page 40 of the Appraisal, it appears that there is relatively little to choose between several of the sites within the IPA. I note that the appraisal has assumed development in isolation, and so presumably the concept of dispersal hasn't actually been appraised.
What it indicates to me, is that the now much enlarged housing allocation could in fact be moved to the site north of Foxhall Road without incurring any significant sustainability issues. If that were the case, it would avoid the many of the problems in relation to visual impact on the countryside and AONB and adverse effect on nearby communities that I have referred to above. It would also facilitate far more flexibility in providing access to any potential commercial development at Adastral Park. Development at Foxhall Road would not have the barrier to integration that the A12 represents and could be made either self contained or integrated with established areas of development to suit prevailing planning thinking. There would be potentially good links with Ipswich and the station, and cycle links could be made to the Martlesham Heath commercial area as they are at Martlesham Heath.
There might be issues with what I suggest, but that sort of alternative should at least have been considered and consulted on as part of the process
5) Conclusion.
I am very concerned that, of the sites available within the IPA for this greatly increased allocation, the Council has (without consultation on alternatives) selected the one that is closest to the AONB. It is also one of the most peripheral in terms of its relationship with the urban area of Ipswich and is in a location where development of that magnitude would be seriously out of scale and character with existing settlements nearby.
The Council's justification for the 100% in crease in housing allocation at Martlesham is that:
Doubling the numbers of new houses at Martlesham provides the impetus/opportunity to create a stand alone community which is of a scale to trigger the need for wider community benefits, particularly a secondary school, and improved public transport provision. It will also increase the amount of developer contribution available to pay for necessary infrastructure. A larger scale development also has the opportunity to provide for a more meaningful set of mitigation measures which can be provided to limit the impact of development on the nearby AONB and nature conservation interests of the estuary. The area has lower negative impacts on landscape quality and public amenity overall than other potential alternatives.
This ignores the fact that a sustainable stand alone community could potentially be created on an alternative site (it is naïve to think that people living east of the A12 will necessarily work at Martlesham Heath) and, if the development were sited further from the AONB, that level of mitigation would not be required. The statement suggests that the area has lower negative impacts on landscape quality and public amenity overall than other potential alternatives, but I have been unable to find any documentary to back up this assertion.
I would urge the Council to consider alternative locations for this now much larger housing allocation, and to consult properly on the issue, giving people a more genuine chance of community involvement and perhaps some sense of "ownership" of the Plan, as is required by PPS advice.
OBJECTION B; To 7.04 Felixstowe/ Walton and the Trimley villages
I object to the proposed reduction in the number of houses allocated to Felixstowe, Walton and the Trimley Villages on the grounds that, without any consultation on, or consideration of potential alternatives, those houses have been reassigned to one particular site within the Ipswich Policy Area. The development of 2000 houses and associated infrastructure there would be poorly related to the existing built up areas of Ipswich, detrimental to the character and appearance of the adjacent countryside including the AONB, and seriously out of scale and character with the nearby settlements of Martlesham Heath, Martlesham and Waldringfield.
SCDC Response: 1, 4, 7, 11, 13, 17, 18, 19, 22
IPSWICH POLICY AREA
Respondent Name: Mr David Copp [188] Submission Agent Respondent ID: 188 ID: 188 ID: SUBMISSION The Deben, and Waldringfield in particular will inevitably be adversely affected by the proposed development, and no relevant "mitigation strategies" are proposed. 2000 homes in the quiet contryside will mean clogging of the local roads and congestion in Waldringfield which has only one entrance and exit and no public car parking.
Martlesham Heath already has one new village which was sensitively laid out to create a village-like atmosphere. 2000 homes in the area will undermine that success.
I strongly contest the need for this number of new homes which seems to have been based on a number of dubious assumptions.
SCDC Response: 3, 4, 9, 16, 17, 19
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mr David Cox [108] Submission Agent Respondent ID: 108 ID: 108 ID: SUBMISSION Most arguments stated for reduction in numbers at Felixstowe are equally applicable to Martlesham. The Port is not alone in suffering from recession, few industries are expanding at all, let alone slowing the pace of their expansion. Generation of new jobs will take just as long at Martlesham. The A14 will be affected by development at Martlesham as most journeys to/from there will use it.
SCDC Response: 7, 15 Other comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr David Cox [108] Submission Agent Respondent ID: 108 ID: 108 ID: SUBMISSION A Development of 1050 homes is in keeping with the size of the existent nearby villages. Increasing the number to 2000+ will radically change the nature of the new development, creating an urban sprawl that will destroy the current village ambiance. Planning consent for mineral extraction is granted on the basis of returning the landscape to it's former condition so references to it in this context are irrelevant. The impact on the road network by increasing the numbers from 1000 to 2000 will not be 'limited' but will be doubled!
SCDC Response: 18, 19
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mr David Creasey [223] Submission Agent Respondent ID: 223 ID: 223 ID: SUBMISSION I object to large scale development on the end of the Felixstowe peninsula as I think it is an inappropriate area. To consider Felixstowe as a major centre is absurd - it is a town. The whole idea that large scale development should be in one or two areas is wrong. It should be organic across the whole region ie considered as and when it is dictated by local conditions - not forced by planners. That way small communities get the opportunity to retain their local services. The A14 and Orwell bridge in particular restrict free access and the green fields should be retained (as directed by the Government)for food production. Obviously it is in the financial interest of landowners to change the designation of their land but this pressure should be resisted. Any increase in housing should be commensurate with local needs - not an inflow from other areas which should cater for their own increases. A large increase in local employment seems unlikely with both major employers currently reducing their workforce.
SCDC Response: 3, 4, 7, 12, 17, 18, 22, 27
IPSWICH POLICY AREA
Respondent Name: Mr David Eaton [536] Submission Agent Respondent ID: 536 ID: 536 ID: SUBMISSION Adastral park and adjoining land, Martlesham - Updated Preferred Option 07/09
I object strongly to the proposed developments outlined in the above application.
The revised planning application does not address the real problems associated with this scheme. Whilst these changes are a small improvement this is really just tinkering around the edges and in the process sets up the opportunity for more houses to be built some time in the future.
The main problem is that of the sheer scale of the development. I do not object to the refurbishment of Adastral park itself or indeed to the building of a small number (guaranteed maximum of 100) of houses directly adjacent to Adastral park. I do object to the building of a new small town of 2000 or more houses that is out of scale with any known or potential local needs. This proposal will create environmental damage, with noise, light and traffic pollution and have a major detrimental effect on the villages and green spaces to the new development.
Surely no one can believe this estate of houses is there to serve the new businesses in Adastral park. This estate will create huge traffic outflows to jobs in Ipswich, Felixstowe, Woodbridge and further afield across the Orwell Bridge. Indeed the new plans include provision of traffic lights on the A12 surely an admission of the traffic problems this development will cause to an already congested area.
Clearly there is a demand for new houses and yes the government are forcing local authority's to accept some of the responsibility for providing them. Nobody is however demanding a new small town and building on this scale. And certainly not in an area of outstanding natural beauty, that provides recreational and amenity benefits to the local towns and the many visitors to the area.
I am a resident of Waldringfield close to the proposed new development and have seen the village grow significantly over the past 30 years. It has done its bit as far as new housing is concerned in a balanced and sustainable way that has not harmed the area or the local environment, unlike the above proposals which if adopted will destroy much of what we all enjoy in the area.
Policy SP20 Area East of Ipswich
Fundamentally disagree with some of the comments/mitigation
Objective 5. To which town centre do you refer - it is not close to any town centre, it is in a rural location on the worng side of the A12.
Objective 6. The major areas of employment are in Ipswich, Felixstowe, up to the A12 and over the Orwell bridge and beyond. Proposed employment at Adastral Park will be at best modest. BT are shedding jobs in the UK and any new jobs are being created overseas.
Objective 8. How does this avoid light pollution, noise pollution, environmental damage. A housing estate of 2000 houses can never 'blend in' with the surrounding landscape.
Objective 19. This says nothing of the impact of this new 'small town' (without proper infrastructure) on the local communities. This development is a juggernaut that will not be stopped from impacting on everything local (environmental, social, cultural, life style) by growing a few trees.
Objective 22. Doubt this will actually happen. There are certainly no guarantees.
Objective 23. Investment and development of Adastral park would be a good thing creating a small number of jobs. I could see a small development of up to a maximum of 100 houses that would more than cover any housing needs of those few employees choosing to live next door to their place of work. It does not need a small town.
Assessment summary The summary acknowledges this location as the worst for the environment. I was under the impression that we should put more emphasis on environmental needs rather than less. In addition there is only a vague hope in these proposals that it is good for employment/linkages, it is not the basis on which to plan the development and building of a small town.
SCDC Response: 4, 7, 13, 16, 17, 19, 20
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr David Foster [142] Submission Agent Respondent ID: 142 ID: 142 ID: SUBMISSION The proposal to use the land to the East of the A12 can only be justified if there was certainty of employment at Adastral Park. Unfortunately BT has run down its operations at Adastral over the past 5 years by Offshoring / Onshoring work to India.
BT claims to have several large IT companies on site, whilst it is true that the major IT players all rent rooms there, they in general only employ 2 or 3 people each at the location. Their only purpose being to service contracts with BT. None of the major IT companies will relocate large numbers of staff from the Thames Valley as Suffolk does not have a major international airport close by. Stanstead does not offer scheduled flights to the USA or the Far East.
So one must question how Adastral Park will grow in terms of employment. If as I suspect it will not then all those living on the new development will have to travel to Ipswich to work or to Ipswich Station to commute to London. Unfortuntely the location of the proposed site means that traveling by public transport to the station is impractical as it would add an additional 1 hour 30 minutes to a commute.
Therefore I would argue that the new housing needs to be closer to Ipswich where short radial bus routes could serve it. Thsi would be more environmentally friendly and reduce the impact on congestion.
SCDC Response: 7, 11, 19
IPSWICH POLICY AREA
Respondent Name: Mr David Foster [142] Submission Agent Respondent ID: 142 ID: 142 ID: SUBMISSION The building of 2000 houses on the land East of the A12 is inappropriate to the area. It is totally out of proportion to Martlesham Heath and Waldringfield. The proposed entrances and exits from the site are inadequate and will lead to even greater congestion on the A12 which is a major trunk road.
SCDC Response: 4, 13, 16, 19
8 YOUR COMMENTS
Respondent Name: mr David Mason [164] Submission Agent Respondent ID: 164 ID: 164 ID: SUBMISSION The propsed increase in size of the adastral development will create a new town which will dominate the existing community, create tremendous infratructure problems and be a visual eyesore I am not oppose this application in principle - but this ammended proposal is too large
SCDC Response: 16, 17, 18, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr David Pike [518] Submission Agent Respondent ID: 518 ID: 518 ID: SUBMISSION I must object strongly to your proposals to build a new town to the rear of the current site owned by BT at Adastral Park.
As a resident of Martlesham, I chose to live here due to the relatively rural location. I did not wish to live in a town and don't want a new town built on my doorstep which will cause many problems. I am aware that there is a need for additional housing in Suffolk but surely there are other areas which would be more suitable.
I appreciate that you propose to improve the infrastructure and road system but this will cause many other problems. The existing road system is already very congested and it is already extremely difficult to gain access to and from the village of Martlesham Heath at off peak times let alone during the rush hour.
PLEASE THINK AGAIN AND TURN DOWN THIS PLANNING APPLICATION.
SCDC Response: 4, 19, 20 Please note: this consultation is not related to a planning application.
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr David Travers [340] Submission Agent Respondent ID: 340 ID: 340 ID: SUBMISSION The phrase 'developer contributions will be sought' occurs with worrying frequency in the plan. Enhanced infrastructure will be essential and must be a non-negotiable part of the development plan. The large Trimley developments of the 70s onwards has already bequeathed us a large number of homes with very poor local facilities.
SCDC Response: 20, 25
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mr David Travers [340] Submission Agent Respondent ID: 340 ID: 340 ID: SUBMISSION Far too many new homes are proposed for Felixstowe/Walton/Trimley. Local need does not justify even the reduced no (1410) proposed; it will be impossible to reach this total without encroaching on high quality agricultural land(some of it bordering an AONB)in an area already deficient in natural green recreational space. Transport pressire on the A14, already congested, will become intolerable. Nowhere is there a clearcut guarantee that 'affordable' homes will form a significant proportion of the total.
SCDC Response: 12, 22, 23 See affordable housing policies DM1 and DM2
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mr David Travers [340] Submission Agent Respondent ID: 340 ID: 340 ID: SUBMISSION What is a 'modest' greenfield allocation? How can there any greenfield allocation be modest in an area already identified as 'deficient in natural green spaces'. The figure for average construction rates (80 per annum) over the prolonged period of the plan is completely meaningless: property developers don't work like that. When new houses are built they will be built quickly in large numbers, imposing a major strain on local infrastructure.
SCDC Response: 23, 25
THE OVERALL STRATEGY
Respondent Name: Mr David Travers [340] Submission Agent Respondent ID: 340 ID: 340 ID: SUBMISSION The reduced new housing allocation for Felixstowe/Walton/Trimley is to be welcomed, but the 1410 houses remaining in the plan go well beyond any demonstrable local need, and take no account of Felixstowe's geographical position. It is simply not credible to suggest (as the LDF does) that the present road system, even with minor improvements predicated on 'developer contributions' (ie optional) will be able to cope with the additional load. The LDF recognises that there is a lack of green recreational land in Felixstowe - so why build on what little remains?
SCDC Response: 3, 23, 26
IPSWICH POLICY AREA
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION I object to the proposed increase in new housing allocation at Martlesham for numerous reason eg it would be on greenfield site, the adverse impact on local infrastructure especially transport, the adverse impact on the local environment eg Deben Estuary, and the impact on and lack of respect it shows for existing communities. The council has not justified why the very significant adverse impacts of its proposal makes this the best option.
SCDC Response: 4, 15, 16, 17, 18, 19, 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION Regarding the Eastern Fringe Infrastructure Study, Emergency Services section. No consideration seems to have been given to the response time increases that would be inevitable, in particular along the A12 between Woodbridge and Seven Hills, if the proposed increase in population takes place at Site 4.
SCDC Response: 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION Mention is made in the Transport Study of a new pedestrian/cycle crossing of the A12 near Barrack Square Martlesham Heath (copied from the BT planning application). I oppose this idea because such a crossing would dump people in the middle of the residiential area of Martlesham Heath village where there is no infrastructure to copy with the influx and no way to add such infrastructure without a major impact on the area.
SCDC Response: 20 Other comments noted
IPSWICH POLICY AREA
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION The proposal to increase to 2000 homes is not based on consistent thinking by the council. In places it says this is to build a stand a alone community and elsewhere it says it it to be integrated with the remainder of Martlesham. The council seems to be using an inconsistent and contradictory set of arguements to justify an unjustifiable change of plan.
SCDC Response: 18
SETTING THE PRINCIPLES
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION The council is using inconsistent arguments to support its proposal. If the arguments cited in 5.19 were also applied to the East of Ipswich area the council would not be proposing a doubling of the number of dwellings on site 4. This difference in approach has not been convincingly justified.
SCDC Response: 15
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION The council appears to have ignored the vast majority of comments from the previous consultations and is basically saying that all objections can be mitigated against by increasing the number of dwellings at Site 4 and getting a big contribution from the developers (ie the purchasers and residents). But the council fails to explain exactly how the problems of doubling the dwelling numbers would addressed, just giving an assertion (or hope?) that this would be possible. Hence the rational for the proposed change is not convincing.
SCDC Response: 1, 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION Regarding the Transport Study and Addendum. The study does not take account of the A12/Eagle Way / Barrack Square roundabout. Major peak hour congestion already occurs at this junction so it seems a significant omission from the study. Insufficient time has been allowed for comment due to the publication late in the consultation period of the addendum The traffic flow diagams appear flawed in that flow leaving a junction does not match the flow arriving at the next adjactent junction (eg Figure 1 flow between A and H) which raises further doubts about how much confidence can be placed in the study.
SCDC Response: 10, 13
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION The council's conclusion that 2000 dwellings at Martlesham would trigger the need for a new secondary school is wrong. Even 2000 dwellings would not provide enough students for a secondary school. Any number of dwellings, when added to other demand, might be enough to trigger the need for a new school. But by itself this can not be legitimately used as justification for an increase from 1050 to 2000 dwellings. Once again this appears (at best) to be muddled thinking by the council.
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION Tha council's response to the comment that 1050 houses are too many is to say that 1050 is the minimum needed to meet RSS requirements. This assertion can not be made in isolation. It is the total number in the whole council area that matters not the number is any one site. By contrast the council's view is that it is possible to reduce the numbers in Trimley/Felixstowe. Hence the council is adopting an unjustified difference in approach in different areas.
SCDC Response: 4, 15, 16
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION The list of LDF evidence base studies given within the online consultation website is not the same as the list on the council's main website. For example the Nov 09 Transport Appraisal Addendum is not mentioned. Also the summaries given do not always fully reflect the actual document summaries accurately eg the Transport Appaisal summary fails to mention the consultant's concerns about the limitations of the study.
SCDC Response: Noted
THE OVERALL STRATEGY
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION Why can't the council use the plain Engish it aspires to on its website? Why does the document say that housing numbers in Felixstowe etc will be "managed" when the actual proposed change is basically a reduction?
SCDC Response: Noted
SMALL WINDFALL PROVISION - REDUCE PROVISION FROM THIS SOURCE
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION The council hasn't justified such a large reduction in the number of windfall sites. Surely the council was aware of the factors driving the number of these sites when the original distribution was made. It looks as though this number is being reduced simply in order to justify the larger numbers elsewhere in the proposed housing distribution eg Martlesham. Very few people want to see any increase in housing numbers in this area the majority would prefer any increase be distributed evenly not in big developments. The council should plan for maximum use of windfall sites and small developments.
SCDC Response: 2, 4, 22
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION The report says that there is no car parking at Waldringfield available as the starting point for estuary side walks and draws the conclusion that 2000 new houses nearby would thus have little impact on the area. It is possible to park a car at Waldringfield and hence the conclusion is wrong. Even without this error regarding car parking common sense would indicate that 2000 new houses close by at Martlesham would greatly increase the number of people using the estuary side for recreation.
SCDC Response: 9
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION I agree that the new proposals for East of Ipswich are less sustainable. SCDC has failed to justify why we should accept the proposed change of a doubling of the number of new dwellings at Martlesham.
SCDC Response: 8
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Mr David Trouse [167] Submission Agent Respondent ID: 167 ID: 167 ID: SUBMISSION Sustainability Appraisal. Paragraph 2.4. I believe that the proposed new policy for East of Ipswich is much less sustainable. Many concerns eg about access to countryside / the Deben SPA, and traffic in an already congested area, have been seriously understated, or ignored.
SCDC Response: 8
MARKET TOWNS - INCREASE PROVISION FROM THIS SOURCE
Respondent Name: Mr Dominick George [550] Submission Agent Respondent ID: 550 ID: 550 ID: SUBMISSION The Updated Preferred Option Housing Distribution 7/09 document about which consultations are sought is unsatisfactory and unjustified in so far as it seeks to provide towards the strategic housing targets by additional greenfield Market Town allocations rather than through windfall housing. The approach and reasons relating to windfall housing and PPS 3 are not justified.
It is of concern that it is at such a late stage of the process that there is such a significant alteration in the housing distribution strategy which as the Council accepts is the most contentious issue covered by the LDF Core Strategy.
In particular in relation to the Market Town of Aldeburgh the Updated Preferred Options are unjustified in so far as they seek to provide for any greenfield allocation. It is inappropriate that any such allocation is made and Aldeburgh should be given special protection. There are better options for housing distribution available which accord more readily with the broad strategy than seeking to provide greenfield allocation given the recognition of the sensitive position of Aldeburgh within the AONB.
SCDC Response: 4, 27 See Policy SP22 Aldeburgh
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION 5.10 "New housing should allow integration with existing communities but at the same time should respect and maintain the character of individual settlements and communities"
How does this policy align with the proposed integration plans of the Adastral development.
These plans propose that private woodland (owned and maintained at personal expense by the householders of Martlesham Heath) be displaced to ensure that the new development gain easy access to Grange Farm, Kesgrave and beyond.
SCDC Response: 18
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION 5.10 "The road, rail and other public transport networks should be capable of accommodating the traffic and journey requirements that new housing inevitably brings with it"
Martlesham Heath cannot cope with traffic at today's levels (at rush hour).
How will it cope with the extra traffic generated by 1000 houses let alone 2000 houses.
Martlesham Heath is equidistant from Trimley and Woodbridge rail stations. Moving 1000 houses from Felixstowe to Martlesham (that is a move to an area less favourable for rail commuting) is in contravention of this policy.
SCDC Response: 11, 13
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION 5.10 "We should look first to re-developing old brownfield sites before looking to identifying new greenfield sites"
With regard to the area to the East of the A12 this is a greenfield site.
Any mineral extraction and related works are obliged to be returned to greenfield following extraction.
Therefore this is a greenfield site and as such any plans to develop on it are in contravention of this policy or point of feedback.
SCDC Response: 15
STEP 1-THE SETTLEMENT HIERARCHY
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION 5.06 "in relation to housing most new development is to be directed towards the major centres and market towns, with very much smaller scale development at the Key and Local Service Centres."
Just because the site at Adastral is tagged onto the end of an urbanised spur (which stretches from Ipswich along the Woodbridge road to Martlesham) does not imply that the development will form an integrated part of the settlement of Ipswich.
Nor will the development be able to avail fully of the services that Ipswich has to offer.
SCDC Response: 4, 16, 18
THE OVERALL STRATEGY
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION "The location for such a community remains at Martlesham although the location is specified as to south and east of Adastral Park"
There is no explanation as to why this specific area to the south and east of Adastral Park is mentioned in the document.
1.02 states that "Once adopted, it should be possible just from the Core Strategy to state whether or not any development proposal, for whatever use, size or location, is acceptable in principle."
It appears that the Core Strategy is being driven to align with a specific development proposal (and not vice versa).
SCDC Response: Noted
IPSWICH POLICY AREA
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION "Create complementary floorspace (eg retail and leisure), and enable the provision of supporting infrastructure, an Area Action Plan be prepared"
The devil is in the detail. Time and time again the planning processes employed demonstrate a happy go lucky attitude whereby key issues are put to one side to be dealt with at a later stage or by some other yet to be produced plan.
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION Re: Response 5 As a resident of Martlesham Heath I have experienced the effects of several minor transport 'improvements' in the locality.
The Park and Ride Roundabout has caused a detrimental effect to the level of traffic on the Foxhall Rd and Dobbs Lane.
A 'Cycle Friendly' route on the Felixstowe Road has only served to increase the average speed and level of motorised traffic.
The Kesgrave traffic lights.
I have yet to see evidence that suggests the local authority would be able to plan an effective transport infrastructure that could deal with the traffic generated by 2000 dwellings in addition to current traffic levels.
SCDC Response: 13 Other comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION Re: Response 4 At the moment the villages of Martlesham, Waldringfield and Newbourne form the main centres of habitation to the east of the A12.
To a large extent the A12 itself forms a traffic barrier between this area and the encroaching urbanisation of Ipswich.
Placing a development, which rivals that of the town of Woodbridge, into this area will have a completely destructive impact on the current environment, wildlife and quality of life.
No level of advanced planting and provision of dog walking areas will lessen the destructive impact on the nearby AONB and estuary.
SCDC Response: 17
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION Re: Response 3
"Increasing the numbers also offers greater funding opportunities for improving existing and creating new public transport provision which will also be of benefit to these other local communities."
With reference to paragraph 2.01 of this document, this 'pack them in' approach does not seem to align with the range of topics that are key to the future of the communities of Suffolk Coastal, including the economy, transport, community well-being, the environment etc.
SCDC Response: 11, 17, 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION Re: Response 3 Only a minor part of the proposed site is being used for mineral extraction.
It was proposed in BT's original submission that this area would form a central lakeside landscape as part of their development.
It is disingenuous to suggest that the presence of this facility would reduce the overall environmental damage caused by a doubling of dwelling numbers.
SCDC Response: 17 Comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION Re: Response 3 <b><i>"[The increase in numbers] offers the opportunity to better mitigate the potential impact of visitors and residents on the neighbouring countryside and estuary through properly managed informal open space provision"</i></b>
This is not a logical argument.
Are the Council seriously suggesting that a doubling of the number of dwellings will facilitate a net reduction in the overall impact of the development?
SCDC Response: 9, 17
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION Re: Response 3 While the original housing numbers allocated to Felixstowe are to be reduced due to a smaller than expected increase in potential employment at the docks, why is it that the area to the East of the A12 is considered to have employment opportunities that support 1000 households, let alone a revised proposal of 2000 households?
All indications are that the major employer to the East of the A12 (BT) is actively reducing its full time employee base.
Apart from BT, the only significant employer on the eastern side of the Orwell Bridge is in fact the Port of Felixstowe.
SCDC Response: 7, 16
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION Re: Response 2 There is no evidence that suggests that the benefits of doubling the size of this development outweigh the drawbacks.
To make this statement raises the serious question as to whether these responses are being made from an objective point of view.
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION Re: Response 2 Throughout the 1960s the British planning authorities believed that a higher density of dwellings (in the form of carefully considered multi-story accommodation) would provide the basis for a 'good sense of place' in the community created.
To say that no 'sense of place' was realised could be considered to be an understatement of the actual outcome.
SCDC Response: 18 Other comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION Re: Response 1 The Council appears to be in broad agreement that the original David Lock study overestimated the demand for housing on the Felixstowe Peninsula. The Council does not indicate why they believe that that demand has now migrated to an area 'to the south and east of Adastral Park'.
Perhaps there is another David Lock study which addresses the location to the East of the A12. One which the Council believes to underestimate (by a similar amount) the demand for housing.
SCDC Response: 4, 16, 22
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mr Eamonn OByrne [274] Submission Agent Respondent ID: 274 ID: 274 ID: SUBMISSION Re: Response 1 The Council appears to be in broad agreement that the original David Lock study overestimated the demand for housing on the Felixstowe Peninsula. The Council does not indicate why they believe that that demand has now migrated to an area 'to the south and east of Adastral Park'.
Perhaps there is another David Lock study which addresses the location to the East of the A12. One which the Council believes to underestimate (by a similar amount) the demand for housing.
SCDC Response: 4, 16, 22
IPSWICH POLICY AREA
Respondent Name: Mr Edward Parkinson [410] Submission Agent Respondent ID: 410 ID: 410 ID: SUBMISSION I am writing in regard to the proposed development and expansion of the Adastral Park site in Martlesham Heath which has been proposed by British Telecom.
The application proposes the introduction of up to 2000 new dwellings in an area which adjoins the village of Waldringfield. This, of course involves not just the construction of housing but the population and the traffic increases that such developments entail. I would question the likelihood of maintaining the unique character of the villages of Waldringfield, Newbourne and other surrounding areas while the ever encroaching, homogenised sprawl of housing from the outlying suburbs of Ipswich continues unchecked. It would seem sensible to preserve an area of transition between those areas one wishes to preserve for their uniqueness or beauty and those areas of housing which are have no aesthetic pretensions.
This is an area which contains landscape already recognised for its unique character and national importance as wildlife habitats (the Deben Estuary SSSI, Newborn Springs AONB). Any expectation that the area will retain its current character if the development proposed brings increased demands for vehicular access, parking and any corresponding infrastructure would seem misguided.
Whilst I recognise that the continuing need for housing necessitates projects of this kind being seriously considered, surely continued encroachment on the River Deben leads to protected areas existing within a metaphorical glass bowl. The idea that areas cherished for their rural beauty can exist as theme park experiences seems ridiculous.
Many thanks for your attention
SCDC Response: 4, 16, 22
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Eric Cook [522] Submission Agent Respondent ID: 522 ID: 522 ID: SUBMISSION Dear Sirs,
My objections to Updated Preferred Option 7/09-Housing Distribution.
First. I wish to object to the structure of this consultation exercise. It's presentation is shambolic, making it very difficult for us to understand and I guess even more difficult for us to raise objections and comment. I have set out my objections below and regardless of whether they conform to your prescribed objection format, I expect them to be recorded and taken note of.
If allowed this development will have a massive impact on the residents of Martlesham Heath. Therefore, it was not a good idea to use insensitive language, such as 'no show stoppers', when summarising your findings in appendix 1.
I object to any future large development of Martlesham Heath (Ipswich Eastern Fringe) for the following reasons:
1. However you reconfigure the A12 road junctions, 8000 plus extra car movements a day will cause unacceptable hold-ups and delays on the A12. Why is there no evidence based study of traffic on the A12, presented in Appendix 1 (List of LDF evidence base studies)?
2. Medical and hospital services will be placed under severe pressure and would not be able to cope. At present we have no critical heart services in Suffolk. Any large increase to the population east of Ipswich, where we have the longest journey for treatment in Cambridge or Norwich, will result in additional deaths.
3. Fire and emergency services will be inadequate at current numbers. Access to Martlesham Heath will be delayed due to the increased traffic levels. How did you predict that the additional growth could be covered by the existing set-up?
4. Any development on this scale will have a detrimental effect on the Deben valley and estuary, currently an area of outstanding natural beauty.
5 There are not enough jobs or potential jobs in this area to support such a large increase in the local population.
6. Building 2000 houses at Martlesham will do nothing to support the rural economy and community. Why not take this opportunity to do something good for Suffolk and Coastal. Build affordable homes in rural communities that allow local people to remain local. Rural schools will remain open and local businesses will thrive.
SCDC Response:1, 4, 7, 13, 17, 20
IPSWICH POLICY AREA
Respondent Name: Mr Fraser Last [76] Submission Agent Respondent ID: 76 ID: 76 ID: SUBMISSION I live at Welburn, School Road, Waldringfield and strongly oppose the building of new homes on Waldringfield Heath.
Waldringfield is a unique Suffolk village with beautiful surrounding countryside. This proposed development of new homes would totally destroy the village and local environment.
Some reasons why this area should be rejected for major development
Impact on the environment
Creating a new suburb for another 10,000 people on the very edge of the Area of Outstanding Natural Beauty will threaten preserving the south side of the River Deben as countryside for future generations.
Visual impact
These houses (on BT's plan including blocks of flats five storeys high) will destroy the rural landscape and create extensive light pollution. The area that is being quarried should revert back to its natural heath land or agriculture once quarrying has ceased, as required under its hitherto green field planning designation - now mysteriously 'brown field' after some undeclared process.
Road congestion
On the basis of current Adastral use, we are told that only 15% of the 10,000 new residents will work or go to school in the new town. The A12 junctions, even with the improvements envisaged by BT, will not be able to cope. New and existing residents will find themselves grid locked. The narrow Newbourne road has already become a rat run for traffic when the A12 is congested.
Impact on Waldringfield
The planning inspector who in 2007 turned down the application for 150 log cabins opposite the BT site recognised the effect of such a development on the character of Waldringfield, the most vulnerable of the villages in the AONB. How much greater would be the effect of the development now proposed?
SCDC Response: 13, 17, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr G.R. Chapman [295] Submission Agent Respondent ID: 295 ID: 295 ID: SUBMISSION After a morning going through the documentation I only registered in order to comment. I am not an expert in computer technology and use and found it impossible to enter my objection on the form displayed. It is clear that this location, containing a location designated as an area of Outstanding Natural Beauty, has one of the few mainly unspoilt rivers in the East and at the moment attracts a maneageable influx of tourists. In most locations of new housing the planners work to an expected increase in population of 3/4 persons per dwelling on average. Even with new Highways development the starting situation is grim. The A.12 access roundabouts are already inadequate to handle the traffic which is bound to increase. Lanes built for horse drawn traffic have sections where cars cannot pass approaching from opposite directions with many bends and no warning signs. Unless there is housing the roads are deristricted and Highways departments are inadequately funded to be able to improve safety. It is so short sighted of planners. They are covering more and more land for housing and reducing the areas of open country and farmland, which enable people re charge their batteries for the lives of the majority living in crowded towns and cities for their work. Nationally we are steadily eroding the areas for tourists and relaxation which increases the problems for the NHS
SCDC Response: 1, 13, 17, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Gareth Thomas [358] Submission Agent Respondent ID: 358 ID: 358 ID: SUBMISSION I wish to object in the strongest terms to the proposed development referenced above.
I have given the matter great thought given the need for East of England development, more housing etc. However, the more I think about it the greater become my objections.
The proposal is entitled 'Re-development of Adastral Park' - that in itself is an entirely misleading title. That might be part of the plan but I cannot see how the title applies to a plan to extend the Ipswich / Kesgrave / Martlesham Heath sprawl outside its natural envelope, without a break, over a site of scientific and archaeological interest, over an extensive area of lowland heath providing sanctuary for wildlife, over countryside latticed with footpaths and bridleways providing recreation for the South Suffolk and Ipswich population and right to the very edge of an area of outstanding natural beauty.
It is a plan to build a new community squeezed and condensed between the A12 and the River Deben in an area which is meant to have been protected by various planning laws and regulations. Why bother with these laws and regulations if they are to be ignored.
I expressed my views to BT in a detailed form following the BT consultation. I am particularly concerned that the planning proposal depends on Suffolk Coastal providing secondary education and providing an adequate network of access roads.
I asked BT about secondary education - according to their representative that is down to Suffolk Coastal. Where are the children from the 2000 homes (plus) likely to go to school for secondary education? There is no extra capacity at present.
The plans suggest that there will be three entrances / exits for motor vehicles - two on the A12 and one at the site of the current quarry entrance. The A12 in its current condition would not suffice - already it can take up to five minutes to cross the roundabout into Foxhall Road such is the continual density of traffic. When challenged the BT representative advised me that the development of the A12 is a Suffolk Coastal matter. The introduction of traffic lights will only serve to create more chaos as shown at Grange Farm. The whole network of the A12 and local access roads will need to be completely redeveloped using motorway- type slip roads and underpasses.
It is likely that car owners from the proposed development (and they will all have cars - it is unrealistic to imagine that they are going to propel themselves on electric bicycles as BT suggests or even that they will all work on the Park as BT imagines) will avoid the A12 and sneak out of the quarry entrance, turn left and exit themselves into Suffolk via Martlesham Heath along the edge of the AONB. The network of C and B roads between the A12 and Waldringfield Heath will all need to be upgraded.
For recreation the occupants of the new development are likely to head for the nearest water and the Waldringfield cul-de-sac adding to traffic which cannot be accommodated even now.
The plans as presented by BT do not give sufficient corridor space for wildlife. As far as one can tell there is only one narrow corridor. Wildlife needs more than one route in and out of an artificial park in the midst of a housing estate.
I am concerned also that a development of this magnitude will make inaccessible for the future several areas of archaeological importance. Such a risk and the above-mentioned risk to wildlife suggest, along with the other arguments, that the BT vision should be much more contained.
This development should not go ahead as proposed. It should not extend right to the edge of an AONB. A considerable portion of the site should be returned to lowland heath as per national policy. It should certainly not proceed without a public enquiry designed to examine the rules, regulations, laws and policies which currently apply, the costs to the public purse and the devastating effect that it is likely to carry.
If you are still reading this I have major concerns over the arrangements, or lack of them, for water drainage from this vast site. Living at the bottom of Waldringfiled we are already inundated with water everytime it rains heavily. Covering this vast area without adequate drainage will run the risk of ecological disaster - remember Boscastle - nobody thought that would happen. The Plan suggests to me that adequate water drainage will not be available until at least 2019 and, ebven then, as with all the other enabling requirements, only if funded by the developers.
SCDC Response: 13, 17, 18, 19, 20 Schools comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Graeme Read [257] Submission Agent Respondent ID: 257 ID: 257 ID: SUBMISSION Dear Sir,
I wish to register my concern and objection to the proposed develpoment of over 2000 new houses at the BT Adastral Park. Having been a resident of Martlesham Heath since 1987 I have seen the underhand and illconcieved manner in which development of housing has crept in an eastward direction. I object to the proposed development for the following reasons.
1)The envionmental impact on Martlesham Heath and Waldringfield, the development would ruin a huge greenfield site.The urbanisation of an AONB.
2)The inability of the road infrastructure to cope with the increased traffic.
3)The possible building of road junctions and interchanges totally out of kilter with the environment.
4)The added strain on local services in relation to health and emergency services and education.
5)The future development of the New Town to 3500 homes.
6)Increase in noise and light pollution from the development and from the increase in traffic.
I am discusted that the Suffolk Coastal Council is even considering such a development. This is the edge of rural Suffolk, leave it that way!
SCDC Response: 13, 17, 19, 20
8 YOUR COMMENTS
Respondent Name: Mr Graham Emsden [288] Submission Agent Respondent ID: 288 ID: 288 ID: SUBMISSION The proposed transport infrastructure upgrades will in my opinion be inadequate to cope with the additional pressure put on the two junctions with the A12. Traffic signal control in place of the existing roundabouts will result in significant tail backs of traffic on the A12 probably back to the A14 during busy periods and as this is already a heavy traffic route the addition of an additional 2000 homes each with an average of two vehicles many of which will want to access the A12 during the period 0730 - 0900 the congestion will almost certainly result in poor if not dangerous driving, eg crossing red lights. Whilst the bus services will be used by a small proportion of the potential new residents going by present usage this is unlikely to have any significant effect, the same applies to BT's Green Routes plan. This of course does not include the additional traffic entering and leaving the development as a result of the additional 2000 jobs which are to be created. In short this is the wrong location for a development of this size which will substantially increse increase traffic on an already busy main traffic artery.
SCDC Response: 4, 11, 13, 16, 19
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Graham Mills [326] Submission Agent Respondent ID: 326 ID: 326 ID: SUBMISSION The creation of a large new town at Martlesham cannot be the preferred option. It goes against the principles of which such expansion are planned against ie valuable agricultural land, integration with existing developments be in sympathy with the country side etc.
SCDC Response: 4, 15, 16, 17, 18
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mr Graham Mills [326] Submission Agent Respondent ID: 326 ID: 326 ID: SUBMISSION New housing should not be provided in isolation, but should be built where facilities already exist or could be upgraded or provided:-
This proposal is totally against the principal above.
New housing should allow integration with existing communities but at the same time should respect and maintain the character of individual settlements and communities:-
This is a new town and again is at odds with the principle above.
Building on high quality agricultural land should be avoided as far as possible:-
This is high quality agricultural land.
SCDC Response: 18
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mr Graham Mills [326] Submission Agent Respondent ID: 326 ID: 326 ID: SUBMISSION One of the core reasons for this proposal seems to be promise of employment from BT at Adastral Park. The fact is BT is getting rid of jobs in the area and exporting what is left. This will put a huge increase on the requirements of the road infrastructure with people travelling to Ipswich going to non existing jobs there. I would question the need to any more housing in this area.
SCDC Response: 7, 16
SETTING THE PRINCIPLES
Respondent Name: Mr Graham Mills [326] Submission Agent Respondent ID: 326 ID: 326 ID: SUBMISSION The current infrastructure is not adequate for this expansion. This includes roads, public transport sewage gas energy etc. This proposal is not an expansion of the village infrastructure of Martlesham but is the creation of a standalone new town. This is outside the guidelines laid down by the Government.
SCDC Response: 18, 20
1 INTRODUCTION
Respondent Name: Mr Graham Mills [326] Submission Agent Respondent ID: 326 ID: 326 ID: SUBMISSION We are hearing from central government that in the not to distant future that this country will need to be more self sufficient in food production. What you are proposing here is to concrete over valuable and productive farm land. This is totally unnecessary with the other options available.
SCDC Response: 15, 22
THE MARKET TOWNS Mr Guy Ackers (Mr Guy Ackers) Respondent Name: [401] Submission Agent Respondent ID: 401 ID: 401 ID: SUBMISSION In response to your request for consultation on this subject, I have the following comments for your consideration please.
Preface. Original decisions are usually the best and after thoughts seldom come up with a better idea. Particularly in the case of the LDF as so much effort is put into the various subjects and little or nothing is considered lightly.
I proposed that the original decision regarding development in the Haven Gateway for housing distribution was the correct one. This gateway runs from Ipswich towards the east via the Trimleys and into Felixstowe. For better or worse, and I believe for the better, the concentration of new building, even to the extent of accommodating the full allocation, should be in this corridor.
It makes much more sense to have one upheaval for increased infrastructure, in one area, rather than turning upside down small townships and villages with little or no infrastructure, where the inhabitants are already struggling for survival in regard to water, gas, electricity, medical, local transport, schools and a lot more. These domicile villages can just about accommodate the "windfall sites" as the impact is slight, sometimes difficult, but we love in difficult times.
My proposal therefore is to limit all new building, which after all is not a huge amount, needing a new township to be built, to be in the above area, using the absolute maximum of brownfield sites as possible. The use of Greenfield areas must be kept to an absolute minimum but if Greenfield areas are to be used, the lowest impact on the environment, wildlife, landscape hedgerows and vital wildlife habitat and corridors would be limited if the Felixstowe area were developed outside the curtilage of the current town boundary.
The following comments arise specifically from the chapters and paragraphs of the report as under
2.05 Felixstowe, Walton and the Trimleys have an infrastructure to support housing development, whereas Martlesham is very much a dormitory area with virtually no services surplus and I recommend the key changes need to be revisited. There is already a large community in Martlesham and any further new community development would be difficult to sustain and would have unreal repercussions on the approach to the Sandlings and other rural special areas. Some threatened wildlife species are currently just about holding their own on the small habitat areas kept aside such as glow worms, other inverts and some birds.
2. "young people are leaving home earlier". This is a contradiction to the published and well documented case that young people cannot afford to move out of the parental home, due to costs, high deposits for house purchase, reduced affordable income, unemployment etc which are all symptoms which will not be solved over the planning period. The problem is there are too many youngsters and that is another problem all together. Likewise young unmarried who plan to have children in order to get to the head of the housing list should be denied accommodation which may stop this mal practice.
3.03 Quality of life 'enjoyed' by the local community should be rewritten using the word 'suffered'
5.10 If housing and jobs are to be provided in tandem, house building in Martlesham and other outlying villages is a non sequitur and points convincingly to the larger conurbations where work and potential work may exist. Building on high quality or agricultural land should be avoided at all costs outside the Haven gateway corridor and then nobly where absolutely unavoidable. Brownfield and in filling opportunities should be exploited at all costs, even to the point of giving incentive to the developer and landowner. (see 5.13 also).
5.17 the concept of a stand alone new community in an already overcrowded county, east of the A12 is pie in the sky. The cost of development of a self sufficient new infrastructure is simply not practical, even more so nowadays with the national debt running at £3 trillion.
6.4 The impact on wildlife will be a serious factor wherever new development is planned. In a situation where some wildlife will have to be abandoned, the network of landscape hedgerows in the Felixstowe area and the semi rural outer limits of the town is somewhat limited when compared with more rural areas surrounding smaller towns and villages. This in itself may not be the overriding factor if it were not for the fact that wildlife habitats of any great number and importance are somewhat limited in and near to Felixstowe. Hedgerows are that vital corridor for wildlife to move between habitats and if there were neither extant, then the impact would be less. This is supported by Appendix 1 Green Infrastructure.
7.05 Evidence to date indicates there are relatively few landscape hedgerows outside the town of Saxmundham, there being less than 70. Greenfield land around Kelsale (which is a much smaller town) for example supports over 200 and this endorses the policy of non development other than in Saxmundham and would therefore present less damage.
SCDC Response: 15, 17, 20, 22, 23 Support Noted
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mr Guy Pearse [182] Submission Agent Respondent ID: 182 ID: 182 ID: SUBMISSION Housing Distribution I think that there are still too many new houses proposed for Felixstowe and the Trimleys but am pleased to see the reduction already put forward. The Felixstowe peninsula is constrained by the rivers and the sea on 3 sides with further limitations from the status of the land adjoining the estuaries. Planning policy should not allow the area to become entirely built up. There is a great need for the rural villages of SCDC to have some additional housing to allow young people in particular to live in these villages. The fugure of 1000 houses for the area appears arbitrary and I am not convinced that this is necessary for regeneration. Access limitations The single route[A14] in and out of Felixstowe is already overloaded at peak times and the incidents that block the road from time to time already bring severe congestion with attendant difficulties for emergency services. Adding further housing and potentially a new access onto Candlet Rd can only make matters more difficult. Improvements to the access onto the Port of Felixstowe Roundabout are needed . I think peak time traffic signal control should be a commitment within the Strategy timescale.
SCDC Response: 4, 12, 22, 26
IPSWICH POLICY AREA
Respondent Name: Mr Harry Pynn [273] Submission Agent Respondent ID: 273 ID: 273 ID: SUBMISSION The preferred option for the Ipswich Policy Area has a number of drawbacks that are better addressed by alternative sites. In particular the proposals have a significant impact on the quality of life for existing local residents.
The impact includes: * Significantly increased traffic causing gridlock. Grange Farm has terrible congestion already, the same will happen east of the A12. * More competition for jobs when the number of employment opportunities is decreasing. * Destruction of existing vibrant communities of Waldringfield and Martlesham Heath. * With a standalone development more new infrastructure such as schools will need to be built. This is more costly than adding to existing infrastructure. The country's debt burden will make funding this very difficult. * The development would effectively mean that there is a conurbation from Ipswich to Melton causing communities to lose identity. Residents do not live in rural Suffolk because they like built up areas. They live their to enjoy the beauty and freedom of the countryside. A conurbation will make it easier to fill in areas between the A12 and Ipswich because all the surroundings will be built up. * The proposed site is close to the SSI at Waldringfield Heath crossroads, significantly impacting wildlife and human enjoyment of the countryside. * Waldringfield already suffers from far too much traffic on a narrow road. This problem will be exacerbated.
SCDC Response: 4, 7, 13, 16, 18, 19, 20
5 HOW HAS THE HOUSING DISTRIBUTION BEEN DRAWN UP? AND HOW AND WHY HAS IT CHANGED?
Respondent Name: Mr Harry Pynn [273] Submission Agent Respondent ID: 273 ID: 273 ID: SUBMISSION The national requirement for our District's allocation of housing should not go unchallenged. While there may have previously been a short term demand for housing, the government projections for housing in our area do not take into account any decline in demand. The fallout from years of economic overindulgence means that many migrant workers have now left the country. BT (a major employer in the area) recently announced 15000 job cuts this year on top of the 15000 job cuts last year. Not only do we have a large surplus of rental accomodation in the area, but a high proportion of the recently built flats in Ipswich are also empty. By allocating land for future housing while leaving existing housing stock unoccupied paves the way for creating ghost towns and ghettos.
SCDC Response: 3, 7
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Harry Pynn [273] Submission Agent Respondent ID: 273 ID: 273 ID: SUBMISSION The proposal for the east of A12 development claims that it will be "closely linked to the existing and proposed employment retail and social provision at Martlesham Heath/Adastral Park business centre". Given that residents of the area already occupy the existing jobs available, new jobs will have to be created to provide employment for the residents of the proposed 2000 homes. BT would have you believe that new businesses on Adastral park will provide this. However employment at Adastral park is significantly decreasing at present. The main BT spinout companies are in decline. One of the two still trading has reduced their presence on the park by 90%. BT itself is consistently cutting jobs as it struggles to replace the business it once had from fixed line telephony. Additionally, new businesses are reluctant to move to Adastral park because the rents are 3 times that of elsewhere. Much as people would like to, it is not easy to foster innovation parks. Look at the aborted IP1 innovation park at Copdock and the IPCity building for examples of the difficulties here.
SCDC Response: 7
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Harry Pynn [273] Submission Agent Respondent ID: 273 ID: 273 ID: SUBMISSION 5.17 "...creating a stand-alone community" is inconsistent with 5.19 "All of these options however were rejected in favour of a Preferred Option dispersed strategy of "organic and evolutionary growth".
The arguments here are contradictory. Clearly there are certain parties with unwarranted influence on the planning process otherwise planning policy would be consistent across the district.
The creation of the local development framework for the Ipswich Policy Area is being driven by the plans of a large corporation with little notice of the views of local people. Local residents showed most support for pepper potting if there has to be any development at all.
By crossing the logical boundary of the A12 sets a precedent where creating a massive conurbation to the east of Ipswich.
SCDC Response: 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Ian Johnson [230] Submission Agent Respondent ID: 230 ID: 230 ID: SUBMISSION Local Development Framework Consultation
Objection
Dear Mr Ridley
I write in response to the invitation to express an opinion of the preferred option for housing in the district.
Having reviewed 100's of pages of consultation and analysis I believe that should the council approve this plan they will have neglected their duty to the current generation and to the future generations.
Suffolk Coastal is a rural district and its virtues should be protected, not plundered with the building of a new town. To allow the building of up to 3500 new homes on good farmland on one site to the east of the A12 (land belonging to BT) is a scale too great for the landscape and infrastructure to cope with.
Congestion. B.T. clearly states (application C09/0555) that the houses come first and the development of businesses come when the economic climate allows. It also identifies that only 3% of the workforce lives within 1 mile of their workplace. With Martlesham heath on its doorstep and houses regularly for sale this situation is by choice not forces and is unlikely to change in the future. The occupants of the new town will have to commute back across and down the A12. Congestion on the Black Tiles roundabout and 7 Hills are indicators of the misery that more meddling with the roads will bring on drivers and this fact is supported by the Transport appraisals carried out in aug 2008 and sept 2009. Transport predictions already state that traffic on the Orwell Bridge will exceed capacity by 12% in peak hours by 2021 without considering the impact of this option. The increased use of 'C' class roads by drivers trying to escape the traffic jams will lead to more accidents. From personal experience business is already citing congestion on the A12 close to Martlesham Heath Industrial estate as a reason not to stay or relocate there. You will exacerbate this situation by building a new town next to it! Schools. In particular the need for a secondary school is not fulfilled by this development because all studies point to the need for 5000 new homes to make this viable. Bussing and taxis to under utilised resources in the west of Ipswich and Felixstowe is bad for kids their parents and the environment and certainly does not fulfil the sustainability criteria. Water treatment works. Anglia water has no plans to build a new treatment works that a development of this scale would require. Either developer funded or late delivery begs the question as to what guarantees are in place to ensure that pollution to the local estuaries of untreated discharge will not occur. Electricity supply. Unless the developer funds a new substation (and this can only be done after a new one is built for Felixstowe) the pressure on the infrastructure could lead to power failure. Community. In the Ipswich Policy Area - East of A12 you have created a circular argument by stating that a larger allocation (of housing) provides the basis for a significant improved range of community facilities. These facilities would only be required if the 'town' was built. 'The land is zoned for mineral extraction.' By law it would have to be returned to farmland after extraction and mineral extraction is not a permanent feature like a new town. The current extraction generates a small increase in traffic and mined land is being returned to heathland. By their very nature mineral extraction is low level and not up to six storeys high as proposed by the BT application. The council in it's appraisal of housing needs mentions the dire lack of affordable homes, yet the BT application and the appraisal for IPA does not specify that 1 in 3 homes should be affordable as per national planning guidelines. Greenspace. The council has made a circular argument by suggesting that the building of dwellings on BT land will allow greater access to the heathland and the AONB via the provision of cycle paths and public footpaths. This area is well serviced by footpaths currently and in the absence of another 2000 homes will continue to do so. In fact in the eastern fringe infrastructure study the authors make it clear that the amount of space per adult as recommended by Natural England could not be met under any circumstances and that human pressure may put such pressure on the biodiversity that some species will decline. To build a new town within 400 metres of the AONB will cause a retreat of the biodiversity that such an area was created to protect.
SCDC Response: 7, 9, 13, 17, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Ian Kay [282] Submission Agent Respondent ID: 282 ID: 282 ID: SUBMISSION Dear Sir/Madam, Re: LDF Core Strategy and Development Management Policies Housing Distribution Updated Preferred Option 7/09 I am writing in response to the consultation request for the document above.
Summary
I strongly object to the increase in the IPA housing numbers from 1,050 to 2,000. No justification has been provided for this increase, which will make all the problems caused by the proposed development at Adastral Park even worse. This proposal will result in a totally inappropriate, highly urbanised town which will overwhelm the local communities. It will massively increase road congestion, damage nearby environmentally sensitive sites and destroy a beautiful rural landscape. The evidence documents are full of inconsistencies and omissions. They do not provide any real evidence to support the increase in housing numbers proposed.
Detailed Comments Q1: do you think that the reasons behind the changes are justified? No, they are not justified. The reasons given for the increase in housing numbers are: * "A larger allocation provides the basis for a significantly improved range of community facilities" (§6.03, response to IPA comment 2). However, the only reason these improved facilities are needed is to service the needs of the occupants of the 2,000 houses. If 10,000 houses were built, even more community facilities could be provided, but this is hardly an argument for building 10,000 houses! A genuine need has been identified for only 1,050 houses, there is no reason to go above that figure. * "The evidence suggests that the benefits do indeed outweigh the disbenefits." (§6.03, response to IPA comment 2) What evidence? No evidence has been provided of benefits from increasing the number of houses. On the other hand, there are many disbenefits, such as damage to environmentally sensitive areas, overwhelming local communities, more traffic congestion and greater problems in providing secondary education. All of these are made much worse with 2,000 houses than 1,050. * "[a larger allocation] triggers the need for additional infrastructure, particularly secondary education" (§6.03, response to IPA comment 3). As with the issue of community facilities, this is a circular argument - the additional infrastructure is only needed to service the needs of the extra houses. With a dispersed housing allocation, the need for additional infrastructure, particularly in secondary education, would be much less. However, it turns out that even the 2,000 houses proposed aren't enough to justify a new secondary school, they simply make the current school capacity problems much worse (see response to the Future Secondary School Provision Alternative Sites Assessment). * "It also offers the opportunity to better mitigate the potential impact of visitors and residents on the neighbouring countryside and estuary ..." (§6.03, response to IPA comment 3) It is ridiculous to argue that more houses will have a lesser impact, even with 'mitigation'. No 'mitigation' is possible which would prevent or even deter people from visiting the neighbouring countryside. All the ideas suggested in the Appropriate Assessment are totally unrealistic (see response to the Appropriate Assessment) * "the impact of 2,000 homes as opposed to 1,000 on individual junctions etc when linked to new and improved transport infrastructure is limited but will help to secure the necessary developer funding to secure these upgrades to a good standard" (§6.03, response to IPA comment 5) The impact of doubling the number of houses will be to roughly double the impact on the road system. This is confirmed by the two Transport Appraisals (see response to the Proposed Strategy Transport Appraisal). This is not a valid justification for increasing the housing numbers - developer funding to 'secure these upgrades to a good standard' can be demanded no matter how many houses are proposed: more housing = more traffic = more developer funding to 'mitigate' the damage.
None of these reasons are genuine justifications for increasing the housing numbers to 2,000. Several are self-justifying, circular arguments, and none are supported by evidence.
Q2: do you think that the reasons behind the changes ... will ensure that the broad strategy that you have already commented, and which has achieved a large measure of agreement, will be better met as a result of these changes? The only 'large measure of agreement' that has been achieved so far is agreement among local people that this strategy will be a disaster for the area! The consultations so far have been a farce - essential evidence hasn't been made available beforehand, people's responses have been summarised and collated into bland overarching statements that lose all the original points, and people's views have been completely ignored (i.e. the points that have been made have not even been responded to, let alone influenced SCDC's thinking).
I assume the question you really intend to ask is: "do you think that the broad strategy will be better met as a result of these changes?" My answer to this question is an emphatic 'No'. The broad strategy is misguided and will do irrevocable damage to the area. Increasing the housing numbers will simply make this worse.
Comments on Suffolk Coastal District Council Local Development Framework Housing Allocations - Proposed Strategy Transport Appraisal - September 2009 The overall conclusion that "no over-riding concerns have been identified" (§8.7) is not borne out by the document. There are simply too many omissions to make this conclusion valid. The document doesn't provide any data on: * the Orwell bridge, which is already a major bottleneck at peak times. * the A12/Barrack Square (BT) roundabout. This is the central junction onto the A12 from the proposed site, and is likely to take a large proportion of the traffic. * the road into Waldringfield. This is often congested, without the extra housing. It is single track in places, with no pavements or street lighting, and it cannot be widened. It is inevitable that congestion will increase further with 4,800 people living 1.5 km up the road. * the use of Newbourne Road (from the Waldringfield Heath crossroads to the Red Lion at Martlesham) as a rat-run to avoid congestion on the A12.
Another serious omission is the absence of any data on road safety.
The document fails to answer the question "what is the impact of 2,000 houses at Adastral Park, compared with 1,050?" which is what I thought its purpose was. The only way to find this out is to compare the traffic data from this document with the equivalent from the Transport Appraisal, Aug. 2008. This reveals that there is a 106% increase in daily traffic (1087 trip for 1,050 houses, 2240 trip for 2,000 houses). This is in stark contrast to the statement in the LDF that: "the impact of 2,000 homes as opposed to 1,000 on individual junctions etc when linked to new and improved transport infrastructure is limited" (§6.03, response to IPA comment 5)
Comments on Future Secondary School Provision: Alternative Sites Assessment Ipswich Policy Area The figures provided in this document do not make sense, and aren't backed up with any evidence.
The apparent number of houses (5,000) needed to justify a new secondary school is questionable (§3.2.3). No evidence is given to convince the reader that 5,000 is the correct number (it is almost certainly too low, as it corresponds roughly to 500 pupils, which is a very small school). Similarly, the apparent shortfall (translated into houses) is stated as 1,500 without any supporting evidence. Even if these figures were correct, there would still be 1,500 houses less than the 5,000 needed to justify a secondary school.
Comments on the Sustainability Appraisal The conclusion is that "The sustainability of the new policy is higher than the previous version ... Concentrating development in the IPA is considered a more sustainable strategy" (§2.2). No real evidence is supplied to support this conclusion. It is based mainly on the dubious presumption that 'mitigation' will solve all the problems. It is not supported by other parts of the document, e.g. "The new policy is marginally less sustainable" (§2.4).
Comments on the Appropriate Assessment The conclusion that: "it is unlikely that visitor recreation activity would substantially increase on the foreshore of Deben Estuary SPA at Martlesham, so there is expected to be no new high levels of disturbance" (§6.2.35) is contradicted in other part of the document. For example: "It is therefore possible that visitor recreation activity would substantially increase on the foreshore of Deben Estuary SPA, bringing in high levels of disturbance to what is currently little disturbed and a 'refuge' area for SPA qualifying birds." (§6.2.32)
Mitigation is used in various placed to get around the problem. The mitigations seem to be: * The houses will be more than 1km from the Deben Estuary What is so significant about the distance of 1km? People are very likely to travel the extra 0.5km to take advantage of an attractive riverside location * Greenspace will be provided as an alternative attraction. However, no greenspace that is likely to be provided will have a large water area comparable to the river Deben.
The inadequacies of this document are exemplified by the ludicrous claim that the lack of public parking at Waldringfield will mean the visitor numbers will not increase significantly. (§6.2.37). If that were the case, there wouldn't be any current visitors to Waldringfield or the river, as the public parking was removed several years ago.
A serious omission of this document is that the impact of boating is not considered. It is very likely that with so many people living just 1.5km up the road, the number of people using the river for water sports, power boating, sailing, fishing and canoeing will increase dramatically. It is acknowledged that boats are a problem: "On one estuarine site, disturbance to birds from boats was thought to be the biggest problem" (§5.5.6). However, no attempt is made to discover the extent of the problem, and by how much it will increase due to the new housing
SCDC Response: 1, 4, 9, 10, 11, 12, 13, 16, 17, 18, 19 Other comments noted
2 THE CONSULTATION IN BRIEF
Respondent Name: Mr Ian Stockley [372] Submission Agent Respondent ID: 372 ID: 372 ID: SUBMISSION Martlesham Heath retains a wonderful village atmosphere and community spirit. This is endangered. Already the Martlesham A12 cannot cope. The infrastructure of Doctors etc are stretched. Adding ridiculous numbers of housing units, when so much property in wider area lies empty will be an enviromental and social disaster and would have an irreversible impact as a legacy. To increase housing you should 1) rent empty properties 2) convert properties into smaller units. Of course, the council would not benefit so much financially from builders. This seems key issue for council, when quality of life and environment should be the priority.
SCDC Response: 13, 17, 18, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Ian Videlo [365] Submission Agent Respondent ID: 365 ID: 365 ID: SUBMISSION I am OBJECTING to the LDF Core Strategy Updated Preferred Options.
SUMMARY The updating of the LDF Strategy is based on "1,000 is insufficient to provide a standalone Community". ONLY ONE comment to this effect was received, and that was ON BEHALF OF THE LANDOWNER.
Increasing the allocation at Adastral Park is counter to 4.02 ... "where most people already live and work, ...". The site at Adastral Park has been in decline over recent years - I am not convinced the overall level of employment will increase significantly even with an innovation park. Locating houses here in anticipation is a high risk strategy.
Secondary education locally will be adversely affected.
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My specific objection is to the proposal to substantially increase the number of houses at Adastral Park from 1050 to 2000.
I dispute the assertion that the changes in this version of the document will ensure that the necessary broad housing strategy for the District will be better met as a result of these changes. 4.01
The primary reason for increasing the numbers since the previous study is given as based on feedback that "1,000 is insufficient to provide a standalone Community". [Ipswich Policy Area - East of A12 - proposal to increase the numbers Comment #2]. It is being economical with the truth to hide that fact that only one respondent made this comment, and that was David Lock associates on behalf of the landowner (BT). Moreover it is asserted that there is evidence to demonstrate the "benefits do indeed outweigh the disbenefits."
Where is this evidence? I can not think of any significant benefits, but several disbenefits such as Urbanisation of a rural area Destruction of local communities Impact of additional traffic on the roads Damage to environmentally sensitive areas nearby, and the wildlife they protect
Moreover, SCDC's support for this position is in stark contrast to the arguments previously used to justify a single site of 1,050 houses, which apparently was needed to create a sustainable community. No mention had been made previously that 1,050 would not be enough. No explanation has been given as to why 1,050 houses were considered sufficient to create a sustainable community in 2008 but now 2,000 are needed.
4.02 - justifies larger settlements what places where most people already live and work - and where facilities and services are concentrated.
The justification for Adastral Park growing to 2000 seems to be on the assumption that Adatral Park will become an innovation hub with 2000+ new jobs created. In reality Adastral Park is in decline, and has been so for some years. Major employers such as O2, and educational establishments UCL have only recently substatially reduced their presence on the park - hardly a show of confidence in a promising future.
Puting as many as 2000 new homes into an area remote from the larger towns ofIpswich and Felixstowe, and onward road and rail conections without any proven new employment infrastructure is a very high risk approach. This is not prudent.
Similar problems seem to be occurring at Rendlesham where local job growth has not matched the influx of population leading to mass commuting and accompanying traffic congestion.
Education From an educational viewpoint - spare capacity for secondary school age children in the East Suffolk area is on the Western side of Ipwich, not in the East, Local schools (Kesgrave & Farlingaye) are already overstretched, and the prospect of further poplation will only further exacerbate the situation. 2000 houses will not provide sufficent justification to provide a new secondary school - so the problem will lead to children travelling further to school. This is hardly a sustainable outcome.
No meaningful study of the educational impact beyond primary school ageseems to have been conducted. The one study published [Future Secondary School Provision: Alternative Sites Assessment Ipswich Policy Area - June 2009 Report by Colin Buchanan and Partners] is narrow in brief and compares the suitability of 3 potentiaol sites for a new build secondary school. However, given that the numbers will almost certainly not justify a new build, then this was at best a hypothetical study, and at worst missed the opportunity to consider realisitic options and solutions.
SCDC Response: 4, 7, 11, 16, 17, 18, 19, 20
8 YOUR COMMENTS
Respondent Name: MR IAN WHITE [96] Submission Agent Respondent ID: 96 ID: 96 ID: SUBMISSION THE 2,000 HOUSES PROPOSED FOR MARTLESHAM HEATH:
* VEHICLE & NOISE POLLUTION WILL INCREASE SUBSTANTIALLY.
* INSUFFICIENT ACCESS FROM THE DEVELOPMENT WILL CONGEST THE FOOTPATH AND ROAD ACCESS IN AND OUT OF THE HEATH.
*THERE WILL NO INITIAL PROVISION FOR SCHOOLS, DOCTOR'S SURGERY, WHICH WILL PLACE A SEVERE STRAIN ON THE CURRENT FACILITIES.
*EMPLOYMENT - WHERE WILL THE JOBS COME FROM IN THE FUTURE, BT, THE DOCKS, RETAIL? NO THESE ARE CUTTING BACK NOW.
*UTILITIES, GAS, ELECTRICTY & TELEPHONES WILL REQUIRE A DRAMATIC INCREASE. WHERE ARE THESE ON THE PLAN?
OVERALL THIS PROPOSAL SEEKS TO CHANGE MARTLESHAM HEATH FROM A SEMI-RURAL COMMUNITY INTO AN URBAN SPRAWL.
SCDC Response: 7, 18, 19, 20
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mr J Hall [456] Submission Agent Respondent ID: 456 ID: 456 ID: SUBMISSION We are in the process of buying a house at Tree Tops. I feel the land is totally unsuitable for so much building. it is a green site. not a brown site.
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr J R Hubbard [106] Submission Agent Respondent ID: 106 ID: 106 ID: SUBMISSION SUFFOLK COASTAL CORE STRATEGY & LDF AREA 4 MARTLESHAM - J.R.HUBBARD FRTPI Rt
The consultation process has so far failed to recognize the overwhelming local concern and opposition to the 'preferred' Option 4. Furthermore, no explanation has been given to the abandonment of existing key policies in the Suffolk Local Plan 1991 which was approved after lengthy detailed examination. The consistent application of these policies which has received general public support has been largely responsible for the protection and enhancement of the rural environment, in accord with the declared objectives of the Local Plan.
Insufficient attention so far appears to have been given by the Council to identifying and evaluating the many environmental issues which need to be addressed before any final commitment to promoting Area 4, in order to provide the necessary basis for assessing the extent of the measures which will be required to be implemented in respect of such a large scale development, and the real cost to the existing community in social and financial terms. The environmental study should include an in depth study of the increased traffic implications and a detailed implementation programme for the implementation of the necessary improvements to the existing road network.
The calculations for projected housing need over the next 15 years accepted by the Council as recommended in the Regional Strategy deserve further scrutiny and need to be regarded as flexible having regard to the uncertainties of forecasting future net immigration levels, demographic variations and the extrapolation method used. The future status of Ipswich Borough Council seems likely to become an enlarged Unitary Authority encompassing the Martlesham area. It appears logical in all the circumstances that there should be no final planning commitment to Area 4 before total agreement has been reached on the Borough's own LDF proposals for the period ending 2025.
Waldringfield village is already struggling to preserve its exclusive identity and maintain the right balance between the highly rated residential environment and increasing recreational demands associated with the riverside attraction. Any dilution of current restrictive planning policies would be likely to lead to catastrophic consequences to the village and the surrounding rural area.
The response to the first consultation is still valid. The revised intention to double the size of the development adds even more substance to the objections raised, and illustrates that once the principle of breaching the A12/A14 with new housing is accepted, there is no limit to its final extent. The responses of Waldringfield P.C. are fully supported. Some of the stated views of Suffolk Coastal's Deputy Leader and Cabinet Member for Planning in Issue 41 of Coastline are seriously questionable. The "informed opinions" which have been presented are far more likely to "safeguard our communities and our valued environment" and "maintain and enhance our excellent quality of life...."
SCDC Response: 3, 4, 16, 17, 18, 19
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mr J Somerville [459] Submission Agent Respondent ID: 459 ID: 459 ID: SUBMISSION The unseemly pace with which this whole alteration to the LDF is being steamrollered through with scant regard for 'other opinion" - be it the County Council, Highways & other adjacent district councils, as well as the total disregard for the views of the affected local communities and residents, simply demonstrates that policy has now been handed by SCDC planners, to one particular developer, whose objectives and with the financial muscle 'to deliver', have been seized upon as an 'easy solution' to a 'difficult' central government directive. To double the previously determined number of houses in one particular location which itself is mostly green agricultural land and to make out that it is all 'sustainable' when that so-called 'sustainability' will all have to be 'created' & 'built-in' - thus only increasing what will inevitably be an environmental disaster for the locality with a huge carbon footprint, is nothing less than a scandal.
At the outset of the worst financial crisis in living memory, with little prospect of recovery within a generation, this change to the LDF is a damning indictment indeed of our so-called 'Planners' judgement. Where are the jobs going to be for the inhabitants of these proposed homes, lumped together in one location rather than in more broadly distributed sites? They cannot be guaranteed 'within' this 'New Town' as is so irresponsibly claimed. Indeed how, without jobs, will the 'intended occupants' be able to buy such housing? Talk about 'cart before horse'! Most of these homes will inevitably not be the 'affordable housing' our rural communities so desperately need.
Future generations will be reaping the consequences, not the benefits of this short sighted and misguided abrogation of duty & an insult to all within the Suffolk Coastal region (& beyond)who will be detrimentally affected, both directly and indirectly.
Please think again before condemning the whole Felixstowe Peninsular to urban sprawl and all its' ensuing environmental, ecological and rural community damage.
SCDC Response: 4, 7, 22, 23
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mr J Stafford [395] Submission Agent Respondent ID: 395 ID: 395 ID: SUBMISSION 7.03 Ipswich Policy Area - East of A12: This is the first proposal I have seen so far that looks a viable proposition. A large development in the Martlesham Area would provide the expanded community with sufficient supporting infrastructure. In particular easy access to the A12, A14, A1214, without the bottleneck problems associated with Felixstowe at the end of the A14.
7.04 As I have stated before, the area of Northern Felixstowe is designated by the authorities as a RADON ACTIVE AREA. As such it is ridiculous to earmark this very area for housing when no such safety risk exists in the rest of the County!
Changes would like made: Housing dispersed across the District based on proven local needs.
7.04 The current Waste Water Treatment Facilities for the Felixstowe Area are operating at capacity level. Further substantial housing would necessitate significant expansion of the current facility and significant additional Sewerage Network capacity. The potential costs and timescales involved are enormous!
Changes would like made: Housing dispersed across the District based on proven local needs.
7.04 Changes would like made: I reject the latest proposals concerning Felixstowe, Walton and the Trimley Villages. I would favour a Core Strategy which through dispersements across the District would reflect proven local needs and not just 'guestimates' of migrant and employment projections.
SCDC Response: 4, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr James Barclay [137] Submission Agent Respondent ID: 137 ID: 137 ID: SUBMISSION Dear Sir
Consultation on Suffolk Coastal Local Development Framework: Core strategy
I have been unable to reply on the web site as it is too complicated and user unfriendly for me but I'm not an expert at web sites. Although I believe I may have logged in, I have been unable to find a way of communicating via the site thus I make some comments here which I hope will be acceptable.
1. One of my main complaints is SCDC's lack of transparency over this major planning issue. A substantial new town is planned in a sensitive site which will have a major impact on the whole of the district and only very few people are aware of it. There are no notices on or around the site and those that were there have blown away many months ago. If you or BT were proud of what you are proposing you would have erected huge drawings and plans etc on the site which could have been seen by passing motorists etc. Instead you have adopted this secretive, even covert, policy. Why?
2. Regarding access to the district, with the expansion of the docks at Felixstowe and possible new development at Kirton, together with the Adastral proposal, we can expect significant increase in the trunk road traffic and particularly the use of the Orwell crossing, a bridge already nearing its capacity. I can find no reference to a study on this aspect or what the solution might be. I can think of only two answers, a second bridge or a northern by-pass. Neither of these option, so far as I am aware, have been discussed or aired in public which is quite wrong which quite possibly jeopardises the whole process on consultation.
3. It seems to me that the thinking is short term and parochial and will result in a mess. The roads are already inadequate (the A12 and A14 regularly have to be closed because of accidents) and the railway is overcrowded at peak times and very busy throughout the day. Even in this recession it is not possible to park near the station after 8.00am.
4. In addition there are too many dwellings too close together in a sensitive location adjacent to SSSIs and an AONB and all on a green field site thus turning a broadly rural area into predominantly urban and suburban.
5. I imagine that much research has been done into the question of sewage/waste disposal, the provision of clean water and of an adequate supply of electricity/gas and oil though I could not find a reference to that aspect. The sewage treatment plant for 2500 families will be a large and unsightly plant which would normally be sited outside the urban and suburban area. But again I have found no reference to this or where it might be located.
6. In conclusion I oppose the concept of building a new town on the Adastral site which will be so large as to impair access to the whole district, reduce the quality of life for those who live in the surrounding villages and effectively urbanise what is currently predominantly an attractive green field and rural area much enjoyed by those who live in and visit it. I sincerely believe that a public enquiry will in due course find against this development and thus a large amount of taxpayers money will have been irresponsibly wasted.
SCDC Response: 1, 11, 12, 13, 16, 17, 18, 19, 20
8 YOUR COMMENTS
Respondent Name: Mr James Brinsley [391] Submission Agent Respondent ID: 391 ID: 391 ID: SUBMISSION I wish to object to the proposed new town on the land owned by BT Adastral Park at Martlesham.Any such development of such a scale will urbanise,inconvenience and completely destroy a beautiful, rural and thus far,treasured corner of Suffolk, the very county you have been commissioned to nurture, protect and treat fairly it's residents. Such a development , if approved, will annihilate all Suffolk Coastal Council is supposed to represent and betray any future trust it's residents may have had.
SCDC Response: 16, 17, 18
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Mr James W Barter [149] Submission Agent Respondent ID: 149 ID: 149 ID: SUBMISSION SP20: SA1 is to improve the health of the population overall. The development of the area east of the A12 at Martlesham Heath will have a detrimental effect on the health of the existing population, especially those living adjacent to the A12. The increase in traffic and the replacement of the roundabouts with traffic lights will considerably increase the noise and air polution, already at a high level. Traffic congestion is already high at peak times, this can only get worse. SA5: Public transport provision has always lagged behind new housing developments, both at Martlesham Heath previously and Rendlesham nowadays.
SCDC Response: 11, 13, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr James W Barter [149] Submission Agent Respondent ID: 149 ID: 149 ID: SUBMISSION The doubling of numbers will increase the pressure for provision in Phase 1. These 5 years will be a nightmare for residents of Martlesham Heath and Waldringfield, with the provision of new waste water treatment, new electricity sub-station, and changes at the three road junctions. In the early stages the community facilities of Martlesham Heath will bear the brunt of the demands arising from the new housing, stretching these to the limit. Eg, our current ability to obtain a same-day appointment at the surgery will go. The size of this development will reduce the quality of life of all who live here.
SCDC Response: 16, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Jeremy Wilson [222] Submission Agent Respondent ID: 222 ID: 222 ID: SUBMISSION My wife and I are residents of Martlesham Heath Village since 1989. We have two children of school age and wish to express our views on the "Updated Preferred Option 7/09 housing distribution".
Traffic Impact To build new housing to the east of the A12 on land adjacent to the existing Adastral Park or on land already occupied by Adastral Park would increase the traffic on the A12 to gridlock status for large parts of the day. I myself do not drive to work but my wife is not in that happy position. When driving onto the A12 from Martlesham Heath Village at the Adastral Park roundabout, it can sometimes take up to 15 minutes to join the A12.( The existing public transport system has limited ability to ameliorate this situation.) Adding substantially more traffic will make the A12 impassable. The suggestion of "improvements" to the A12 is unrealistically optimistic. There is no scope to substantially widen the carriageways on their passage between Martlesham Heath Village and Adastral Park without the destruction of large numbers of buildings. Presumably the destruction of houses in Martlesham Heath Village would be counterproductive. Even if this option were to be taken then this would increase the noise level to an extent that would seriously degrade the quality of life for local inhabitants. It should also be borne in mind that the A12 is a major arterial route for East Anglia and if the economy of the region is to grow, then the long distance commercial traffic on the road will also grow giving yet another source of pressure.
Impact on Local Schools At present because of other recent building development in Kesgrave, the need for places in the local schools has increased to such an extent that many people who live in the catchment areas for primary schools and secondary schools are being denied places for their children at these schools. (This means that children are unable to walk to school or bike as many of the local children do at present again increasing road traffic.) This large number of houses suggested in the document for the site east of the A12 will again tax the local educational provision. It will no doubt be said that developers will be obliged to provide new school provision but this presumably will not include a new sedcondary school and the bitter experience we have had in the area is that this has always been said in the past and yet with each new development the overcrowding has increased, such overcrowding being evidenced by Portakabin classrooms in some school playgrounds.
Recreational Land Martlesham Heath Village has both natural woodland and natural heathland, which at present is managed by the residents of the village and maintained to a high standard. Part of the heathland is designated as a SSSI and has unique wild life features. A substantial increase in housing will inevitably impact on this. If for example another bridge for pedestrians and cyclists were built over the A12, then both the woods and the heathland would become a through route and its unique character would quickly be changed.
Health Care Again the local primary care service is overtaxed. The Martlesham Heath Surgery is sometimes unable to take new patients even though they live in Martlesham Heath Village.
Public Transport If a sustainable local population is to develop and a new development is to be anything but a dormitory area, it is essential to have good public transport so that those who do not own cars and are unable to drive can for example travel into Ipswich or Woodbridge. Public transport provision has been cut recently and I see no sign that this is likely to change.
General Comments The philosophy of where to place new housing is that areas should be used which are already "developed" and where facilities already exist. However, as a resident of Martlesham Heath Village I am confident that the capacity of existing facilities has already been exceeded. Educational, health and transport facilities are already overstretched.
SCDC Response: 11, 13, 16, 17, 19, 20
2 THE CONSULTATION IN BRIEF
Respondent Name: Mr John Arkwright [450] Submission Agent Respondent ID: 450 ID: 450 ID: SUBMISSION We support SP2. Its approach, designating the East of ipswich area is consistent with the policies of the East of England plan.
SP3. We welcome and support the inclusion of Martlesham within the area East of Ipswich. Referring to SP3.320 we welcome the Council's preferred option for creating a new community/neighbourhood alongside the existing community of Martlesham.
Site 650 provides a good opportunity to deliver housing or related development to assist realising the new community neighbourhood at Martlesham.
Site 650 relates well to the proposal for Adastral park.
We would be grateful if the Council would consider the position of the boundary line of the proposed expansion of the community/neighbourhood area in the knowledge that this site is being put forward for potential development.
Representing the Brittain family, as agent, John Arkwright and Co are supporting Site 650, Walk Farm, Martlesham as suitable for development in the proposed LDF.
We attach a site plan indicating the boundaries of the site, edged in red with the letter dated 27th April 2006 from peecock Short to Stephen Brown, Develoment Plan Manager of Suffolk Coastal District Council. Peecock Short were acting for the Brittain family. We are now acting and therefore this is a continuation of the representation made by Peecock Short. please note that, Walk Farm Cottages, included in the site plan/Site 650, are not within our clients' ownership, nevertheless, we are including this in our comment.
The site is presently mixed/poor quality woodland, close to the Tesco superstore and other commercial development as well as The Falcon Park mobile home park. The subject land is presently uneconomic and unproductive with security issues. in view of its proximity to urban development under pressure to expand, we consider that development of the site, either in part or as a whole, would be suitable.
We suggest that potential uses include residential, industrial, retail or commercial, possibly as an extension of Martlesham business Park. the site may be suitable for permanent residential mobile home or recreation use.
We would be pleased to discuss the site with the Council to bring it forward for economic use
SCDC Response: Support and site comments noted
IPSWICH POLICY AREA
Respondent Name: Mr John Forbes [462] Submission Agent Respondent ID: 462 ID: 462 ID: SUBMISSION Although I am on Martlesham Parish Council, this response is from me personally and not as a representative of Martlesham Parish Council. I agree with the points raised by MPC but feel that some points need to be added or emphasised.
Climate change can be reduced by adopting certain planning principles and rigorously enforcing them.
1. Transport causes much emission of carbon dioxide into the atmosphere. Therefore any proposed development needs to minimise the need to travel especially by car. Any development of more than, say 10 houses, needs to be within 5 minutes walk of a railway station. If no station is nearby, then its provision needs to be a precondition of planning consent. It follows that suitable house development sites will have to be near the Ipswich lines to Lowestoft and Felixstowe. Blob 1 (Westerfield) or blob 5 (Purdis Farm/Nacton) would be less bad if a large development continues to be recommended partly because they have direct or potential rail access. 2000 houses at BT would greatly worsen the A12 traffic problems which have not been properly investigated or solved. If an Ipswich Northern by-pass is to be re-considered this would make congestion problems through Martlesham much worse. The proposed extra housing is premature until congestion problems of the A12, A14 and the Orwell Bridge have been solved. Whether or not 2000 houses are built in Martlesham, it would help congestion, and reduce CO2 emissions, if a railway station were inserted in the village. There is an obvious place for it.
2. Energy source. Wherever the site(s) are, they need to be as nearly self sufficient in energy as possible. Again there needs to be a preplanning condition that energy needs are provided on site from renewable sources e.g. wind turbine. If that is too inconvenient or expensive, then planning permission should be refused.
3. Infrastructure. The word includes many things - Roads, railways, utilities, schools, heath services, shops etc. These tend to grow with development if house building is not too fast. 1% p.a. should be the maximum considered. There are 2200 houses in Martlesham, so any proposals should not exceed 22 houses p.a. 1% throughout the Ipswich Fringe would seem to provide the numbers required. A dispersal policy would be much fairer and less destructive of existing villages. I have previously shown how this could be achieved in Martlesham (see comments dated 1/11/2008)
The present local schools (primary and secondary) are at or near capacity. I am concerned that future provision has not been thought through. When we were shown around the BT site SCDC officers showed us where a secondary school site could be provided at one of two treasured green open spaces in Martlesham. This is not the way to plan for the future and shows that other parts of Martlesham are also at risk if 2000 houses are to be built around BT.
Nationally it is better to put houses where infrastructure already exists e.g. in the North East, rather than try to get it put in as a planning condition or worse still, fail to get adequate infrastructure.
Comments about page 8 of the document. Housing development without car ownership facilities is possible and desirable. Brighton Corporation do it.
If land outside existing village envelopes is to be allocated for housing it should all be affordable. If BT want housing they should give the land to the Housing Corporation. I presume the BT are using their big corporation power and influence to get housing permission to make lots of money.
Any planning applications submitted before the LDF process is complete must be refused as premature.
Most of the land around BT is used as sand and gravel quarries. Planning permission for quarry use includes a condition that the land has to be returned to agriculture when the sand and gravel is exhausted. It is not a brownfield site and needs to be on a par with other high grade agricultural land.
The proposed housing allocation for Felixstowe and Trimley was drastically reduced after local criticism. Those criticisms apply equally to Martlesham. Port jobs depend on port location. IT jobs can and should be anywhere where there is renewable energy and telephone links.
Because of the Greater Gabberd wind farm and/or Sizewell power stations and existing rail links, Leiston and Saxmundham are more suitable for 500-1000 houses. Areas close to the 400Kva national grid electricity may well be suitable for IT jobs and a few houses to keep rural villages alive.
Most of the Felixstowe Port traffic needs to go by rail as promised at the port expansion enquiry. Cross country rail links need to be improved as a much higher priority. The Beccles loop also needs to be a very high priority to enable more frequent trains to run on the line. The cost of these can be paid for by appropriate developers. These rail improvements need to be in place before occupation of the planned buildings.
Living closer to work and working from home are good principles to reduce travelling but no-one seems willing to take the simplest of measures to encourage this; e.g. Every job application could include the question 'Are you able and willing to live within walking or cycling distance of work?' and every job advert should state convenient arrangements for home working, not compulsion but sensible encouragement. There is no guarantee that dwellings close to BT will be occupied by local BT employees.
SCDC want a 'stand alone' development to get the infrastructure. This has not worked in the past and could be made to work just as well on smaller developments. Small scale developments are much better for 'social integration'. BT is very exclusive and would get much worse with the SCDC proposal. On page 20 refers to the BT option for 2000 houses but also say this is not collusion with BT but that is what it is.
2000 houses in one place would create a separate town which would not encourage integration with existing communities.
Houses around BT in a doughnut plan would restrict future expansion of BT industrial/research space. This is short-term thinking and bad planning.
The proposed development would be very close to the AONB and would inevitably put undue pressure on it (cars, people and dogs).
Developing on BT land is between 15 and 40 years premature because the sand and gravel needs to be fully extracted at a slow rate and the site restored before any houses would be occupied.
SCDC should also adopt the Merton rule so that it can insist on higher building standards for insulation etc. than in the building regulations and not tody to developers.
The points in the Martlesham parish Council response to the BT planning application need to be taken into account. They express the local views of the BT proposal or any other housing development in that location.
I have a personal plea that any new house should only be served by underground cables, not overhead. This is for appearance.
It should be remembered that economic growth = more CO2 emissions and faster climate change.
SCDC Response: 4, 7, 11, 12, 13, 17, 18, 20, 22, 24 See DM24 Sustainable construction Other comments noted
1 INTRODUCTION
Respondent Name: Mr John Harbridge [107] Submission Agent Respondent ID: 107 ID: 107 ID: SUBMISSION By finalising the core strategy document ahead of the Site Specific Allocations this consultation is seeking agreement to housing allocations with very little indication of of where these houses will be built. Earlier consultations have received comments about various possible sites for housing but there is no indication that account has been, or will be, taken of these comments. Once the Core Strategy has been approved permission for any development that meets the vague criteria could then be given on the grounds that it complies with the Core Strategy.
As an example, Para 7.04 states that greenfield allocations for Felixstowe, Walton and the Trimley vilages will be "land within and immediately abutting ... Felixstowe, Trimley and Walton" This could be almost anywhere. Some broad policy statements would be useful, for example: 1. Whether or not Trimley will be allowed to merge with Walton. 2. If The Grove and Eastward Ho will definitely not be developed (The Entec report showed these areas as top ranking sites; numbers 73-76) 3. If land north of Links Avenue/Upperfield Drive would be considered for development.
To reach any agreement that large numbers of houses should be built in a district without indicating where they would (or would not) go does not allow the full impact of that decision to be assessed.
SCDC Response: 4 Sites comments noted
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mr John Harbridge [107] Submission Agent Respondent ID: 107 ID: 107 ID: SUBMISSION Whilst welcoming the reduction in the number of houses proposed for the Felixstowe peninsular I think that it is still too many. The sea, rivers and adjacent AONB enclose Felixstowe; policy should not be to develop the rest of the area. Access to Felixstowe is limited to a single road, at times highly congested, closure of which (e.g. by accidents) could cause problems for emergency services access. Further development with a resultant increase in traffic will further exacerbate this problem with potentially serious consequences. Felixstowe & The Trimleys is already a viable community able to support a multitude of local services, the figure of 1000 minimum extra houses (Appendix 4, Table1) on greenfield sites appears somewhat arbitrary and not related to local need. More of the allocation for SCDC should be in towns and villages where there is an established need for more (particularly low-cost) housing and in some cases a requirement for modest growth to maintain the viability of local amenities (pubs, Post Offices etc)
SCDC Response: 4, 12, 22
IPSWICH POLICY AREA
Respondent Name: mr john ogden [147] Submission Agent Respondent ID: 147 ID: 147 ID: SUBMISSION The size and geographical extent of this development is entirely inappropriate to and unsupportable by the local area, infrastructure and adjacent AONB. Arguments that by increasing it in size will mitigate these concerns are entirely misplaced. SCDC should accept that their attempt to take the easy option of riding on a BT-inspired solution is misguided, unsupported by proper planning evidence and process, and unacceptable to its constituents. It also an extraodinarily insensitive intrusion on a delicate and precious AONB that borders on enviromental vandalism. It must not stand and more sensitive piecemeal approach adopted.
SCDC Response: 16, 17
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: mr john ogden [147] Submission Agent Respondent ID: 147 ID: 147 ID: SUBMISSION Doubling the number of houses will NOT mitigate but only exacerbate the impact on and overload of the adjacent AONB and the very limited access and amenities it supports. No amount of 'open dog walking areas' are going to stop the resultant vastly increased numbers of visitors and their cars clogging up our narrow lanes, limited car parking and amenities and very sensitive estuary environment. There must a sensible buffer between this AONB and any more limited urban development that is in keeping with the local area and its limited ability to support such an excessive development.
SCDC Response: 16, 17, 19
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: mr john ogden [147] Submission Agent Respondent ID: 147 ID: 147 ID: SUBMISSION It is erroneous to claim that this is the preferred solution because of employment opportunities, road structure, and the least impact on other individual communities. Evidence would suggest that most of those employed at Adastral Park and neighbouring sites commute in from elsewhere. Local roads, even the A12 and Orwell Bridge, are not even able to sustain traffic flows at peak time now, let alone when another 2000 houses are added. Such a development will have a profound impact on local communities, particularly those such a Martlesham, Brightwell and Waldringfield who are closest to the proposed development. All would be swamped by a development that would rival Woodbridge in size. Finally it is invidious to claim that these are the reasons for the preferred option. The reason is transparently because of BT's plan to sell off and develop land adjacent to Adastral Park. In other words this, rather than any strategically led plan has driven this entirely inappropriate option.
SCDC Response: 4, 7, 12, 13, 16, 18
THE OVERALL STRATEGY
Respondent Name: Mr John Sommerville [467] Submission Agent Respondent ID: 467 ID: 467 ID: SUBMISSION The unseemly pace with which this whole alteration to the LDF is being steamrollered through with scant regard for 'other opinion' - be it the County Council, Highways and other adjacent district councils, as well as the total disregard for the views of the affected local communities and residents, simply demonstrates that policy has now been handed by SCDC planners, to one particular developer, whose objectives and with the financial muscle 'to deliver', have been seized upon as an 'easy solution' to a 'difficult' central government directive. To double the previously determined number of houses in one particular location which itself is mostly green agricultural land and to make out that it is all 'sustainable' when that so called 'sustainability' will all have to be 'created' and 'built-in' - thus only increasing what will inevitably be an environmental disaster for the locality with a huge carbon footprint, is nothing less than a scandal.
At the outset of the worst financial crisis in living memory, with little prospect of recovery within a generation, this change to the LDF is a damning indictment indeed of our so-called 'Planners' judgement. Where are the jobs going to be for the inhabitants of these proposed homes, lumped together in one location rather than in more broadly distributed sites? They cannot be guaranteed 'within' this 'New Town' as is so irresponsibly claimed. Indeed, how, without jobs, will the 'intended occupants' be able to buy such housing? Talk about 'cart before horse'! Most of these homes will inevitably not be the 'affordable housing' our rural communities so desperately need.
Future generations will be reaping the consequences, not the benefits of this short sighted and misguided abrogation of duty and an insult to all within Suffolk Coastal region (and beyond) who will be detrimentally affected, both directly and indirectly.
Please think again before condemning the whole Felixstowe Peninsular to urban sprawl and all its' ensuing environmental, ecological and rural community damage.
SCDC Response: 4, 7, 16, 17, 23
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mr Jonathan Smith [92] Submission Agent Respondent ID: 92 ID: 92 ID: SUBMISSION Regarding the Felixstowe infrastructure study, considering that you want to build a minimum of 1600 homes in the three phases & that most of this requirement will be for "affordable housing" we must consider that the most likely purchasers of such dwellings will be young couples & what do 1600 young couples do best? Well they spurn at least 1600 new children, so how on earth the projected requirments of 116 primary, 40 nursary & 214 secondary school placings in addition to the present requirement was arrived at is beyond me & is simply LAUGHABLE. In addition the extra 4 beds at Ipswich hospital, proposed under the "health" heading, leads me to beleive that your consultants use a dart board to arrive at their conclusions.
SCDC Response: 20
THE MARKET TOWNS
Respondent Name: Mr Jonathan Smith [92] Submission Agent Respondent ID: 92 ID: 92 ID: SUBMISSION Once again the prosal for other parts of the district is non commital & wishy washy, choosing to apply what is still a vastly excessive burden on the Felixstowe penninsulur as oppose to a greater dispersal around the district & the market towns. All the fuss about primary school closures due to falling roles could be addressed if you build a larger proportion of housing in these areas.
SCDC Response: 4
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mr Jonathan Smith [92] Submission Agent Respondent ID: 92 ID: 92 ID: SUBMISSION After all that has been said by way of objections to the joining together of Walton & Trimley St Mary, I am appauled that the proposal focuses on this very stratagy as it goes against the district policy of not merging individual communities into an urban sprawl & is going to inflame the traffic congestion in this area, link road or not.
SCDC Response: 23, 26
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mr Jonathan Smith [92] Submission Agent Respondent ID: 92 ID: 92 ID: SUBMISSION Now we discover that 250 houses an enormous Tesco store, A hotel, a pub & a waste incinerator are waiting in the wings for the field between Walton & Trimley. This area should be left arable, we need none of the above, it would all do untold damage to the area/local small bussiness. Don't target Walton as the area of least resistance, becaause the other areas have STAG & SFC you have proposed Walton as the preferred greenfield option because you think you'll get away with that more easily, well think again.
SCDC Response: 23
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mr Joseph Clark [36] Submission Agent Respondent ID: 36 ID: 36 ID: SUBMISSION The latest proposals in the Core Strategy for housing distribution appear to make no proposals for upgrading the infrastructure. Roads, secondary schools, hospitals, doctor's surgeries, dental facilities and public transport to mention but a few. In the light of the latest, on the hoof, Government policy proposal that 'teenage single mothers be placed in shared hostels'. Will your latest proposals include such a hostel or hostels, with the consequent reduction in the need for affordable housing? Will adult males be banned from such hostels? Who will supervise these establishments? Who will bear the cost of these hostels, local or central government? Where do you propose building the first and subsequent such hostels?
SCDC Response: 4, 20 Please see Objective 3 and Policy SP3 of the Core Strategy which refers to providing for the full range of housing needs within the district.
IPSWICH POLICY AREA
Respondent Name: Mr Julian Page [221] Submission Agent Respondent ID: 221 ID: 221 ID: SUBMISSION The provision of 2000 new homes will change the whole nature of the existing environment. It will have a severe detrimental impact on the existing very successful self-contained Martlesham Heath Village. i.e. excessive traffic and noise; change of a rural landscape to an urban landscape; excessive pressure on existing services until new services are provided which are unlikely to be provided at the same rate as the new housing.
SCDC Response: 16, 17, 18, 19, 20
THE OVERALL STRATEGY
Respondent Name: Mr Julian Page [221] Submission Agent Respondent ID: 221 ID: 221 ID: SUBMISSION The proposed large development East of the A12 will be in contradiction to planning policies as indicated in section 5.10 eg. "New housing should allow integration with existing communities but at the same time should respect and maintain the character of individual settlements." "In deciding where new development should go, it should respect the quality of the local environment" "Building on high quality agricultural land should be avoided as far as possible. " - NOTE just because sand and gravel has been extracted does not mean the land can not be returned to agricultural use.
SCDC Response: 17, 18
BASE REQUIREMENTS
Respondent Name: Mr Julian Page [221] Submission Agent Respondent ID: 221 ID: 221 ID: SUBMISSION Brownfield use is good, but after sand and gravel extraction - as at the site east of the A12 - it should be returned to agricultural use , not used as an excuse for housing development.
SCDC Response: 15 Other comments noted
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Julian Page [221] Submission Agent Respondent ID: 221 ID: 221 ID: SUBMISSION This option may have the least impact on several other communities but it will have a very high impact on a large number of people living on Martlesham Heath as well as others living within at least a 5 mile radius of the proposed development. As a larger development it will have a larger impact and the quality of life for the large number existing local residents will be considerably reduced.
SCDC Response: 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Kevin FISHER [90] Submission Agent Respondent ID: 90 ID: 90 ID: SUBMISSION Ref: - Proposed Development of Area 4, Strategic Housing Growth.
Dear Sir,
I would like to register my objection to the proposed development at area 4, south of Old Martlesham.
You will be aware that the development falls within 60m of an area of Outstanding Natural Beauty. Any development on such a large scale so close to this protected area is likely to have an extremely damaging effect.
The Waldringfield Pit site of Special Scientific Interest will be destroyed and the Deben Estuary, which is a Special protection Area will be placed under threat from the increase in people and traffic.
The local infrastructure, schools, roads and health care will not cope with the increased demands placed upon them.
The Villages of Waldringfield and Newbourne will loose their rural character and become part of the urban sprawl.
I respectfully submit that the proposed area be restored to it's original state of diverse heathland, protecting this special area for future generations.
Yours sincerely
K. Fisher
SCDC Response: 9, 16, 17, 18, 20
IPSWICH POLICY AREA
Respondent Name: Mr Kevin Guy [146] Submission Agent Respondent ID: 146 ID: 146 ID: SUBMISSION During peak periods, turning right on to Main Road from Deben Avenue is virtually impossible and the same can be said for Dobbs Lane; and for exiting Foxhall Road on to the A12. Kesgrave High School is already at capacity, and any further increase will have an adverse affect on results. We have Grange Farm, but a further large scale development in this area would not only lead to traffic gridlock but be an environmental and ecological disaster. BT might be a large employer, but this does not give them the right to impose their wishes on everyone for profit.
SCDC Response: 13, 17, 19, 20
8 YOUR COMMENTS
Respondent Name: Mr Kevin Guy [146] Submission Agent Respondent ID: 146 ID: 146 ID: SUBMISSION I find the Councils fast track, back door approach of trying to double the amount of proposed new homes without proper and timely local consultation not only abhorrent but also surprising not unexpected. We moved here 5 years ago from just outside the M25 where these type of developments were continually being implemented. There were no positives from these, and they only led to more anti social behaviour, traffic choas, and a strain on services. The need for housing is understood, but developments must be in keeping with the surroundings and not to the detriment of the people already living here.
SCDC Response: 16, 17, 18, 19, 20
IPSWICH POLICY AREA
Respondent Name: Mr L Lawley [481] Submission Agent Respondent ID: 481 ID: 481 ID: SUBMISSION As a Martlesham Heath resident I took the opportunity to examine BT's first Adastral park Planning Application because I was concerned about the number of new houses/homes that were to be built. My study of the plans soon revealed that a number of areas had not in my opinion been adequately addressed, the glaring shortfall being the manipulations proposed for the A12 i.e. the road widening and traffic lights scheme, which will be a totally inadequate solution to what is already a daily traffic jam.
I wrote to the Planning Dept at that time outlining my objections to the 1,000+ houses proposed and the inadequate solution to the road problem described above. What I did not do was to oppose in principle the building of new homes by BT on the basis that everyone in UK should have the opportunity to live in a decent house of their choice.
We now have a revised BT plan for what can only be described as a new town.
Once again Bt has spent its money on supportive research and fact finding, using professional bodies and specialist companies, all of whom have submitted interesting data and plans that advocate the benefits' of the project, without examining the very considerable negative effects on the local population and anyone in fact who lives in coastal towns of East Anglia.
BT's proposal is naturally profit driven and is therefore 'without balance,' clearly advocating what it would like local residents to believe is a development that will benefit all concerned, not just its share holders.
In processing BT's application SCDC's Planning Dept. has failed in its duty to adequately involve the residents of Martlesham and District, or to identify the inadequacies of these plans in terms of their long and short negative impact.
In view of my main concerns, I wish to draw the following to your attention.
1. It is clear that BT was satisfied with the original concept of building 1000+ homes in its first Planning Application or it would not have submitted it for approval. I therefore ask; to what extent was SCDC or its officers involved by way of counselling or design in BT's decision to dramatically expand its plans?
2. Why is there no local Councillor on the steering committee? I have it on good authority The Steering Committee of councillors handling the Adastral project does not include an elected councillor for Martlesham Heath. This omission defies logic because it passes up the opportunity to learn first hand the opinion and concerns of the very residents who will be most affected by this proposal. This is so glaring; one could easily believe the omission was by design?
N.B I for one will draw this lack of democratic representation to the HM Government Planning Inspector when the time comes and the fact that very little effort has been made to canvas the opinion of Martlesham residents, see item 3.
3. The Planning Departments efforts to keep local residents fully informed about this massive project and the reason it has decided to embrace it has been and remains totally inadequate. I therefore ask on what basis was it decided not to actively seek local opinion? Please don't tell me cost of canvassing each household was too prohibitive, because money was found recently to finance a 'mail shot' questionnaire) (post paid return) requiring residents on Martlesham heath to provide information about car parking practices. Car parking is a 'fait accompli' whilst the Adastral project will be life changing.
The limited response to articles in newspapers, magazines and the odd meeting does not represent a concerted effort to test concerns or inform local people of what will be a life changing development. You appear to have simply assumed that the low number of written objections received to the first planning application to build 1,000+ houses, indicated that the majority were content with the Adastral project. If this is the case, it was not a safe decision.
4. What sustainability? BT's projections in this area are painfully transparent particularly with regard to its continuing employment of the local population. With the exception line rental related activities, the financial press has already identified that BT is reducing its UK interest and is, for example, planning yet more large scale redundancies and persuing its policy of 'technology transfer' (read jobs) to India.
Where are all the jobs going to come from for the 2 to 3,000+ residents of this new town, certainly not BT?
A town without employment is a disaster and leads to significant social problems.
5. The concept of generating what will be (based on the revised application) "a new town2 with a major highway running through its centre is by any standard ill conceived.
Does Milton Keynes or East Kilbride etc. have a major road passing through their centres?
6. When virtually every small town and village in East Anglia with a major road passing through it is calling out for a by-pass, why is the SCDC Planning Dept. prepared to give this planning application consideration when clearly it has a major flaw?
7. The projected fugures for the increase in traffic volume using the A12 must be based on an out of date survey because Martlesham is already experiencing traffic jams every morning and evening.
Why is there no mention of this anywhere in the consultation documents?
Even without the Adastral project, the numbers of cars on the A12 is forcast to increase significantly as more people take up residence in the north of the Suffolk and Norfolk, not forgetting the projected increase in holiday makers. Similarly, where is the factor for the Ipswich norther by pass plan? Much of this is recognised in SCDC's own documentation.
Hasn't anyone recognised that with the exception of the A140 to Norwich, the A12 is the only main road serving the coastal towns of Suffolk and Norfolk?
8. Has no one considered that the proposed 2,000+ dwellings will have more than one car in their drive/s and that most of occupants will not be provided with work by B.T? Even a conservative forecast indicated that an extra 2,500+ private car/van movements between the hours of 8.00 and 9.30am in the morning and similar figure in the evening? The companies in the proposed new business enterprise units will receive goods by road, own trucks and vans, and will not exclude recruiting a high percentage of their staff from the greater Martlesham/Suffolk area.
The above begs the question, has no one from the Planning Dept test driven through Martlesham on the A12 in the morning or tried to get out of Tesco's car park at peak travel times or for that matter any holiday weekend.
9. Why does the SCDC Planning Dept. believe that the provision for a four/six lane highway, (in sections) that will pass straight through the centre of Martlesham Heath and have ¾ cross roads controlled by traffic lights, is an environmentally friendly long term solution to the projected exponential growth in traffic volume? I ask this question because in my experience there can be no better way of interrupting a high volume smooth traffic flow on a major road (and increasing fumes and noise pollution) than a stop start traffic light control system.
NB. Am I the only one that's noticed that Ipswich Council Road Traffic Dept. has recently removed a set of traffic lights on the Kesgrave Rd in order to improve traffic flow?
10. Where is the section in this application that addresses the traffic jam that occurs every day, (particularly in the evening) at the A12 intersection with the A14 (they fly-over) where the tail back frequently reaches a mile in length? The Adastral project will by its very nature exacerbate this congestion and contribute to the traffic volume on the A14 which is already causing concern.
The problem at the A12 intersection with the A14 are not going to conveniently disappear.
11. Healthy living and long term amenity decline have not been fully addressed. I believe that the Planning Dept. would find it enlightening to read the report which found that children in Birmingham, who live near major road intersections, have been found to have dangerous levels of toxic chemicals in their blood from ingested traffic fumes.
I therefore ask, are the residents of Martlesham Heath seriously expected to acquiesce to any project that potentially impinges on their health and that of their children?
12. I would like to know if anyone from SCDC Planning Dept. has consulted Suffolk Constabulary Traffic Department. Have they?
They have extensive knowledge about the prerequisites needed to achieve safe/smooth traffic flows and no doubt will want to be convinced that continuous 24 hour access to Martlesham Police Headquartes (Plus their proposed new Detention Centre) has been built into these plans.
13. Education has not been adequately addressed in these plans, just one new school? Tinkering with temporary classrooms at existing schools and bussing early teens and sixth form pupils to senior schools and colleges in the area will be yet one more example of educational mediocrity being inflicted on England's children.
In the event of this ill-conceived project going ahead (preferably in a much reduced form) at the very least the proposed new infants' school must be complete and ready to receive its first batch of young pupils at the same time as the first residents take possession of their new houses and flats.
14. I believe all UK residents are entitled to expect their Town and Country Planning Departments to protect them from the inadequacies of any project that exposes them to pollution (fumes noise and reduction in the amenity etc.) or that which make calls on the environment and infrastructure which its capacity cannot sustain.
In the absence of information to the contrary, are we to assume that there are no concerns or questions being asked by planning professionals? What happened to probity?
15. Finally, one is tempted to believe that in terms of the Adastral project, SCDC and its Planning Dept. has taken the least line of resistance in responding to HM Governments edict to the effect that; East Anglia must ensure that a large number of new houses are constructed by 2020 etc. and have in consequence embraced BT's expanded plans as an easy solution. Have other possibilities/plans been considered, if so what were they?
Very few are privy to the projected profit that BT's Adastral project will generate, but it is safe to assume that a multi-national company of this nature will only undertake this venture if it is confident of a multi- million pound return, this philosophy being confirmed by the fact that it has already invested heavily. It therefore follows that in the event of this project going forward, preferably in a much reduced from (I am not a NIMBY) there will be more than sufficient funds to pay for a civil engineering type answer to the growing A12/A14 problem.
If the Planning Dept. is short of ideas please give me a ring.
One thing for sure, in the event of it being given approval (in whatever form) without a solid solution to the A12 question, (and others) neither BT nor Suffolk Coastal District Council will want to finance the remedial work needed at some future date to cure a traffic problem of its own making, which will incidentally adversely affect trade and commerce in the region for years.
This is truly an opportunity to 'get something right' at the planning stage because if we collectively fail in this responsibility, we will bequeath to the people who live in this beautiful part of Suffolk and their descendants, a number of severe problems that will persist for years.
SCDC Response: 1, 7, 11, 12, 13, 16, 17, 19, 20 Point 1 is not relevant to the consultation on the Core Strategy housing options as it relates to a specific planning application. For information, it is normal practice with a planning application for the Council's officers, where necessary, to enter into a dialogue with an applicant and discuss the proposal, seeking to understand fully the details of it, offering views and opinions, and indicating where further supporting information may be required. It is the prerogative of the applicant, as a result of such a dialogue, to retain the application unchanged, to make revisions to it, to resubmit it in a different form, or even to withdraw it. Regarding point 2, I will assume you are referring to the Local Development Framework Task Group (TG). Task Groups are politically balanced. That means that the number of Conservative, Liberal Democrats and Labour members on the TG is in the same proportion to the number of elected Conservative, Liberal Democrats and Labour members on the Council. Each group leader allocates members from his group to fill the number of seats available. Whilst Councilors have a representational role, in relation to their own wards, they are also responsible for developing policy proposals across a wide range of Council functions, and for the whole of the district.
Point 12 - Suffolk Police, were consulted for both the Ipswich Eastern Fringe and Felixstowe Infrastructure studies.
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Laurence Burrows [368] Submission Agent Respondent ID: 368 ID: 368 ID: SUBMISSION Dear Sirs
I object to the proposal to increase the number of houses allocated to the Ipswich Policy Area and I object to all of the allocation, now 2000 houses, being on one site at Martlesham next to Adastral Park for the following reasons:-
Roads and traffic - adding 2000 houses will require major changes to the A12 (at least what BT proposed in their planning application) which in turn will have a large adverse impact on the residents of Martlesham with more traffic volumes and congestion which in turn could lead to traffic safety issues. In particular the residents of Martlesham Heath will have even more problems entering or leaving the only two access points (ie the Tesco and BT roundabouts). Increased traffic and congestion will also increase air and noise pollution. The road alterations needed will also have a detrimental effect on the appearance and character of the area.
The LDF is keen to create a new community - all very well but this would in fact create an isolated community effectively far from the rest of the community. This could lead to possible community cohesion problems in the future with residents in one part of Martlesham not wanting to be involved with those from other parts. It would also mean that many of the facilities that will be needed will not be easy for residents of the rest of Martlesham to use and vice versa.
The LDF gives one of its justifications as being close to jobs. This is a fallacy, eg. how many residents of Martlesham Heath work at BT?. In practice if this development were to go ahead the houses would be occupied by people from anywhere who happen to be looking for a new home at the time and are just as likely to work elsewhere. Being further out of Ipswich (a far bigger employment centre than BT) there could be more commuting traffic.
Public infrastructure and facilities - The LDF documents provides a sort of 'shopping list' of what would be needed but if a development of this size is to proceed in any way then there must be compulsion to provide all of the necessary facilities at the beginning or early on. Providing all of this infrastructure will also have an adverse impact on the area over and above that of the 2000 houses. For some infrastructure requirements this impact will impinge on areas away from Adastral Park (eg. providing foul sewerage facilities, extra upper school places, electricity supplies etc.).Of particular concern is that SCDC infrastructure studies have been carried out with conclusions in the LDF document without the promised consultation on the infrastructure appraisals.
Sports fields - a relatively small issue but the LDF documents appear to repeat the wrong assessment of public sports fields available for public use in Martlesham. Although it only gives an area available it seems that they may have included the Police HQ and Woodbridge Town FC, neither of which are publicly available. If I am right then the amount of space needed would be much greater.
If this development goes ahead Martlesham will be a very large village of almost 12000 people, only Felixstowe and Kesgrave will be larger! Martlesham will become a 'mish mash' of several large residential areas with no clear focal points.
SCDC Response: 4, 7, 11, 13, 16, 18, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Leo Brome [304] Submission Agent Respondent ID: 304 ID: 304 ID: SUBMISSION The proposed development in Ipswich Policy Area at BT
The A12 at Martlesham Heath is already congested at peak times, and very busy at other times. Traffic leaving Martlesham Heath often has difficulty entering the stream of traffic. Wherever development takes place, Martlesham Heath will become a major bottleneck on the A12 in the future, especially if a northern Ipswich bypass is built (as it will then become an alternative route to Felixstowe from the A14 west)
In 10 or 15 years the only solution will be a Martlesham Heath bypass, the only feasible route for that bypass would be right through the proposed development on the BT site
I object to the current LDF plan in that blocks any future possibility of the A12 bypassing Martlesham Heath when traffic flows necessitate it
SCDC Response: 4, 13, 16, 19
IPSWICH POLICY AREA
Respondent Name: Mr Lionel Scott [94] Submission Agent Respondent ID: 94 ID: 94 ID: SUBMISSION I apologise that having registered, I have lost my password to reply to the local core plan in relation to the proposed housing and other developement at Adastral Park, Martlesham. Having lived in the area for nearly fifty years I would howerver like to make the following comments. I am not one who is against the proposed developement which is mainly fuelled by the 'not in my back yard' thoughts. I am happy to see developement which the area is clearly going to have to provide. I can remenber when Grange Farm was a farm and indeed the planning control then in existence initially resisted any developement, the rest is history and we are where we are today. However what has really been missing is a strong demand by local planning control to make developers pay via Sec.136 agreements over the years. It would certainly have seen far greater improvement in the local road structure Main Road at Kesgrave, Foxhall Road, the A12 at this location and possible a big push for a northern bypass. I am in favour of the proposed development provided there is a requiirement placed on the developer to provide greater road improvement in the area. (1) a slip road for south moving traffic leaving the area to join the A12 and a flyover or underpass for northern bound traffic is a mimimum, thus avoiding villages such as Waldringfield and Newbourne being grid locked in when main traffic flows leave the proposed development. There will also be increased movement into surrounding villages by any new arrivals at this developement. To this end and as a balance I feel the nearby villages should also be allowed development where it can be done by infill and without adversely detracting from the natural landscap. It will also tend to allow a ballance to prevent the new developement becomiong a golliath with existing nearby villages being a poor David.
On the roads issue whilst not your direct responsibility I would suggest a mini rounabout at the juctions of Foxhall Road with both Bell Lane and Dobbs Lane would improve access/exit and safety and improved traffic flow. The removal of traffic lights on the Main Road Kesgrave at one entrance into Grange Farm has greatly improved traffic flow, the other junctions along that road would benifit from the same treatment. A really bold move would be to move the Main Road juction to Suffolk Police HQ's a few metres east by shaving the corner off and on the other side of the road moving the bus exit from park and ride west a few meters and yes another roundabout. This would provide entrance and exit to the park and ride for all meaning that the A12 would have one less junction into the park and ride complex, this would help the flow off traffic on the A12 and may even be able to see the removal of yes another set of traffic lights. Traffic entering or leaving police HQ's would also find it a great deal easier.
SCDC Response: 4, 11, 13, 19 Comments noted
1 INTRODUCTION
Respondent Name: Mr Malcolm Wheatley [139] Submission Agent Respondent ID: 139 ID: 139 ID: SUBMISSION I think the amount of development east of Ipswich has already been excessive and the proposed housing beside the BT building will mean a loss of amenity to everyone, locals and tourists alike, including you. For God's sake, leave some wild bits. Don't concrete everything. Leave somewhere for the flowers to grow, to hear the birdies sing!
SCDC Response: 4, 16, 17
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Mark Stone [244] Submission Agent Respondent ID: 244 ID: 244 ID: SUBMISSION Once again we are writing in protest against the proposed urbanisation of the countryside between Waldringfield Heath and Martlesham.
As we now no it is not 2,000 but over 3,000 many being 3,4,5 and 6 storeys high.
This is a green belt area, this kind of development is totally unsuitable for a rural location.
The village of Waldringfield and Waldringfield Heath will be the most effected by this proposed hideous devlopment, Far too many properties in one location. Our fine village school will probably close. I cannot of any benefits for the residents of Waldringfield.
SCDC Response: 4, 16, 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Martin Cottrell [515] Submission Agent Respondent ID: 515 ID: 515 ID: SUBMISSION Dear Sirs,
I wish to make comments on the LDF / Housing Distribution Updated Preferred Option 7/09.
My comments are based on the inappropriateness of the development, the need for major road works, the inadequate public transport and the effect on the local fauna and flora.
The number of houses to be built on BT land is greater than the number on Martlesham Heath and will therefore create a new town next to a village. The impact of this will be overwhelming. Smaller developments would be more easily absorbed.
Water services in this, the driest part of the country, will be stretched. The existing sewage system will not be able to cope and extra treatment facilities will need to be built at Sandy Lane so this part of Martlesham will be affected too.
I object to the need to remove the roundabouts along the A12 and replace them with 7 lane junctions. The barrier that exists between the houses at Martlesham Heath and the road will be very much reduced.
I find it unethical that the LDF Distribution of houses has been changed to match the planning application submitted by BT.
Paragraph 5.10 says that new housing should be provided where facilities exist. With regard to transport the existing bus services e.g. route 66 cannot cope with the present demand let alone the extra passengers from a further 2000 homes. Changes are being made to other routes such as the number 65 which will in future only provide a two hourly service.
As the new building will be on greenfield sites there will be no protection for wildlife and the landscape. The height of the proposed development will be intrusive.
Building on agricultural land should be avoided. The Government recently said that this country should grow more of our own food. How can this be achieved if the land is built on.
I do not feel that the changes to the LDF are justified and I do not consider that the changes will meet the broad strategy. I do not agree that the housing distribution has met with a measure of agreement. I have not found anybody who is in agreement with it.
Suffolk Coastal - where quality of life counts - obviously not any more.
SCDC Response: 11, 13, 15, 16, 17, 20
THE OVERALL STRATEGY
Respondent Name: Mr Martyn Shakespeare [392] Submission Agent Respondent ID: 392 ID: 392 ID: SUBMISSION Martlesham appears to have become a dumping ground. A greater spread across the entire area would be preferred.
SCDC Response: 4
BASE REQUIREMENTS
Respondent Name: Mr Martyn Shakespeare [392] Submission Agent Respondent ID: 392 ID: 392 ID: SUBMISSION Challenge need for so many homes. We are taking it on trust that they are required. I can't see it. There seem to be a lot of empty properties around at present, and I question whether we are making best use of all existing properties.
SCDC Response: 3 Other comments noted
IPSWICH POLICY AREA
Respondent Name: Mr Martyn Shakespeare [392] Submission Agent Respondent ID: 392 ID: 392 ID: SUBMISSION Size likely to overwhelm existing villages. 1000 may (just) be acceptable only if of very highest environmental standards and low rise to minimise impact. Concern that such a large development (on top of Grange Farm, which we've already suffered) will totally overwhelm existing routes into Ipswich, which are already at capacity at many times, and local amenities. Huge amount of building around Ipswich at present, much currently empty; additional need in this area questionable.
SCDC Response: 3, 18, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Matthew Davies [277] Submission Agent Respondent ID: 277 ID: 277 ID: SUBMISSION One of the reasons mooted for the East of A12 site being "closely linked to the existing and proposed employment retail and social provision at Martlesham Heath/Adastral Park business centre" is not sufficient to justify the development of an entirely new community.
The BT Adastral Park site is shedding employees left, right & centre, and more and more of the offices are becoming unoccupied. I forsee that if this development goes ahead, the community that will be created will have no opportunity for local work, and will therefore suffer all the ills that go with unemployment. (Work that is not local hardly fits into any local sustainability ethos.)
Coupled with this will be the inevitable localised baby boom, as inhabitants of new houses tend to be of a certain demographic, which will in time lead to a generation of children whose parents are long-term unemployed and who have no prospects themselves. Need I go on?
SCDC Response: 7, 16
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Michael Cowell [317] Submission Agent Respondent ID: 317 ID: 317 ID: SUBMISSION We do not feel that the proposed changes are justified and object to them most strongly because the huge increase in the proposed number of houses gives rise to many serious concerns. Among them are the following- The changes will * destroy the rural environment of Martlesham, which will become almost urban. Martlesham Heath will be completely overwhelmed by such a large development and the quality of life there will be diminished. * cause a huge increase in traffic, which will lead to major delays both in Martlesham, the A12 and the A14 Orwell Bridge. * mean that the local secondary schools will not have sufficient capacity. * swamp the Park and Ride which is already very busy at peak time.
The construction of a footpath/bridge from the new development to Martlesham Heath will lead to increased foot/cycle traffic through the village to Ipswich, for which no provision exists. The woodland trails are not designed for cycles. How will this traffic get through the SSSI without destroying wildlife habitat?
A smaller development at Martlesham Heath & required number of new houses achieved by in fill.
SCDC Response: 12, 13, 16, 17, 18, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Michael Hall [280] Submission Agent Respondent ID: 280 ID: 280 ID: SUBMISSION Dear Sir,
I write to object to the new proposals re the development of BT land to the east of the A12 at Martlesham.
My objections are based on the following:
1. The impact of the a new town of 2000+ houses and commercial buildings on the locality I believe that the proposals will cause what is a relatively small village community to be overwhelmed. 2000 houses ( possibly more) will at least double the existing community at Martlesham/Martlesham Heath. This is quite simply an urban development in a rural area I believe your description of the proposed development is inconsistently applied. In your proposal you talk about a stand-alone development at Adastral Park on the one hand and later on refer to an integrated development. It cannot be both. I believe that there will be an adverse effect on local services, particularly with the proposed increased number of houses on the site. There appears to be no acknowledgement of the effect on policing (more people inevitably means more crime), and waste (the existing services will be stretched even more). Similarly with the health provision not only in the immediate area (Martlesham) but also in the wider area (services at Ipswich Hospital for example) I se no indication that his has been given serious consideration. Much of the area around Martlesham and Waldringfield is an Area of Outstanding Natural Beauty and the Western Corridor and Common in Martlesham/Martlesham Heath is a Site of Special Scientific Interest with nationally important fauna. I do not believe that the new proposals do anything to reduce the impact on community efforts to maintain the health of the population of Silver Studded Blue butterflies for instance. Impact on the road and transport system I believe the new proposals will increase still further the inevitable dramatic increase in traffic into Adastral Park and along the A12 which in turn will impact adversely on villagers trying to exit the village onto the A12. This happens at the moment (particularly at peak time); I cannot see that the new proposals will do anything to reduce the problem. I believe that the new proposals will further increase the congestion and noise/light pollution in the area. The night sky in Martlesham Heath village is already blighted by light pollution from Ipswich and I fear that a 2000+ development on the other side of the A12 from the village will exacerbate the problem. We have all seen the light pollution streaming out from Felixstowe Docks as we drive across the Orwell Bridge; are we to believe that a large-scale commercial/residential development even closer to Martlesham Heath will be pollution-neutral? I think not. I note that proposed access to the new development is via Martlesham Heath village with a cycle/footpath network that cuts through existing, non-developed community-owned land. I believe that this will be to the detriment of these spaces and hence the environment in the village. I also note that there is expected to be an increase in the level of cycle traffic which inevitably means greater pedestrian/cyclist interaction. I firmly believe that this will penalise and/or threaten pedestrians. I further note that the traffic predictions are based upon the 2001 census. I believe that this will have given a false (ie lower) estimate of the traffic expectation due to inevitable changes in vehicle usage since 2001. I believe that it is essential that a new comprehensive survey of the traffic and vehicle use in the area is conducted as a matter of urgency before the new proposals are accepted. I see that the proposals include a traffic light-controlled multi-lane superhighway at the village junctions with the A12. Are we to believe that the rest of the A12 (N & S) will be able to cope with the increased traffic flow that the new proposals will bring?. I think not. I also note that additional land will be needed to accommodate the new junctions. Where will this land come from? The land at the village edge bordering the A12 is village community -owned land that incorporates a bund to insulate the inhabitants of the nearby hamlets from traffic noise from the A12. Were this to be removed, it would increase the level of noise intrusion for the these people. I live about a half mile into the village from the A12 and, although it is not over-intrusive, traffic noise from the A12 has increased considerably over the years. I believe that the new proposals for the A12 will exacerbate the problem. This is not good. I note that public transport is expected to take the strain of getting people to and from Ipswich and the surrounding area for work (other than those who are willing to cycle/walk the 8 miles or so which I am led to believe is but a small proportion of the total) At the moment, Route 66, good as it is, struggles at peak times to maintain the service that they have timetabled and it is not unusual for the Route 66 bus to miss out Martlesham Heath and return to Ipswich directly after Martlesham Tesco. Are we to honestly believe that the increased traffic/demand that the new development will engender will do anything other than make the situation worse as I believe it will? I am not a NIMBY, instinctively opposed to development I recognise that people need to live somewhere I would be not be bothered to see some level of development in the area but on a much smaller, distributed and much less overpowering scale. In summary, I believe that the new proposals for development on the land to the East of the A12 at Martlesham are ill-founded and excessive and strongly urge you to reject them.
SCDC Response: 9, 11, 13, 16, 17, 18, 19, 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Michael Smith [455] Submission Agent Respondent ID: 455 ID: 455 ID: SUBMISSION OPTIMA LAND AND PROPERTY HOUSING DISTRIBUTION - UPDATED PREFERRED OPTION 7/09 On behalf of Optima Land and Property Ltd., I am writing to respond to the current consultation exercise on the Housing Distribution - Updated Preferred Option 7/09 element of your authority's emerging Core Strategy and Development Management Policies DPD. Optima Land and Property has an interest in land to the north of Felixstowe that was identified as part of the Site Specific Allocations Issues and Options consultation in December 2008, therefore the revised housing distribution is a matter of great interest to my client. My client wishes to formally object to the change to the distribution of the housing numbers throughout the district and, in particular, to the reduction in the number of new homes allocated to the Felixstowe area by some 660 dwellings. It is understood that the general tone of the response to the previous consultation exercise (Preferred Options 12/08) raised concerns with regard to the level of growth proposed for the Felixstowe area, my client believes that further evidence is required to show that the council's response is driven by information provided by the evidence base instead of political influences. The number of new homes to be allocated to the Felixstowe area is continually reduced at each step in the preparation of the Core Strategy. Contrary to the latter, however, there have been absolutely no significant changes to the evidence base to justify these alterations and reductions - as such, there is a risk that the latest version of the housing distribution will be found to be "unsound" at the forthcoming Examination in Public. The Issues and Options consultation (February 2007) offered six different development scenarios for the district, with the number of new homes to be provided in the Felixstowe area ranging from zero (option 1) to 2,720 (options 2 and 6). The Further Issues and Options consultation (February 2008) settled on a figure of 1,620 new homes, which was amended slightly to 1,660 new homes in the Preferred Option (December 2008). The proposed housing provision reflected the professional conclusions set out in the April 2006 study A Local Strategy for the Felixstowe Peninsula, prepared by David Lock Associates and which addresses a number of issues facing the decline, or not, of Felixstowe in the immediate future. It is not necessary to list the negative trends identified by the report (most of which are replicated on page 9 of the Updated Preferred Option 7/09), but it is very clear that the reduction of the allocation to 1,000 new homes will not serve to address those existing negative trends. JCN Design Limited 2 Exchange Court, London Road, Feering, Colchester, Essex, CO5 9FB T: 01376 572977 | F: 01376 573774 | www.jcndesign.co.uk The public's rejection of the earlier options for the growth of the town that were put forward in favour of what is described as "organic and evolutionary growth" does not mean that the negative trends need to be perpetuated. Whilst large-scale growth on a single greenfield site is not favoured, it remains that smaller allocations for residential development around the town and adjoining villages will achieve the effect of revitalising the local economy, support existing facilities and services, fund new infrastructure and, most importantly, address the imbalance between the supply and demand for new homes in the area. Organic growth can do more to maintain existing services across a wider area than a single strategic development that focuses new facilities into one development. It follows, therefore, that the revised approach for organic and evolutionary growth should not be automatically coupled to a reduction in housing numbers. While the current recession has had an impact on the housing market and, perhaps on the expansion of the Port of Felixstowe, short-term economic "blips" will not affect the longer-term significance of the need to regenerate the town. It is understood that some regeneration schemes are already being brought forward without funding or support from residential development, but it is far from certain that such an approach can be maintained throughout the plan period and beyond without the introduction of new residents to address the existing and emerging issues. The Core Strategy provides a framework for growth over a fifteen-year period and should therefore be drafted to take account of peaks and troughs in the economy, rather than reflecting the prevailing issues at a time when economic activity is at a low ebb. To date, there is no evidence to suggest that the expansion of the Port of Felixstowe will not recommence when economic activity begins to gain momentum, therefore it is not acceptable for housing numbers over a fifteen year period to be constrained on the basis of a temporary change to the operation of the port lasting only two or three years. Similarly, the justification for the change to the housing numbers given in the response to the Preferred Option 12/08 consultation notes that Suffolk County Council have chosen to rationalise school facilities by providing a single secondary school. This is a disappointing response, as such a move is a clear indication of the trend towards an ageing population, which could be counteracted by organic growth throughout the town that would mean that the demand for school places could be spread amongst the existing facilities. For the District Council to fail to provide for the number of children that will maintain the sustainable existing school system will leave a legacy of reduced facilities that can only serve to continue the negative spiral. All as cited within the evidence base. Failure to support existing facilities will restrict the town's ability to accommodate growth in the future, unless the growth provides the services and facilities that will be lost through a lack of demand or funding, which is not a sustainable approach to managing the regeneration of Felixstowe. The response states that "a reduction in housing numbers could therefore be considered, particularly during phases 1 and 2, without seriously compromising the overriding objective of securing regeneration" but no evidence to justify this claim has been made available and it is not reflected by the recent actions of Suffolk County Council. It appears that the short-term economic impact of the recession is being used to justify changes to housing numbers for the next ten to fifteen years. The response also states that a sensible approach would be to provide "a rate of new housing growth more closely linked to new jobs provision". However, this relationship is not established by the Updated Preferred Option 7/09 and does not accord with the findings of A Local Strategy for the Felixstowe Peninsula, which seeks to diversify the local economy and, quite rightly, reduce the dependency on the Port of Felixstowe to drive localised economic growth. To tie the short-term reduction in activity at the port to reducing the housing numbers will achieve the opposite effect, with housing provided only when the port is at its busiest and is seeking to JCN Design Limited 2 Exchange Court, London Road, Feering, Colchester, Essex, CO5 9FB T: 01376 572977 | F: 01376 573774 | www.jcndesign.co.uk expand. To re-balance the relationship between employment and housing, opportunities need to be provided for people to live and work in Felixstowe without any relationship to the port. Any growth in the tourism industry or any other sector of the economy will be held back if workers need to commute to the town from the east side of Ipswich or further afield. One element of the evidence base that has been used to good effect is the need for new housing to balance the current trend for commuting into Felixstowe, but no data is presented to show the effect of a reduction in the supply of new housing on levels of commuting. The reduction in housing numbers in the Felixstowe area is balanced by increased provision in the Ipswich Policy Area, therefore it can be presumed that there will be an increase in the levels of commuting into Felixstowe as some 660 households are required to make longer journeys to work by being shifted away from the area's main centre of employment. The previous approach of allowing people to live closer to their jobs has not been abandoned, but it has been ignored for reasons that are not made clear in the Updated Preferred Option 7/09. The effect of the alteration on the highway network, the need to reduce the requirement for people to travel and the regeneration of Felixstowe needs to be explained and justified through reference to the evidence base. The policy of organic growth is supported, and the opportunity to use small-scale development throughout the Felixstowe area to address the negative trends described in the David Lock Associates report is a practical and sustainable approach. However, the loss of around one third of the new homes allocated to the area will have a serious impact on the ability of the town to achieve the necessary critical mass to deliver the regeneration of the town whilst simultaneously breaking its reliance on the Port of Felixstowe for economic growth and employment opportunities. The importance of these targets cannot and must not be underestimated, as they are fundamental to the future of the town. Care is needed to avoid taking too narrow a view of the relationship between the port and the town, as the current round of changes appear to be based on short-term economic data instead of the need to manage the supply and demand for new homes in the long term. Care is also needed with regard to the proposal to increase the number of new homes allocated to the Ipswich Policy Area. The increase appears to be justified on the basis that more homes are needed to facilitate the minimum level of community facilities, including a district centre, primary school and healthcare facilities and will trigger the provision of new facilities that serve a wider area, such as a secondary school and public transport improvements. It is also suggested that an increased population at Martlesham will provide better opportunities to mitigate the impact on the nearby Area of Outstanding Natural Beauty. To take the approach of securing more contributions from developers by increasing the housing numbers in the new stand-alone community at Martlesham is counter-intuitive, as the impact of the scheme will require greater mitigation and the requirements for the provision of infrastructure, services and facilities will grow as the number of new homes increases. Critically, protecting the AONB should not be dependent on the construction of a greater number of houses. Furthermore, the reverse effect will be applied to the existing community at Felixstowe: the council's evidence base shows that facilities such as those listed above are already required in the town; but the Updated Preferred Option 7/09 proposes that the allocation of new homes be reduced because the scale of development cannot justify the provision of new facilities. No explanation has been offered to demonstrate why the loss of existing facilities and the loss of opportunities for new facilities in Felixstowe is deemed acceptable at the same time as numbers to the east of Ipswich must be increased in order to achieve the scale of development needed to JCN Design Limited 2 Exchange Court, London Road, Feering, Colchester, Essex, CO5 9FB T: 01376 572977 | F: 01376 573774 | www.jcndesign.co.uk sustain new services. There is no balance between the strategies for the two main areas that will accommodate district's growth and no reasoned justification is provided for the swap of housing numbers between the two locations. Furthermore, there is no evidence to suggest that the broad strategy for meeting the housing numbers set by the East of England Plan will be better met by shifting a significant proportion of the housing allocation from the Felixstowe area to Martlesham. The creation of a self-sufficient community at Martlesham is a laudable aim, but it should not be achieved at the expense of Felixstowe's future. Damaging the opportunities to meet the social and economic objectives for the Felixstowe area will have a negative impact on many more people than will be accommodated in new homes at Martlesham. Whilst the objectives behind the creation of a new community at Martlesham can be simply set out in a new Area Action Plan that has tightly drawn boundaries, the relationship between the existing settlements of Felixstowe, Walton, Trimley St. Martin, Trimley St. Mary and new development is much harder to quantify and the impacts and benefits will be harder to identify within such a complex and inter-dependent relationship. The 2006 David Lock Associates study has not been updated to consider the implications of the revised strategy for the town, nor has any other part of the evidence base been used to justify the new approach to the housing numbers. In short, it is simply not possible to determine whether the broad strategy to accommodate residential development in the district up to 2025 will be better met by the changes because very little new information has been provided to justify the changes. Succinctly, the background information available does not support the council's decision to revise the distribution of new housing between Felixstowe and Martlesham. The previous approach was justified by the evidence base, which reflected the conclusions set out in the David Lock Associates Study A Local Strategy for the Felixstowe Peninsula, whereas the new approach seems to be based solely on a desire to make the scheme at Martlesham self-contained. The public opposition to the growth of the Felixstowe area is documented (both in responses to previous consultation exercises and in the local press), but it is not clear, however, if the change is a response to political pressure or whether there is a genuine planning- based reason why the alteration should be made. As such, on behalf of my client I urge you to enhance the evidence base and release further justification for the change to the housing distribution, or if such information is not available, return to the levels of development set out in the Preferred Options 12/08 document. I trust that you will find the above notes to be clear and straightforward, but if you have any comments or queries, or if you would like to discuss this representation in more detail, please do not hesitate to contact me at the above address.
SCDC Response: 4, 22, 24
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Neil Cawthorn [284] Submission Agent Respondent ID: 284 ID: 284 ID: SUBMISSION Dear Sir, BT Planning application Ad Astral Park
I write to express my concerns with the above planning application. As a resident of Waldringfield I am certain that a development of this size will overwhelm the limited public resources and have an adverse effect upon the quality of life of those already living in this beautiful village.
We are on the edge of an AONB with barn owls, egrets, short eared owls, and many other rare species of wildlife. A development of this size is bound to have an effect on the natural habitat of these species, and the inevitable pressure on the AONB caused by more and more people seeking to enjoy the river, can sadly only have a detrimental effect upon the wildlife there.
At a recent planning enquiry, regarding the building of holiday log cabins, the Inspector concluded that one consequence of a development which would have been far smaller than anything here contemplated, would have had such an effect on the roads and resources that Waldringfield would not have been able to cope. Please bear this in mind in your deliberations.
SCDC Response: 17, 18, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Neil Cawthorn [284] Submission Agent Respondent ID: 284 ID: 284 ID: SUBMISSION Dear Sir, BT Planning application Ad Astral Park
I write to express my concerns with the above planning application. As a resident of Waldringfield I am certain that a development of this size will overwhelm the limited public resources and have an adverse effect upon the quality of life of those already living in this beautiful village.
At a recent planning enquiry, regarding the building of holiday log cabins, the Inspector concluded that one consequence of a development which would have been far smaller than anything here contemplated, would have Had such an effect on the roads and resources that Waldringfield would not have been able to cope.
Over and above this, there is no provision made for education at secondary level for the children of these developments, and the current schools are full. I hope that the planning authority will accept that this matter must go to an inquiry.
SCDC Response: 17, 18, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Oliver Ballam [236] Submission Agent Respondent ID: 236 ID: 236 ID: SUBMISSION why is standalone necessary? the community will always interact with others nearby, with the proposed high density highrise development the community is likely to be transitional thus no key family type members essential to establishing a 'standalone' community. public transport is already poor hence investment required already roads are strained already orwell bridge cannot keep up cannot be 'widened' even with increased investment whole road would need doubling all the way to London no number of homes will 'provide investment' for this doubling homes to 2000 will more than double road strain as even less % of people will work locally, limited jobs.
SCDC Response: 7, 11, 12, 13, 18, 19
SMALL WINDFALL PROVISION - REDUCE PROVISION FROM THIS SOURCE
Respondent Name: Mr Oliver Ballam [236] Submission Agent Respondent ID: 236 ID: 236 ID: SUBMISSION the existing social infrastructure is under less pressure if small developments are allowed across the region, this also supports rural services which are becoming less viable due to lack of economies of scale. we will still need extra secondary school(s) but we already do, Kesgrave and Farlingaye among others are at bursting point.
SCDC Response: 4
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mr Oliver Ballam [236] Submission Agent Respondent ID: 236 ID: 236 ID: SUBMISSION you have paid someone to study how many houses are required MINIMUM then totally ignored it. more housing should be provided in this area as Felixstowe badly needs more investment. Whereas Martlesham is already in good state and needs minimal investment. POF is good employment provider and already some people travel from other areas to work here because Felixstowe needs this investment why not provide them with somewhere nice to live and cut down road pressure. why will building the extra houses at Martlesham instead of Felixstowe help with A14 traffic? Most commuters will still use the A14 road link to W Suffolk
SCDC Response: 12, 22
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Oliver Ballam [236] Submission Agent Respondent ID: 236 ID: 236 ID: SUBMISSION Where will a new sewage works be located? where will the waste go, foxhall is nearly full. You will be building new houses very close to the existing landfill site. 'almost certainly' enough water supply rates for new development. this is contrary to press various reports suggesting we have limited resources available for even the exsiting population.
SCDC Response: 20 See Suffolk County Council Waste Core Strategy
IPSWICH POLICY AREA
Respondent Name: Mr Oliver Ballam [236] Submission Agent Respondent ID: 236 ID: 236 ID: SUBMISSION how can doubling the number of new houses reduce the impact of the development which is what your document implies The traffic data seems dodgy at this stage, definately not robust enough to make a major planning decision. its not cvosted properly and basically requires the northern bypass a plan which has been axed several times before for good reason
SCDC Response: 10, 16
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Oliver Ballam [236] Submission Agent Respondent ID: 236 ID: 236 ID: SUBMISSION Why has the dispersed option been adopted for Felixstowe whereas a new development option has been adopted for martlesham. public opinion is in favour of dispersed option either the original middle option in your consultation or the pepperpot development strategy which has been ignored even though it was most popular. this type of development will destroy the Martlesham Waldringfield local area more so than it would have in Felixstowe yet the dispersed option has been ignored
SCDC Response: 15, 18
APPENDIX 4 - BREAKDOWN OF UPDATED DISTRIBUTION STRATEGY
Respondent Name: Mr Oliver Ballam [236] Submission Agent Respondent ID: 236 ID: 236 ID: SUBMISSION You have said that the overall increase from 1000 to 2000 houses in the Martlesham development hardly changes the overall provision statistics, this is tru, but a large block of 1000 new houses (not to mention the further 1500 BT have said the site 'can provide') has a much greater effect on the area than the overall statistics can hope to show! We need some sort of a plan which limits the amount of houses not specifies a minimum there is only so many people the land and jobs can support and this cannot be increased.
SCDC Response: 4, 16
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Mr Oliver Ballam [236] Submission Agent Respondent ID: 236 ID: 236 ID: SUBMISSION why has this not been done before sept 09 what is definition of sustainability? opportunity to create sustainable settlement/s etc is highly questionable & meaningless. What is the behavioural/social science evidence for this? developing SP20 will more likely produce the opposite - a 'souless estate', a 'slum'with the high rise buildings and social housing. I am concerned about many seemingly subjective ratings, how is the new proposal 'marginally less sustainable', doubling houses? does future development require a further environmental study Re the benefits of building on a no. of sites. If recommended for Felixstowe why not for Martlesham?
SCDC Response: 8, 9
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Mr Oliver Ballam [236] Submission Agent Respondent ID: 236 ID: 236 ID: SUBMISSION why has this not been done before sept 09 what is definition of sustainability? opportunity to create sustainable settlement/s etc is highly questionable & meaningless. What is the behavioural/social science evidence for this? developing SP20 will more likely produce the opposite - a 'souless estate', a 'slum'with the high rise buildings and social housing. I am concerned about many seemingly subjective ratings, how is the new proposal 'marginally less sustainable', doubling houses? does future development require a further environmental study Re the benefits of building on a no. of sites. If recommended for Felixstowe why not for Martlesham?
SCDC Response: 8, 15
IPSWICH POLICY AREA
Respondent Name: Mr P Davis [403] Submission Agent Respondent ID: 403 ID: 403 ID: SUBMISSION I am writing to object to the Adastral new Town planned for good agricultural land, which is needed for feeding people, not housing them. This year, the land has been used to produce potatoes, onions and barley.
The development of this urban sprawl would create gridlock on local roads and lanes, as well as local facilities.
I can only hope that sense will prevail and we stop covering Suffolk agricultural land with concrete.
SCDC Response: 15, 16, 18, 19, 20
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Mr P Davis [403] Submission Agent Respondent ID: 403 ID: 403 ID: SUBMISSION I have read all the consultation/discussion documentation available at this stage. My specific interest is some what parochial - proposed change to housing distribution FRISTON parish. However I have tried to balance my views by considering the situation in total.
I might say in doing so I have a far greater appreciation of the complexity of the work undertaken by the planners. In general I feel you should be congratulated on the work done so far. It was never going to be possible to please everybody, either in terms of interest area/subject or residential location.
I should like to comment on the sustainability appraisal of Core Strategy and Development Management Policy document. I offer the following (hopefully helpful) operational suggestions:-
It has become increasingly clear to me that the inadequacy of our highway infrastructure is a major bugbear that adversely impinges on virtually every aspect of life in Suffolk Coastal.
The A14 has become one of the most dangerous and hated routes in the country. The planned development, industrial and housing, in the Felixstowe area will not ease matters. Similarly the A12 is a National disgrace - where else in the country can one find a major trunk road with so many 30 and 40 MPH restrictions and so few sections of dual carriageways? There is a saying (true) that the weather will not cross the A12, I am not surprised, nothing else can!
Many of the significant main development centres identified in the development plan are located either side of these roads. Safe crossing provision is a vitally important factor. Not only because it will reduce unnecessary main road use = traffic density, but because it will improve the local traffic and viability of settlement types. Plus quality of life for all residents of Suffolk Coastal.
Of course this won't solve all planning issues you have highlighted but it would ease or enable a good number of them.
Finally I return to the revised Settlement Hierarchy changes and FRISTON village in particular.
I am pleased to note that Friston has been downgraded from a Local Service Centre to Other Village status. This is entirely sensible and since the February 09 consultation Friston has lost its only public house and the post office provision (2 hours 1 day per week) has been reduced. Further the trend of houses becoming second homes (weekenders) has continued ie less permanent residents.
Many thanks for keeping me on your mailing list.
SCDC Response: 12, 13 Other comments noted
KEY SERVICE CENTRES
Respondent Name: Mr P King [416] Submission Agent Respondent ID: 416 ID: 416 ID: SUBMISSION Whilst I continue to disagree with the distribution of new homes across the district, I have no objection to a certain amount of regeneration in Felixstowe, but it should not be at the expense of the Trimleys, and the peninsula a s a whole, especially with regard to the use of agricultural land.
2.05 Little has changed: the distribution of new homes has simply been moved from one end of the Peninsula to the other. Martlesham, and its environs are, to all intents and purposes, on the Peninsula. I reiterate that new homes should be spread across the district.
3.01 The Council has not regularly consulted with local residents. 3.02 The ageing population justification can only be used once, and time is running out. In any event those of us who were born in the late twenties, thirties, or early forties are coming to the end of our life span and our demise will release many homes for sale/rent. 3.04 The Council should have consulted the residents of Felixstowe about the furutre of their town; rather than David Lock et al. 3.05 I have yet to meet anyone who is happy with what has been and what is now proposed. 3.06 The Council have pressed ahead, mindset on their initial proposals, paying lip service to consultation, but in fact having scant regard, or more to the point, seemingly ignoring completely the measured arguments, tempered with moderation and common sense, expressed by many local residents, parish Councils, together with various august bodies/organisations; that basically; your proposals are "over the roof", and which in the long term are neither sound, or sustainable. Even the Port of Felixstowe now doubts the wisdom of building the proposed number of new homes on the Peninsula. Should, heaven forbid, it all come to fruition, it will pave the way for a linear city to be created, stretching from Ipswich to Felixstowe.
5.09 The distribution may have changed but concerns for the Peninsula remain. 5.10 It was considered in 1813 that the soil in the Felixstowe/Trimley area could (for depth and richness) scarcely be exceeded by and soils elsewhere in other parts of the Country, and would rank high among the best in England. No use of agricultural land for housing or industry. Words like "unfortunately" and "avoided as far as possible" are words that give the impression that the use of agricultural land for housing is of little, or no consequence, whereas it could be construed to be a criminal act. Building should only take place on agricultural land in extraordinary circumstances, no such circumstances currently exist. 5.12 The quality of life especially in the Trimleys will deteriorate. 5.19 There is nothing "organic" or "evolutionary" about the housing distribution. Again the Council seeks "to protect the setting of Felixstowe". Further proof that the Council appears to be bias in their attitude towards the Trimleys.
6.03 Despite their protestations to the contrary, in my opinion, the Port of Felixstowe will automate. Intervention cannot, and will not, alter where people choose to live, their choice of calling, or the mode of transport they use. Again "protecting the setting of Felixstowe" to us poor mortals in the Trimleys it means "build in the Trimleys" This is democracy! Would like only modest development to be carried out in the Trimleys.
The comments in paragraphs 1-6 are perfectly valid points of public concern, but the council seem impervious to any view that is at variance to their proposals which in my opinion will, with the passage of time, prove to be ill conceived. There has to be a better way forward.
7.02 Again "pace of development only increasing in order to achieve social and economic objectives for the town" "Allocations at Key Service Centres to meet local needs" would appear to be at variance with the foregoing. 7.04 I disagree with the proposal to create a "hub" between Walton and Trimley St Mary for the following reasons: A) employment. It's been tried before and failed; initially when it was thought the Port of Felixstowe would receive "free port" status, and later with Trinity 2000, where light engineering units were not taken up. B) Housing. Trimley St Mary does not wish to be merged with Walton. The penultimate and last sub paragraphs again deal with Felixstowe, as if the Trimleys were in no way affected. 7.06 From sub paragrpagh 3, I conclude that overall, a total of thirty new homes will be built in the Trimleys, as Key Service Centres, and yet throughout the whole document they are seemingly portrayed as part of a Major Centre, which they are not. Neither should they be earmarked as the only Key Service Centres that are capable of accommodating strategic levels of growth, and once again; they are not. Trimley St Mary should remain an individual settlement, and not be merged with Walton.
SCDC Response: 4, 22, 23, 24, 25, 26
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Patrick Doorly [519] Submission Agent Respondent ID: 519 ID: 519 ID: SUBMISSION Dear Sir/ Madam
I am e-mailing you to strongly object to the new housing development proposal for the BT site at Martlesham Heath, and to voice the views of many local residents and friends.
Being a local resident, I already experience the traffic problems which we face on a day to day basis just by travelling to and from school/ work/ shops etc. I could name many particularly bad areas, and I dread to think of the effect this will already be having on the local natural environment. Increasing traffic by building a new settlement can only make this worse. I am well aware that you intend to "minimise the effect" of extra traffic and other aspects of this new development - however, you have failed to state how far this "minimising effect" will go. For all we know, you could just be planning to plant one tree, where 1000 is necessary to reduce pollution levels. My father used to cycle, and still does so in this area - as do I. He has informed me, and I am also aware that it is not safe anymore, with current levels of traffic - building more property and increasing traffic will also increase the risks of accidents in the area. I remind you here of the statement on your website - "Suffolk Coastal... Where Quality of Life Counts". I can only assume that if you get knocked of your bicycle by the increased traffic, and are wounded, your quality of life would not be very high. I advise you to consider this before ignorantly building more unwanted property in our local area.
Also, referring back to my earlier point of you website statement - "Suffolk Coastal... Where Quality of Life Counts", I assume that you are talking about the quality of life for not just humans, but for the plants and all sorts of creatures exactly where you intend to build - therefore destroying their habitat and no doubt killing many in the process. I remind you that some of the sites have been granted a special status, such as AONB and SSSI. I believe that it is the council's role to protect these areas rather than actively promote development upon them? "Where Quality of Life Counts". Remember that. You're not being fair to anybody here by building upon that site - plants, wildlife and humans alike.
I also believe in your report that you talk about creating a "stand alone" community? Having lived here for 8 years, I can competently inform you that we are a fully capable and well functioning "stand alone" community as we are, without additional traffic and huge extra strain on local schools. The schools don't need any more pupils - however, if you intend to ignore all of our objections and build the settlement anyway, I strongly advise you to fund local schools in the area for more teachers and resources etc. so they will be able to cope with the large influx of new pupils. In a survey conducted by Kesgrave High School, the following question was asked:
"What concerns do you have about the school?"
One response was:
"I hope that the school doesn't get any bigger as I feel that would be detrimental to its success."
I think this fairly shows that the schools in the area do not need more pupils - which would be an unquestionable result of a new housing estate.
Here is my 100 word summary which I believe is required:
I object to the new proposed development in Martlesham Heath due to the strain it will put on local schools, increased traffic, increased pollution and huge damage to wildlife. The public deserves more of a voice in the decisions being made regarding out local environment, and that the council needs to consider our "quality of life" before ignorantly building unwanted houses on an unsuitable site. The levels of traffic will undoubtedly be a hazard to any cyclists or pedestrians, causing more accidents in the area. I think the council needs to reconsider this planning proposal to a more suitable spot.
Thank you for taking the time to read this email. I hope that you will think about the points which I have made here and therefore change the plan to a more suitable area.
SCDC Response: 13, 16, 17, 18, 19
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: mr paul davey [157] Submission Agent Respondent ID: 157 ID: 157 ID: SUBMISSION The SCC sustainability report states that 'development (IP20 Adastral Park)likely to increase traffic considerably as this is already a heavily congested area however policy encourages use of public transport, foot and cycle provision and upgrade'. The fact that the area is already congested clearly indicates that the current policy has failed. The development proposals do not contain any new or serious means of addressing the considerable transport problems a new settlement of 2000 units would create. Without a solution to this problem the economic viabilty and sustainabilty of this project must be questioned.
SCDC Response: 10, 19
8 YOUR COMMENTS
Respondent Name: Mr Paul Jordan [8] Submission Agent Respondent ID: 8 ID: 8 ID: SUBMISSION I reluctantly agree with revised proposal PROVIDED that the related infrastructure buildings are not placed in the existing surrounding communities. In particular the required secondary school should not be in the existing Martlesham villages but rather should either be in the same loaction as the new housing or between Martlesham Heath and Foxhall refuse area (with appropriate links).
SCDC Response: Noted
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Mr Peter Robinson [385] Submission Agent Respondent ID: 385 ID: 385 ID: SUBMISSION 1. "Housing Distribution". P6 step 2 5.10. It's a pity that the 4th paragraph, "road, rail and other public transport networks", omits "walking and cycling". Surely this is a government requirement? It is included in your "Tspt Appraisal" after all!
2. Page 9. "Comments 1" - "Too many houses"... What are the traffic figures for traffic to Felixstowe and away from Felix. which lead to "am imbalance". Please forward these. And "2". It is naive to state that new housing "will provide the opportunity...to live closer..." Why are you not advocating that all of us live nearer our work, or vice versa? "Predict and Provide" is no longer a valid option for new transport infrastructure, we can only reduce travel by an array of other means, including that above. You do not address this major issue.
3. "Transport Appraisal" P49 5.2.2. Please do not refer to walking and cycling as "slow modes" - they are far more energy efficient, less polluting and less dangerous than "too fast modes"!
4. As above P49 5.2.3 "car reliance...is notable". Absolutely right - why no car sharing scheme or bringing lower CO2 options personally as well as generally, to people's notice, as is done elsewhere in UK.
5. P49. 5.3.1 etc. For those of us not intimately aware of every road name in the district, why no map? Silly!
6. P49. 5.2.3. I would disagree strongly that we "benefit from strong pedestrian + cycle links". The cycle/footpath along the A14 is both dangerous and terrifying, being so close to the carriageway. A major opportunity was missed when the parallel "rat-run" was implemented just try cycling along it! The route through the Trimleys and Walton is also dangerous due to parked cars in the cycle land - you should have the courage to make it a continuous white line, and to have it all the way, not stopping at every road junction and pedestrian refuge - Hopeless!
Policy SP21 - Felixstowe Objective 1 - How can you possibly exclude air pollution and traffic danger in Hamilton Road? Obj. 9 says it all! Have you given up on all who use our shops? See also Obj 14 Policy SP21. Obj 22. Completely unsustainable as many comments elsewhere in your report, confirm. "Improvements" only generate more traffic, more pollution, more global warming, more risk and danger to the community.' Why do you not look to solutions which are everywhere being discussed except here, about reducing the need to travel!
"Quality Control - Appropriate Assessment" Item 45.1. What investigations are in place with regard to the renting of radioactive waste to atmosphere and sea at Sizewell? Are you aware that those who regularly eat inshore fish in our area are regarded as the group to be studied for signs of associated cancers. Can you forward historical results of this work? What reports have been generated for air released radioactive waste? Please forward historical reports.
Transport Appraisal P8 - Map. Hopeless! How can we be expected to get to grips with all this detail when you offer us such rubbish! It could almost be deliberate obstruction! P17 your last paragraph identifying modal shift in Site 4 does not state any reasons for this. Why not? Surely attempts to get people out of private cars should have a much more significant place in your work? Is Site 4 a good example to address in other areas? (see last para. P20) Does the 2001 census include the huge increase in trips by bus brought about by free bus passes?
P27 etc. 4.2.2.In my view cycle provision in the area is poor, with the possible exception of Kesgrave which is often used as a National example of cycling to school. However after the fiasco of the trial roundabout at Tuddenham Road roundabout, which as laid out by Ipswich Borough Council, I believe, was lethal, showing just how little experience their road engineers have of cycling needs. You speak several times about roundabouts, and are presumably aware just how dangerous they are for cyclists and pedestrians. Why not bite the bullet and remove them, replacing them with intelligent traffic light systems? In addition, you will be aware that at each and every pedestrian refuge, the ? road space produces a dangerous 'pinch point' for cyclists, and of course any cycle lane disappears, showing you recognise this fact! Therefore, roads should be widened at all these refuges and if this is not possible, they should be moved to where it is! In addition you should be making strong arguments with the police about running red lights parking on pavements, not bothering to signal at junctions, and speeding. Finally national government should be lobbied in the strongest possible terms to follow European practice on insurance liability in all accidents - to alter our macho driving culture. Once these are addressed you will see a sea change in people getting out of their cars and walking and cycling.
P36. 445. This focus on "increased capacity" will solve nothing, it is well established, as I have already pointed out, that increased capacity only generates more traffic, and traffic jams help people decide whether their journey is really necessary or to go by alternative, and sustainable means. Your thinking is not sustainable.
P47. 5.1 Why no map!?
5.2.2 and 5.4.1 The route through Kirton and the Trimleys is not a safe enough route to encourage further increase in use. Cars parked, fast traffic and disappearing cycle lanes all contribute to making this sufficiently dangerous to all but the least timid of cyclist. Bite the bullet and make the cycle lanes continuous and permanent, then remove any parked cars! Be brave! I do not believe (5.2.3) that the "sites are proved to benefit", for the reasons above.
P51 5.3.3 Not another "link road". The one from the Trimleys towards Ipswich is an unmitigated and largely unneeded disaster - not to mention the cost in wasted resources.
SCDC Response: 7, 9, 10, 11, 25 Other comments noted The monitoring of radioactive discharges to atmosphere from Sizewell Power Station's is the responsibility of the Environment Agency and they hold a data base of this information. Details can be obtained from;- Chris Lloyd Tel. 01634 862875 or 07766781535 e-mail: [email protected] for Sizewell A and Gary Mc Meekan Tel. 07823532530 e-mail: [email protected] for Sizewell B
With regard to the monitoring of 'Critical Groups' of persons who eat particularly vulnerable food (i.e. inshore fish caught close to nuclear power stations) this would come under the scrutiny of The Food Protection Agency. Detailed information can be obtained from;- The Food Protection Division web address www.food.gov.uk/science/surveillance/radiosurv/
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mr Peter Bridge [250] Submission Agent Respondent ID: 250 ID: 250 ID: SUBMISSION OBJECTION with comments
I believe the proposed 1000 new homes in the Felixstowe area are too great a number.
I believe the Planning Inspectorate will find this proposal substantially defective because the assessment of "Infrastructure" requirements omits consideration of roads, rail and public transport; where problems, rooted in topography as much as politics, are already self-evident and can only be exacerbated by the proposed new homes.
All new Felixstowe building east of Dock Spur Roundabout [A14 Junction 60] potentially increases non-dock traffic at that roundabout. The railway is impractical for a majority of local journeys and the bus routes, which all use Walton High Street, congested.
This latest proposal (07/09) briefly exposes the infrastructure problem by reference (Para. 7.04, fourth point) to a link road between "Candlet Road and the High Road" (?High Street). The proposal then drops the roads issue.
Candlet Road was built to bypass Walton but this exit from Felixstowe is severely interrupted and impeded by the layout at Dock Roundabout because the flyover allowed for in the ground plan has not been built. In my opinion any idea that a town developer will finance improvements on the A14 Trans-European highway is absurd.
Average road capacity figures do not help. People do not and cannot average out their travel needs. There are peak times. The Dock company [and the LDF] predict increased Dock traffic on the A14 which can only worsen the town traffic blocking.
There must be added concern in Felixstowe for the irony that all new Ipswich-Eastern housing east of the A12 will potentially increase peak time traffic congestion at Seven Hills Roundabout [A14 Junction 58] and further impede traffic leaving Felixstowe.
There is a knock-on effect on the published infrastructure plan (07/09 - Appendix 1) under "Health" . This recognises a projected need for some extra capacity at Ipswich Hospital. It fails to recognise increasing delay to ambulances at peak times. There is potential for Felixstowe to become a death trap at peak times.
Concentration of school (in Felixstowe) and hospital (in Ipswich) facilities increases average travel miles per resident.
Reducing the average age in the community increases traffic congestion per resident. Most noticeably at school-run and worker commute times. Except for emergencies, old people travel off-peak, if they travel at all.
Bus public transport serving Felixstowe has its own critical capacity problem, related to topography, in that all principal routes operate out of central Ipswich and can just about maintain regular cycle times if traffic is not congested in Ipswich or Walton/Felixstowe. Congestion destroys the cyclic economy of the system and in practice leads to intolerable delays in the hourly service to Felixstowe's outer housing districts. Any development that could further congest traffic in the Felixstowe area thus has a disproportionate negative effect on bus transport. The proposal does not address this issue and is therefore again defective.
Each of the above factors adds an extra degree of skew to the infrastructure statistics underpinning the currently proposed (07/09) housing allocation. The aggregate effect will be to choke the local economy and massively degrade the quality of life.
The above leads me to the conclusion that I must object to the Core Strategy in its entirety as it affects Felixstowe and Walton. Apart from a small number of affordable homes for local needs, the rest should be distributed across the Coastal District to avoid infrastructure failures, minimise infrastructure costs, preserve the Felixstowe economy and quality of life and to maximise sustainability of smaller communities.
SCDC Response: 4, 10, 11, 12, 20, 22, 23, 26
8 YOUR COMMENTS
Respondent Name: Mr Peter Clark [133] Submission Agent Respondent ID: 133 ID: 133 ID: SUBMISSION I strongly object to the proposed development at the BT site. The site is totally unsuitable for such a major Town to be constructed
SCDC Response: 4, 16
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Peter Crofts [130] Submission Agent Respondent ID: 130 ID: 130 ID: SUBMISSION Dear Sirs,
Max 100 words, defintion of "countryside", impact on AONB wildlife, 6 lane alteration to A14, up to 6 story buildings, schools, 50% increase in traffic, diversity/concentration, 60,000m2 of commercial buildings, mineral extraction, preference to vested interests, "where quality of life counts" , NANT, dumping of problem from Felixstowe, market trough, sudden change from 1500 to 3500 dwellings, proximity to cycle priority route and RSPCA, oppressive nature of targeting correct paragraph; are just a few of the headlines.
For reasons, similar to Martlesham Parish , I protest at the proposal to urbanise this peninsular and wreck nature .Kindly withdraw.
SCDC Response: 4, 16
8 YOUR COMMENTS
Respondent Name: Mr Peter davies [134] Submission Agent Respondent ID: 134 ID: 134 ID: SUBMISSION This consultation has been ammended without proper communication with the local residents of Martlesham Heath, and the justification of 2000 homes and numerous other buildings for commercial use,is neither viable, nor acceptable. If we are living in a democracy then the local voices should be and will be heard. The infastructure will not support this proposal, and our envirionment will be severely damaged by this proposal.
SCDC Response: 1, 4, 16, 17, 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Peter Glen [421] Submission Agent Respondent ID: 421 ID: 421 ID: SUBMISSION Dear Sir,
I have the following comments relating to the Suffolk Local Development Framework (LDF). My comments are related to specific documents which support the LDF. I understand that the SCDC web page states that only comments related to the increase in housing numbers should be submitted . However I have been informed that the Head of Planning has agreed that comments will also be accepted on the other documents issued since the last consultation.
Summary
I object to the proposal in the LDF for the building of 2000 houses in the Martlesham area on the grounds of the significant impact this would have on the environment, traffic, health, education and the quality of life of those in the surrounding areas. The evidence on which this policy has been developed is unreliable and has overlooked the 'pepperpot' approach where the impact of house building is spread over a much greater area so significantly reducing the impact in each area.
Housing Distribution - Updated Preferred Option 07/09
Para 2.05
Comment: I believe that the building of houses in a few discrete areas is wrong and will cause severe impacts on the selected areas in terms of the environment, infrastructure, education and transport. A more sensible approach would be to follow a 'peppercorn' approach where small numbers of houses are built over a wide geographic area thereby reducing the impact of such building to a minimum. This approach has not been followed but the council has seen fit to actually reduce the number of houses proposed for Felixstowe/Trimley whilst doubling the number in the Martlesham area. This goes against the 'peppercorn' approach which would at least share the burden across the two sites thus reducing the impact. The allocation of house should be split a third each between Martlesham, Felixstowe and Trimley respectively.
Para 2.06
"The Council is maintaining its strategy of concentrating new housing at the major centres, market towns and larger villages remains the same, as does the strategy of development east of the A12 at Martlesham being in a single location forming a new community, but adopting a dispersed strategy for development in Felixstowe/Walton/Trimley."
Comment: I have read this paragraph several times and it does not make any senses. Please delete it or rewrite it in readable English.
Para 3.02 Section 4
Comment: This paragraph implies that BT will be a key driver in housing demand. However BT is currently reducing its head count considerably (15000 job reductions so far this year) and are continuing to follow a policy of outsourcing large number of jobs to off-shore third parties. As a result the number of BT staff in the area will REDUCE rather than increase.
Para 3.03
Comment: If the building of 2000 houses in the East of Ipswich goes ahead there will be significant impacts on existing facilities and infrastructure.
Existing primary and secondary schools in the area (Birchwood, Beacon Hill, Kesgrave and Farlingaye) are already at full capacity and the influx of new pupils will result in a severe negative impact on the standards of education that can be delivered. In due course new schools will be built but not for a number of years during which time a significant number of students will be adversely affected.
Existing roads will be drastically affected. The proposal to install traffic lights at the BT and Foxhall Rd roundabouts will cause:
Severe disruption to users of the A12 and residents of Martlesham Heath Significant increase in pollution due to stationary cars at these junctions Backing up of traffic along the A12 Severe disruption to Suffolk police who use this route as a primary access
Para 6.03 - Ipswich Policy Area point 1
"1,050 homes originally proposed represented the number required to meet the RSS minimum housing figures. It is of sufficient size to provide a relatively self contained community including a measure of health, primary education and a district centre type facility. (To reduce the numbers would mean not meeting RSS requirements as well as resulting in a development which was little more than an overgrown housing estate)."
Comment: Where is the evidence to support this statement ? Martlesham Heath was originally less than 1050 houses and yet managed to support a vibrant community with significant social activities, a school, shops and healthcare facilities. It is obvious that the 1050 figure is not correct.
Para 6.03 - Ipswich Policy Area point 2
"A larger allocation provides the basis for a significantly improved range of community facilities, eventually leading to a 'good sense of place' in the community created. However careful consideration needs to be given to see whether the benefits of additional housing would outweigh the disbenefits for example in relation to traffic impacts. The evidence suggests that the benefits do indeed outweigh the disbenefits." Comment: What evidence and how does it "suggest"? The government have published a report which concludes that regeneration of dwindling villages IS sustainable - by keeping village facilities intact and thereby reducing the need to drive everywhere
Para 6.03 - Ipswich Policy Area point 3
"One of the reasons for choosing this area east of the A12 is to create a stand alone community but closely linked to the existing and proposed employment retail and social provision at Martlesham Heath/Adastral Park business centre. The increase..."
Comment: This is in direct contradiction to para 7.03 in the conclusions which states; In order to achieve those objectives, integrate the development into the remainder of the Martlesham community, create complementary floorspace (eg retail and leisure), and enable the provision of supporting infrastructure.. You cannot have it both ways, either it is stand alone or it is integrated. This is confused and muddled thinking.
Para 6.03 - Ipswich Policy Area point 5
"Development east of the A12 both employment and residential will require improvements to be undertaken to the main and local road networks. However the impact of 2,000 homes as opposed to 1,000 on individual junctions etc when linked to new and improved transport infrastructure is limited but will help to secure the necessary developer funding to secure these upgrades to a good standard."
Comment: Where is the evidence to support this statement ? The Ipswich Borough Council LDF calls for a study on the proposal for a Northern bypass due to the significant traffic problems arising when accidents occur on the Orwell Bridge. This supports my own view that traffic levels on the A12/A14 are becoming problematic and the building of 2000 new homes directly next to the A12 will only exacerbate this problem.
Para 6.03 - Ipswich Policy Area Conclusion
"Doubling the numbers of new houses at Martlesham provides the impetus/opportunity to create a stand alone community which is of a scale to trigger the need for wider community benefits, particularly a secondary school, and improved public transport provision. It will also increase the amount of developer contribution available to pay for necessary infrastructure. A larger scale development also has the opportunity to provide for a more meaningful set of mitigation measures which can be provided to limit the impact of development on the nearby AONB and nature conservation interests of the estuary."
Comment: I completely disagree with this conclusion. The higher the number of houses the greater their impact will be - end of discussion. This is just window dressing trying to hide the significant impact that 2000+ houses will have on the Martlesham area.
Appendix 1
"Waste - No pressures on the Household Waste Recycling Centre identified as a result of the predicted growth. Developer contributions to be sought towards the proportion of costs of a new County-wide residual waste treatment facility and new transfer station not covered by PFI."
Comment: This sounds like a significant development and unlikely to be welcomed by local residents. Presumably this will need to be located close to where the new house go - another unacceptable development as a result of the proposed plan.
SCDC LDF Housing Allocations - proposed Strategy Transport Appraisal
I am commenting on this document as it provides key inputs to the LDF and it's conclusions.
Para 1.3 Study restrictions
"Given the time scales, it has been agreed with SCDC and SCC that the study has been progressed with the following restrictions:
- No new survey work has been undertaken;
- No formal new transport network modelling work has been undertaken.
- No consultation relating specifically to this study has been undertaken at this stage;
- This study comprises an initial round of investigations and conclusions, without subsequent iteration or optimisation;
- Without detailed traffic data available, and with the large range of uncertainties it is not yet possible to identify in detail a comprehensive schedule of mitigation requirements and associated costs; and,
- The trip generation and distribution calculations are largely based on 2001 census data which is considered to be the most appropriate data available and is suitable for this study, however it should be highlighted that it is now 9 years old and mode splits in particular are likely to be slightly different now.
It must be emphasised that this study has provided one isolated input to the debate on the merits of the proposed allocations. While the results are considered robust, and indicate no critical concerns, they need to be considered together with non-transport factors. Given the high level context of this study the specific transportation measures cannot be identified or costed in detail, however a broad understanding of the likely transport mitigation measures required has been identified, where possible, along with key issues for consideration in taking forward the proposed allocations."
Comment: In other words a key input to the LDF decision is based on traffic data which is out of date, incomplete and uncosted. This data should therefore be discarded as it is not fit to be used. Any decision based on this information is suspect and should be rejected.
Para 4.3.3 Site 4
"With regards to highway access to the Adastral Park site, given its location, it could have a number of accesses onto the local road network, primarily:
- Via the existing eastern arm of the A12/ Foxhall Road/ Newbourne Road Roundabout
- Via the existing eastern arm of the A12/ Anson Road/ Eagle Way Roundabout. This would require access through the existing industrial estate;
- To the east via a new junction onto Newbourne Road;
- A link/ loop road to distribute traffic between these access points through the site could also be provided. This could spread out and reduce the impact of a development at this location over these junctions which could be a key benefit.
For the purposes of this assessment it has been assumed that a 50:50 split has been assumed for the Newbourne Road and Anson Road accesses to the A12. It can be assumed that traffic destined for Adastral Park would have no impact on the exterior road network."
Comment: How can this last sentence be justified. Of course traffic to this site will have an impact on exterior roads. We are talking about 2000 houses plus a busy industrial site. You cannot possibly ignore this.
"Traffic to Felixstowe would travel south on the A12 to Seven Hills and then east on the A14. Traffic to Ipswich would disperse evenly along the Foxhall Road and Woodbridge Road corridors."
Comment: Where is the evidence to support this statement ? At peak times the Foxhall Road and Kesgrave (A1214) routes are congested and the siting of 2000 house will exacerbate this problem considerably.
Para 4.5.1
"Cycle links at Adastral Park to Martlesham and Kesgrave are in place, though cycle links to Ipswich Town are lacking in places and the distance from Site 4 is considerable."
Comment: A government survey has shown that only 10% of those who cycle to work cover more than one mile. It is naïve to assume that any but a small group of keen cyclists will be prepared to cycle the 7 miles into Ipswich on a route which consists of a mixture of footpaths, cycle tracks which traverse peoples front drives and road way. The notion, which supports the sustainability credentials of the proposed site, that it will support commuting via bicycle is false.
"Given the location directly adjacent to Adastral Park and the larger quantum of housing proposed, the cost associated with delivering effective public transport solutions would be considerably less than for the other scenarios. Whilst Scenario 1 offers significant overall potential for reduced car reliance, the impact on the local road network, in particular the A12, is unavoidable and considerable improvement would be required at a number of A12 junctions to preserve existing service levels."
Comment : Agreed. If substantial investment is not made in the road systems then the proposal in the LDF will have a significant impact on the roads, environment and quality of life of those people living in the area.
SCDC Response: 4, 7, 10, 11, 13, 15, 16, 17, 18, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Peter Hatcher [279] Submission Agent Respondent ID: 279 ID: 279 ID: SUBMISSION Dear Sirs
Site References:
693 Adastral Park (625519-244867) 769 Three Stiles Lane (625251-246584) 573 Land Opposite Black Tiles
I am writing to reject the above planning applications
Primary Reason for Rejection:
* The land at all three sites is prime agricultural land as is demonstrated by the fact they are currently all in full agricultural production. To turn this land over to housing is in direct conflict with the policies of the current government to produce more locally produced food and to reduce dependencies on imported food.
* Any development of housing must not be on greenfield sites.
[Site 693 is shown as a brownfield site but this is misleading as it is predominantly greenfield. It appears to encorporate site 644 (625180-245052) which is the exisiting Adastral buildings]
Implications of Greenfield development
* Reliance on imported food - increased food security risk. * Increase in road miles * Increases UK cost burden to import food * Increases UK job losses in primary agriculture but also packing and distribution * Uncertain quality of imported food.
Conversion of agricultural land to concrete is irreversible.
Building on agricultural land must only be undertaken when all other land options are exhausted with no alternatives - or there is a driving need to provide housing to support other critical local industries or clearly provide overwhelming benefits to the local community. There is no case for development of this scale in this area.
There can be no arguments we can put to our grandchildren to justify the destruction of this area particularly when all the other negative impacts to the Martlesham and surrounding communities are taken in to account. We chose to live and raise our children in a country community and not a town.
There is no demonstrable reasons in both the current and longer term climate for the need to develop this type of environment in these locations. Housing at these sites is completely inappropriate and I am therefore strongly opposed to the planning applications above.
SCDC Response: 4, 15, 16, 17, 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Peter John Robertson [186] Submission Agent Respondent ID: 186 ID: 186 ID: SUBMISSION The changes that existing residents of the parishes of Rushmere St Andrew, Kesgrave and Martlesham Heath demand are that your proposed "preferred option" to be scrapped as being to the most detriment of our environment, its ecosystems which encompasses more greenfield sites being given over to crammed in housing with densities of 40 to 50 houses per hectare. Added to this without putting in the infrastructure to support massive (over 450 dwellings per year, equating to 1080 persons) influx of people per year your scheme becomes untenable. All this new house building has already impacted very negatively on the quality of our lives what with greater congestion on over laden road systems, flooding of roads where drains cannot cope, bad parking on roads, overcrowding in schools (particularly the High Schools) leading to lower standards, long waiting times at health centres and doctor surgeries, police on beats rarely seen, teenagers having nowhere to engage their minds and expend energy in clubs that need to provide attractive events on a daily/weekly basis so they do not hang around being nuisances, and no day care activities for the elderly. In total all you are proposing is to build high density housing that is too expensive for most first time buyers (i.e. under £100,000 each) then maybe, just maybe, at a later juncture, if at all, put in the minimal possible infrastructure - too little, too late. All this diminishes the quality of existing residents lives - FACT. What we need is preferably NO new house building (after all central government dictats are NOT in tune with their 'banging on about' their so called democracy, NOR do the M.P's live around here). Failing this, if more than another 7,710 new houses need to be built in the Suffolk Coastal Area then they SHOULD BE DISPERSED AROUND THE AREA TO MITIGATE AGAINST POPULATION CLUMPING causing all the attendant problems from lagging behind infrastructure needs, urbanization of the above named parishes and the importing of problems to the area eg antisocial behaviour, congestion on roads, pollution and damage to the rural environment. The residents wish for any new population influx to be DISPERSED NOT concentrated in masses as you suggest for site 1, 2, 3 and 4 and in particular the proposed 2000 dwellings on the Adastral Park Area Site. Your surveys are all out of date - those for traffic congestion and infrastructure needs etc are for 2001 to 2005. I've read them all and find them woefully out of date and inadequate in recommendations. By dispersing new house building over a wide as possible area you will also disperse/reduce significantly all the problems and even negate any from occurring. The added population, if dispersed, will NOT contribute to the growing problems of road congestion, infrastructure requirements, social and economic difficulties. In todays climate of recession there aren't the jobs/careers available in sufficient numbers that justify clumping together vast numbers of people who are then reliant on a very few firms like B.T. for work or then having to commute, increasing traffic-jams and road congestion in and around Ipswich, Felixstowe and further afield (London etc). Why always greenfield sites? Is it a case of developers making more money and being a powerful lobby in local, regional and national governments to grant their wishes at the detriment of the environment and the quality of peoples lives? - I know so, not just suspect so. Brownfield sites (more expensive for developers to clear) MUST be used FIRST before any greenfield site development is contemplated. There are numerous, small and large brownfield sites in and around Ipswich eg the old sugar factory, the old bakery whitton sites, the Crane engineering works site to name a few. These could/must be used first for housing development if you must. You say that the proposed 2,000 dwelling site east of the A12 will be self-contained and self sustaining - what rubbish. NO development was ever so, no place is ever self-contained and can NEVER be self- sustaining (this is garbage) since people need to go shopping, go to work, got to dentists, hospital, see doctors, use roads, go out for entertainment and use amenities further afield etc. It is an illusion for any housing cluster to be self-contained or self-sustaining unless you are going to build all these facilities on site - I don't think so - DON'T LIE TO US No new housing site is beneficial to the area - it imposes constraints and problems for the environment (destroying chunks of it) and existing residents lives. We see NO benefits, except that the council will extract more tax from more people. Yet again we see our council tax go up year by year to provide facilities and more expensive housing and have a greater influx of people to our detriment. Where is the affordable housing? The only mention of it was a reference to it in the negative, in all the consultation documents since developers are disinclined to build affordable houses since to do so impacts on their massive profits - FACT. Does the building of another 950 new homes in the Rushmere St. Andrew parish mean you will build on heathland? - we suspect so on the wedge of land between Playford Road and the A1214. So much for your conservation policy hey! You wish developers to build on woodland as well (in Kesgrave parish) on farms and any greenfield site. NO we vehemently oppose this. We only see housing developments over the last 30 years - no new infrastructure - none in Rushmere St Andrew Parish only housing and more housing - no amenities while only 2.4% of our council tax generated in the parish is spent in the parish - absolutely a con - pure theft. Routes into/out of Ipswich, such as the A1214, Foxhall Road, Spring Road, Felixstowe Road, Nacton Road and Landseer Road, are all inadequate for the volume of traffic using them and all you want to do is provide more cycle and bus routes and a few upgrades to junctions to the extortionate tune of £16.25 million to £22.75 million, when you know full well that the vast majority of people use their own cars for convenience (door to door transport, no long waits at bus stops with heavy shopping or standing around in cold/wet foul weather) leading to further road congestion , not to speak of school car runs for the safety of their children. All due to new house building going on and on and on. A few years ago one could travel from Rushmere St Andrew along the A1214 in under 10 minutes, now it takes 35 to 45 minutes. That is the level of increased congestion due to continual house building in this and other parishes surrounding us - INTOLERABLE. More concentration of housing equates to the destruction of the countryside, farmland, heathland, woodland and urban sprawl. Is this the 'backdoor' to Ipswich Borough expansion and takeover of the parishes of Rushmere, Kesgrave and Martlesham Heath? We know so and is NOT what the public here want. More housing equates to traffic-jams on inadequate roads, overcrowded: schools, doctor-surgeries, clinics, hospital, and an overburdening of infrastructures which already lag far behind population increases and house development. Local, regional and national government bodies say they consult people - maybe but then promptly ignore public opinion and wishes so it is a case of consult and then ignore people and do what you originally wanted to do - witness Ipswich airport which the residents in the area wanted to retain, the council wanted to build on, so did so, the woodland in Kesgrave, the housing development on Grange Farm, Tower Farm and Purdis Farm, all on greenfield (farmland) and heath all wanted (by residents) not to be built on and guess what, the council had its stupid way and built on them all. Democracy? What democracy - a mockery of the word. The only thing that counts is profit, profit, profit - FACT. The new housing developments proposed ARE high density NOT appear to be high in number. The abilities of communities to absorb new housing development is NIL, precisely NIL, that is without destroying the quality of existing residents lives and more of the environment. Just get it: we don't want new housing developments on sites 1, 2, 3 or 4 - disperse the development and make housing affordable for first time buyers. DISPERSE NEW HOUSING ACROSS THE REGION AND THE COUNTY SO NOT TO COMPROMISE OUR LIVES, THE INFRASTRUCTURE AND THE ENVIRONMENT.
SCDC Response: 1, 3, 4, 7, 10, 15, 16, 17, 18, 19, 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Peter Ling [447] Submission Agent Respondent ID: 447 ID: 447 ID: SUBMISSION 5.10 You state that housing and jobs should be provided in tandem. There is too much emphasis in the Felixstowe/Walton/Trimley areas on employment at the Port. This will mean more traffic exiting Felixstowe on the A14.
2.05 I note that there is a reduction in the amount of housing proposed in the Felixstowe/Walton/Trimley areas. This is a peninsula that already has problems on the A14. As above too much emphasis is placed on 'Port employment'. The workforce at the port is diminishing. Even with the extension, current levels of employment may not ever be reached again. Container traffic has reduced by about 20% because of economic downturn. This may increase slowly however - other ports are taking traffic away from Felixstowe i.e. Norfolk Line have left. The Port operates a Priority Boarding System to even out traffic. If this were operated correctly, operation stack and the blockage on the A14 should not be required. They are in contact by phone, email etc and could stop lorries in yard, locally and out of county if the will was there.
3. Background You commissioned a study that you found unfavourable. You then commissioned another report that was biased. You do not listen!
5.10 There is only one road in - A14 and 1 out. Therefore this will need upgrading if you are are to increase housing in the Felixstowe/Trimley/Walton areas. The roads cannot cope now. If there are developments in the Trimley/Walton area the high Road could not cope. There will be complete homogenisation of the trimleys and Walton leading into Felixstowe so character and individuality in Trimleys will be destroyed.
5.18 The David Lock Study allegedly did not take account of the Felixstowe Port expansion. It did not need to as manning level, due to automation and modern working practices will not lead to more staff being required.
6.1 Councils response on 12/08 Consultation. People living in Ipswich would not move to Felixstowe to save a commute to the Docks.
6.4 Anywhere north of the A14 that is designated as road or housing development MUST IMPACT ADVERSELY on the AONB area
Appendix 1 Police. You state that increased facilities will be required to deal with anticipated increase in crime generated by growth. It is proposed that Felixstowe police Station is to close and that that the area will be Policed from Woodbridge. Everyone is totally aware that this will lead to a reduction in police personnel and service. Water. Living in one of the driest areas there will have to be a significant increase in supply of water. This is apparently not available. Green Infrastructure. The Haven Gateway Study has already identified a deficiency in natural green spaces. You intend to build on these existing spaces. Infill!
SCDC Response: 7, 12, 23, 24, 25, 26
7 THE UPDATED PREFERRED OPTION 7/09 HOUSING DISTRIBUTION SUMMARY
Respondent Name: Mr Peter Little [537] Submission Agent Respondent ID: 537 ID: 537 ID: SUBMISSION I do not feel that the proposed changes to the Preferred Option are adequately justified nor do they suggest a better method for meeting the broad strategy for development in the district.
Paragrpah 3.02 (4) of the Updated Preferred Option (UPO) states that the Council "recognises the wider economic role that the port of Felixstowe and BT research and development at Martlesham heath play both nationally and within the Haven Gateway sub-region." However, despite these two areas being given equal weight in this paragrpagh, they are treated differently within the UPO>
The proposal to reduce the allocated dwelling numbers at Felixstowe/Walton and Trimley villages is underpinned by the assertion that "...the financial crisis and resulting recession have significantly slowed the rate of expansion of the Port of Felixstowe." However, this is not reflected in the Core Strategy Preferred Option. Objective 2 states that "...new housing will be provided for some of the many workers who are currently forced to commute into the town...". Indeed, paragraph 3.50 continues, "It cannot be assumed that the Port's success and importance will continue indefinitely, though there are no signs of any change on the horizon."
The apparent concern over the current financial situation is not reflected in the discussions over increasing the dwelling numbers east of the A12 to "create a stand alone community, closely linked to the existing and proposed employment retail and social provision at Martlesham Heath/Adastral park business centre."
It is inconsistent for the Council to take the view that Adastral park will not be affected by the financial crisis and will be able to offer increased employment opportunities, but that Felixstowe Port will (despite clear evidence and statements within the Core Strategy preferred Option to the contrary). There has been consistent signs of increased activity at the Port, from the commencement of its expansion programme (to incorporate the UK's first deep water container capacity) to announcing a record number of rail moves per week late last year. The first phase of the redevelopment is expected to open in 2010, with the second phase operational by 2014. It is anticipated that such expansion will create nearly 1500 jobs.
This is in contrast to Adastral Park where there has been no firm commitment of expansion from BT or any other employer, and nothing approaching a similar level of activity. According to BT Group's annual accounts, the amount of free cash flow within the organisation fell by half in the last financial year, casting further doubt on BT's ability or willingness to support growth at Adastral park. In fact, there are a number of prominent signs offering "office space to let" in and around Adastral park. This does not suggest that the employment opportunities within the area will be able to sustain a new "stand alone community" of 2,000 dwellings.
In addition, as stated in section 5 of the table accompanying section 6.03 of the UPO, there is an aim to reduce the number of dwellings at Felixstowe port to emphasise the role of tourism by "protecting the setting of Felixstowe". However, there is no such concern expressed about increasing the housing quota at Martlesham which is located near to an Area of Outstanding Natural Beauty and estuary. The imposition of 2,000 dwellings in this area will impact heavily on nearby Woodbridge. Policy SP 24 of the Core Strategy Preferred Option (in relation to Tourism) states that "The protection of their [Aldeburgh and Woodbridge] settings will be of prime importance". The proposed 2,000 dwellings will destroy such a setting, and irrevocably damage the tourist industry in this area.
This damage to the setting of Martlesham is supported by the Sustainability Appraisal of Core Strategy and Development Management Policies dated September 2009. Paragraph 2.4 of the document accepts that the new policy is less sustainable due to "the additions of land abutting Adastral park". This Greenfield land includes current archaeological and biodiversity sites, and there is "additional concern about access to the countryside and proximity to the Deben SPA"
I would like to see the Proposed Changes struck out and the Prefferred option returned to its original state.
The additional increase in dwelling numbers at Martlesham cannot be supported by the employment opportunities at Adastral park alone, which is what the Council appear to be suggesting. In addition, if the Coucnil wishes to reassert the role of tourism within the wider area, then martlesham is clearly the location to start this process. Such an opportunity would be lost if the new changes were adopted.
The treatment of Felixstowe and Martlesham within the Proposed Changes document appears muddled and confused. Despite the Council itself asserting that similar considerations apply, it then applies a selective and unexplained approach to them. This cannot form the basis of sound policy.
SCDC Response: 4, 7, 15, 16, 18, 22, 24
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Peter Loosemore [283] Submission Agent Respondent ID: 283 ID: 283 ID: SUBMISSION As a long-standing resident of Martlesham Heath I have been priveleged to live in this award-winning village and value highly the benefits of our rural surroundings and good access to local towns.
I believe that the proposed plans for 2000+ houses on Adastral Park will ruin this area and will cause terrible traffic problems on the A12. The proposal to change the junctions at Foxhall Road and Martlesham Heath to traffic lights will cause horrendous congestion with the accompanying noise and pollution to Martlesham Heath.
Martlesham Heath village is almost hidden from view from the A12 but the design of the new housing is "high-rise" which will be totally out of character to the rural surroundings and more akin to an inner city development.
The proposal for a new footbridge will bring in extra cycle and foot traffic to Martlesham Heath with no obvious route through to Kesgrave and Ipswich. This would be highly undesirable and we certainly don't want a major cycleway cut through our woods which would ruin the amenity value of this area.
There is no evidence that the new residents will work in the local area so we can expect a significant increase in traffic on the local roads. Access routes into Ipswich are poor and coupled with the plans for a new Sizewell C power station to be built in the next few years will cause total overloading of the A12.
SCDC Response: 13, 14, 16, 19
2 THE CONSULTATION IN BRIEF
Respondent Name: Mr Phil Wilson [328] Submission Agent Respondent ID: 328 ID: 328 ID: SUBMISSION Dear SCDC
We oppose the updated preferred Option 7/09 Housing Distribution to the south and east of Adastral Park near Waldringfield Heath for the following reasons:
1) Traffic congestion on the single track road into Newbourne. The increase in the number of houses will cause be more traffic to be on the Ipswich Road into Newbourne and will make the road impassable. This is a long single track road with a few passing places. Already the traffic levels are bordering on causing all journeys to require one or more passing manoeuvres, and we have seen several road rage incidents due to the lack of any clear precedence and long distance between passing places, and because all the passing places are on one side. Even a small increase in traffic will start to add a delay to every journey for a great proportion of the day, but this development will cause a large % increase - enough to make it impossible for traffic to leave the village due to the incoming traffic rate. The traffic will increase due to: residents of the new development wishing to visit Newbourne for the Pub, Nature Reserve, employment, alternate routes e.g. to Felixstowe, diversions in emergencies, and the normal extra growth of native traffic. 2) A larger development will have more impact on the bordering area of Outstanding Natural Beauty. This is in the countryside many miles away from Ipswich . The addition of this many houses would have less impact on the environment if they were added to existing sites, such as Martlesham Heath, Grange Farm, etc - spread some on each site. These already have shops, schools etc. Indeed it has not been justified why there is less impact by building one huge village rather than adding a few houses to multiple sites such as Grange Farm, and other suburbs of Ipswich. 3) The placing of the development on the other side of Martlesham Heath from Ipswich effectively links the suburbs of Ipswich to the country village of Newbourne - a village of unique character. Newbourne will become a short walk, or bike ride, or car ride away from the new development. Unfortunately the character of the village will be impacted by the extra visitors, especially considering it is inevitable that in any population there will be a small proportion with criminal intent. Over the years as the development grows and its effect is felt by the Newbourne residents there be a steady predicable death of the character of a unique country village. Village stalwarts will move out, house prices will drop, town dwellers will move in, crime will rise. 4) Surely developments should not be in the countryside but be adjacent to Ipswich , not spiral outwards into the countryside impacting village life?
SCDC Response: 4, 16, 17, 18, 19
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Philip Smith [327] Submission Agent Respondent ID: 327 ID: 327 ID: SUBMISSION The response of SCDC to the concerns raised over developments east of Ipswich mentioned in section 5.09 has been to propose at least a doubling of houses to over 2000 in the Wadringfield, Martlesham, Brightwell area. It indicates SCDC have not listened seriously to concerns about this area. It opposes several of the principles outlined in section 5.10. In summary - impact on road, impact on agricultural land, protection to wildlife, development proposed is in isolation. The development represents a very expensive option. More dispersal of housing through Suffolk Coastal district should be seriously considered.
SCDC Response: 1, 4, 16, 17, 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Philip Smith [327] Submission Agent Respondent ID: 327 ID: 327 ID: SUBMISSION The large concentration of housing in a single spot with the associated car journeys plus commercial traffic will have a very serious adverse affect on the functioning of the A12. There is too much housing proposed in this location. All of the proposed housing should be dispersed across the whole of the Suffolk Coastal District and not concentrated in a single spot. The risk of serious disruption on a major road is too great. The policy as stated seems to be driven by securing funds for the would be developer rather than considering the impact upon the existing local population.
SCDC Response: 4, 13, 16
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Philip Smith [327] Submission Agent Respondent ID: 327 ID: 327 ID: SUBMISSION I am concerned about the impact upon the surrounding areas of wildlife habitat from such a large housing development. The large numbers of people would bring increased pressures on the local wildlife and habitat compounded by accompanying increases in domestic pets such as dogs and cats The AONB around Wardringfield and Martlesham is likely to be detrimentally impacted. The SSSI at Martlesham Heath would be detrimentally impacted by increased people pressure and recreational dog walking. The Newbourne Springs SSSI nature reserve would be similarly detrimentally impacted. Wildlife in areas of surrounding woodland would be detrimentally impacted.
SCDC Response: 9, 17
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mr Philip Speirs [307] Submission Agent Respondent ID: 307 ID: 307 ID: SUBMISSION * Government directives are that Brown field sites should be developed before Grade 1 Farmland, consequently I object most strongly to the land behind Treetops, hitherto farmed for food production, possibly being used.
* The A14 is the only main road into and from Felixstowe; this is already heavily used with dock and commuter traffic as well as the more occasional traffic. The proposal to create a link road across the field behind Treetops, with its attendant development of housing, small businesses and especially a Dot.comsupermarket development will inevitably aggravate the already heavy flow of traffic on Candlet Road and the rush hour congestion on the approach to the Dock Spur roundabout - have any Councilors visited this area between 8 a.m. and 9 a.m. ? This proposal has the potential to make the High Road connecting Trimley with Felixstowe even busier and more dangerous than it currently is.
* The above objections apply to the "Alternative master plan" prepared for Tesco Stores Ltd. by 'One20 Consulting' dated 02/09/09. This design and layout has not been thought through with consideration of the housing on Treetops and Ascot Drive. If this particular proposal were to go ahead, the car park and supermarket buildings would be backing onto housing; with the inevitable noise pollution for residents, especially from delivery vehicles. Why not site this aspect of the development so that the supermarket and car park back onto the A14 cutting ? Equally the placing of small businesses so near the back of numbers 2,4,6 of Treetops as on the plan is insensitive and surely not necessary given that there are clear alternative spaces nearer Candlet Road and backing on the horses' field; the proposed buildings are so close that no tree screening of these buildings from the houses has been proposed. One has to ask what height will these buildings be and what sort of businesses will occupy them - again noise pollution is an issue here. Surely if this development has to go ahead, why not turn the whole design around so that the business aspects back onto the A14 not onto housing and gardens ?
* Once again - this field is Grade 1 Farmland and home-based food production will increasingly be an issue in the future in this country. It should not be developed for housing and yet another supermarket for which the need in Felixstowe is questionable.
SCDC Response: 12, 22, 26 Site specific comments noted
1 INTRODUCTION
Respondent Name: mr philip squirrell [128] Submission Agent Respondent ID: 128 ID: 128 ID: SUBMISSION In respect of the proposed building of the new housing at Adastral Park,Martlesham Heath. In my view the A12 road change proposals are not suffient to handle the grartly increased traffic.
Four traffic light controlled crossroads will cause great congestion.
The traffic survey conducted on behalf of BT is flawed. The numbers of vehicles is incorrect.
The only way to handle the greatly increased traffic will be to creat a new road in place of Waldringfield Road to enter the new estate from the Foxhall Road/A12 roundabout.
The whole concept of 3000 houses is also flawed. Who will buy them.
SCDC Response: 10, 13, 16, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: mr philip squirrell [128] Submission Agent Respondent ID: 128 ID: 128 ID: SUBMISSION Please note my objection to this plan, and confirm receipt thanks.
I object to this plan on the basis that the road plan will create chaos and increase our carbon footprint due to long queues of vehicles.
If the development goes ahead a new road must be build from Foxhall roundabout/ A12 into Waldringfield Road.
The houses should be distributed around the County not in one or two locations.
The BT link with housing and jobs is a red herring.
SCDC Response: 4, 7, 13, 16, 19
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION Comments on Ipswich Eastern Fringe Infrastructure Study. Section 11 Summary of Key Findings.
Please see attachment. (The full text can be viewed via http://suffolkcoastal.jdi-consult.net/ldf/)
SCDC Response: 16, 20 Comments noted
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION Comments on Ipswich Eastern Fringe Infrastructure Study. Section 10 Community And On-Site Infrastructure - Green Infrastructure.
SCDC Response: 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION Comments on Ipswich Eastern Fringe Infrastructure Study. Section 7 Utilities - Water - Wastewater.
Please see attachment. The full text can be viewed via http://suffolkcoastal.jdi-consult.net/ldf/)
SCDC Response: 20 Comments noted
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION Comments on Ipswich Eastern Fringe Infrastructure Study. Section 7 Utilities - Electricity.
Please see attachment. The full text can be viewed via http://suffolkcoastal.jdi-consult.net/ldf/)
SCDC Response: 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION Comments on Ipswich Eastern Fringe Infrastructure Study Section 7 Utilities - Telecommunications.
Please see attachment. The full text can be viewed via http://suffolkcoastal.jdi-consult.net/ldf/)
SCDC Response: 7, 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION Comments on Ipswich Eastern Fringe Infrastructure Study. Section 6 Education.
Please see attachment. The full text can be viewed via http://suffolkcoastal.jdi-consult.net/ldf/)
SCDC Response: 20 Comments noted
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION Comments on Ipswich Eastern Fringe Infrastructure Study. Section 4 Health.
Please see attachment. The full text can be viewed via http://suffolkcoastal.jdi-consult.net/ldf/)
SCDC Response: 20 Comments noted
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION Comments on Ipswich Eastern Fringe Infrastructure Study Section 3 Options for Growth. Please see attachment. The full text can be viewed via http://suffolkcoastal.jdi-consult.net/ldf/)
SCDC Response: 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION Comments on Ipswich Eastern Fringe Infrastructure Study - Section 3 Options for Growth.
Please see attachment. The full text can be viewed via http://suffolkcoastal.jdi-consult.net/ldf/)
SCDC Response: 16, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION The following objections are made against the part of the table appearing in Paragraph 6.03 that deals with "Ipswich Policy Area - East of A12 - proposal to increase the numbers".
Table. Row 1. SCDC's response to the comment that "The numbers of houses currently proposed is too great " includes the words ""To reduce the numbers [below 1,050] would mean not meeting RSS requirements as well as resulting in a development which was little more than an overgrown housing estate)". This reveals SCDC's wish for a development that is substantially more than an over-grown housing estate, and hence the source of much local opposition.
Table Row 2. SCDC's response to the comment that "1,000 [houses] is insufficient to provide a standalone community" includes the words " . . . careful consideration needs to be given to see whether the benefits of additional housing would outweigh the disbenefits for example in relation to traffic impacts. The evidence suggests that the benefits do indeed outweigh the disbenefits". What is this evidence?
Table Row 3. SCDC's response to the comment "Adverse impact on existing communities at Martlesham, Martlesham Heath and Waldringfield" includes the words "The increase in numbers, provided it is the subject of a comprehensive development plan actually creates the opportunity to provide for a more self contained development but which triggers the need for additional infrastructure, particularly secondary education which is of wider benefit to other existing communities". A secondary school east of the A12 will not be filled by demand from 2,000 homes, so unless the true intention is to build more like 5,000 homes, it will serve other communities, resulting in a significant increase in traffic.
Table Row 5. SCDC's response to the comment "Unacceptable Impact on the primary and local road network" includes the words "Development east of the A12 . . . will require improvements to be undertaken to the main and local road networks. However the impact of 2,000 homes as opposed to 1,000 on individual junctions etc. when linked to new and improved transport infrastructure is limited but will help to secure the necessary developer funding to secure these upgrades to a good standard". I believe that the council should be focusing on what is right for the residents of the area it serves, and not on what it anticipates it can squeeze from developers (and hence indirectly the landowner) through S106 negotiations.
Table Row 6. SCDC's response to the comment "The existing social and community infrastructure cannot cope" includes the words "A thorough investigation into the Ipswich Eastern Fringe infrastructure requirements . . . have included an appreciation of the existing pressures on the area as well as any additional pressures which development may bring. The findings have dealt with what infrastructure is required, estimated costs of implementation and approximate timescales for delivery". The study does not guarantee that what is required will, to quote Paragraph 5.10, be delivered in advance of or in parallel with new development". Indeed the study identified that it is impossible to look more than three years into the future when planning infrastructure.
SCDC Response: 11, 16, 18, 19, 20
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION Paragraph 5.10 lists as many reasons militating against the current preferred option as it does in favour of it, and is therefore unconvincing. The second bullet states that "Any new or improved infrastructure should be provided in advance of or in parallel with new development", and yet the Infrastructure Study explains that this is unlikely to be achieved, and certainly not guaranteed. The third bullet states that "We should look first to re-developing old "brownfield" sites before looking to identifying [sic] new greenfield sites". The fifth bullet states that "New housing should allow integration with existing communities but at the same time should respect and maintain the character of individual settlements and communities". Common sense suggests that it will be difficult to achieve both these objectives, and that they are in fact mutually exclusive. The sixth bullet states that " . . . development should . . . respect the quality of the local environment", the seventh bullet that "protection should be given to wildlife and to the landscape, particularly those areas that are designated as being of national and international importance". Both imply that land east of the A12 is not a suitable location for a development of 2000 homes. The eighth bullet states that "housing and jobs should be provided in tandem", but there is no likelihood, let alone a guarantee, that this will happen. I do not believe that the changes to the proposed housing distribution are either justified, or that the necessary broad housing strategy for the District will be better met as a result.
SCDC Response: 7, 15, 17, 18, 20
3 BACKGROUND
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION Paragraph 3.02 (4) Even though the RSS is not apparently open to challenge, I will nevertheless remark that in my view, "the wider economic role" that the BT site at Martlesham plays is likely to diminish in respect of providing significant opportunities for employment. Where is the evidence that the BT site - not necessarily BT itself - will be a centre for employment in the period covered by the LDF? Unless the site provides jobs, and those jobs are largely filled by residents of the development located east of the A12, significant traffic flows will be generated by commuting.
SCDC Response: 3, 7
3 BACKGROUND
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION Paragraph 3.02 (2) Where is the evidence that "young people are leaving home earlier"? This is being used as partial justification for the need for more houses, yet anecdotal evidence is the reverse, and in my view credible because young people are faced with an unfair burden of total unemployment, debts arising from participation in tertiary education and in many cases an inability to afford even so-called affordable housing. The whole paragraph is lazily written, and in any case I am unclear why SCDC needs to rehearse the arguments attempting to justifying more housing since the figures it is seeking to deliver have been dictated by central government, and as a result cannot be directly challenged.
SCDC Response: 16
3 BACKGROUND
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION In Paragraph 3.02 (1) I cannot understand the logic behind the assertion that because the RSS covers the period 2001-2021, but the LDF must cover the period 2010-2025, it is necessary to extrapolate post-2021 housing growth at the rate derived from the RSS. In my view, the rate of housing growth dictated by central government remains unknown until a successor to the current RSS for the period including 2021-2025 is eventually promulgated. I note however that footnote 4 on Page 2 of the document states that ". . . the RSS is currently the subject of its own review. That review is looking at possible new housing options for the period to 2031. It has no impact on the housing numbers to be accommodated in the current Suffolk Coastal Core Strategy document on which comments are now sought". I would be surprised if the RSS review did not result in an increase in the extrapolated figures for housing growth in the period 2021-25.
SCDC Response: 5
3 BACKGROUND
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION There is a typo in 3.02 (1). It states that "For Suffolk Coastal, this district housing figure is 10,200 new homes between 2021 and 2021 or 510 new homes per year". This is further evidence that the document was written in haste, and that haste suggests that the impact of the proposed changes have not been properly thought through.
SCDC Response: Noted
2 THE CONSULTATION IN BRIEF
Respondent Name: Mr Philip Wilmot [214] Submission Agent Respondent ID: 214 ID: 214 ID: SUBMISSION Paragraph 2.06 refers to the SCDC ". . . strategy of development east of the A12 at Martlesham being in a single location forming a new community, . . . ", but this contrasts with Paragraph 7.03, which states that for the Ipswich Policy Area - East of the A12 there will be an allocation of 2,000 new homes made at Martlesham, and that the objectives of this allocation will be achieved by integrating the development into the remainder of the Martlesham community. SCDC appears confused as to the degree of integration it envisages, and local residents need clarity.
Also, Paragraph 2.06 doesn't read right, suggesting that the Housing Distribution Update Preferred Option 7/09 document was produced, or more likely updated, in unjustifiable haste. It states that "The Council is maintaining its strategy of concentrating new housing at the major centres, market towns and larger villages remains the same . . . "
SCDC Response: 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Reg Starkey [511] Submission Agent Respondent ID: 511 ID: 511 ID: SUBMISSION Dear Sirs,
I would like to register my objection to the proposed MASSIVE increase in the number of houses seeking to be built on my friends' doorstep.
However well planned or well-intentioned, 2000 houses are bound to have a huge impact on the Constable- country character of the area and its current idyllic quality of life.
I'm only a frequent guest in the area but I have come to love it and dread to think of it being degraded by excessive development.
SCDC Response: 4, 16
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Richard Atkins [227] Submission Agent Respondent ID: 227 ID: 227 ID: SUBMISSION This is a high-risk strategy. Such a large development will create huge strains. The road network is not suitable for such a large development; employment will largely be in Felixstowe or Ipswich, and roads and transport to Ipswich is poor. The impact on existing communities is bound to be significant and would be very negative on Martlesham, Martlesham Heath and Waldringfield. The adverse effects on the local AONB and SSSI are obvious and cannot be "mitigated". The feelings and objections of so many local residents cannot be ignored and misrepresented as they were in the first consultation.
SCDC Response: 1, 7, 9, 11, 12, 13, 16, 18, 19, 26
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Respondent Name: Mr Richard Atkins [227] Submission Agent Respondent ID: 227 ID: 227 ID: SUBMISSION The revised proposals entirely ignore all the objections raised initially. The impact of 2000 (or even 1000) homes will be huge, destroying the rural nature of the area and the lifestyles of current residents. The mitigation argument is a futile and unconvincing attempt to justify sacrificing the nearby villages and such a lovely area. The proximity of the A12 will not solve the transport problem, and massive road construction will only destroy the area. The idea of such a large development might have originally seemed appealing, but the consequences will be catastrophic and must not be ignored.
SCDC Response: 1, 13, 16, 17, 18
THE UPDATED PREFERRED OPTION REPORT JULY 2009
Respondent Name: Mr Richard Atkins [227] Submission Agent Respondent ID: 227 ID: 227 ID: SUBMISSION I'm afraid this is an attempt to punish the residents of Martlesham Heath, Martlesham and Waldringfield for daring to raise the obvious objections to the initial proposed development of Adastral park. This is a cynical ploy, compounding the errors of the first Preferred Option. The new option is of course far worse than the old. It is sad to see SCDC wasting money by putting this forward as a serious proposal.
SCDC Response: 16
IPSWICH POLICY AREA
Respondent Name: Mr Richard Staines [539] Submission Agent Respondent ID: 539 ID: 539 ID: SUBMISSION I wish at the outset to emphasise that although I am a Parish Councillor for Martlesham, I write as an individual voicing personal viewpoints on the matter referred to above. A few years ago I wrote to the Planning Services on the subject of future intended development at Martlesham, but I understand now that the present stage of the planning process has inaugurated a new process of consultation with a request from Suffolk Coastal District Council that any response reaches your offices by Novemer 16, 2009.
Unjustifiable and unacceptable increase in quantity of houses.
The purpose of this letter is to register in the strongest possible terms my personal dismay over the proposals envisaged at Adastral Park to situate a very large number of houses in what has been designated at 'Site No. 4'. I understand that the new Preferred Option report is being forwarded to deal with the anxieties invoked by Preferred option document of 12/08 and to 'recognise other changes in circumstances', but it remains unclear as to what these 'other changes' might be (Updated Preferred Option 2.02:1). There has been no independent study of Martlesham which I find puzzling, especially since Martlesham now appears to be the area containing the 'preferred option' for what will constitute an ambitious, if not overwhelming housing scheme, the development and presence of which will threaten to raise all kinds of interrelated problems that one suspects have not been thoroughly acknowledged and explored by Suffolk Coastal District Council. Three options had initially been suggested: for the intended development, namely, for it to be positioned (i) in one large site; (ii) to be comprised of an unspecified number of smaller sites at different venues; and (iii) an allocation involving sites of variable sizes.
Considering consultees' preferences: confusion and uncertainty?
In view of the fact that in the initial consultation that majority vote - 51% of those who were asked to express their preference - opted for (ii), could you explain why a decision had been taken to ignore their views and instead to favour the first option? Why had it been felt necessary to make the decision to concentrate the housing all in one site? And why was 'Site No. 4' selected, despite the recognition that it possessed significant defects and disadvantages? Why were soundly based conclusions, which had previously been published in Preferred Option 12/08, summarily overturned without careful thought and consideration for the views of other people? The density and mode of housing proposed in this new development will differ markedly to that already in existence. Moreover, the sheer quantity of housing envisaged now appears to involve a fluctuating figure apparently being persistently, even surreptitiously, upgraded: from 1050 to 2000, then from 2000 to 2500, whilst, at the latest forecast, from 2500 to 3000+. Accordingly, how can you depend on the validity of the previous consultation stage when the numbers of houses being planned since that stage have increased?
Unacceptable scale of development: infrastructural and environmental identity implications
The proposed changes to the Local Development Framework will not only sanction the construction of a highly visible and grossly obtrusive swollen housing/commercial development to the east of the A12 twice in size to that of Martlesham Heath, but permit an encroachment to within 88 metres of an Area of Outstanding Natural beauty. With its 66,000m2 of commercial premises, a plan is being presented so incoherently conceived and involving such a daunting scale of urbanisation that, on its materialisation, any meaningful structural reference to, or integration with, Martlesham Heath, its contiguous neighbour, would be lost, and which, if implemented, would lead to an inexorable devaluation of so many aspects of the 'quality of life' (which, to quote your logo, you say 'matters') enjoyed by people living in the villages of Brightwell and Waldringfield. Is such a devaluation really intended? In holding unresolved implications affecting the existing infrastructure, this projected development would not only accelerate the process of blurring pre-existing distinctions between 'the urban' and 'the rural', but lead to these villages being deprived of their familiar social and environmental identities. Furthermore the stated rationale offered as to why Suffolk Coastal District Council has apparently decided to decrease the quantity of proposed new houses to be planned for Felixstowe (Updated Preferred Option 1:9) is scarcely a sound one: the effect on jobs at the Port by the economic retardation has been felt similarly at Adastral park with ten thousand posts at BT having been terminated so as to enable the company to live through the current difficulties. It is hardly a reliable strategy to ground any future proposed housing and commercial growth on estimations, however tentatively made, of an employer's future employment capabilities since these can change at any time and without warning.
Unresolved problems concerning traffic density and flow: delay or denial?
Perhaps the principle objection that can be levelled at these proposals has to centre on traffic density and traffic flows: the Sustainability Appraisal had not only acknowledged the already congested conditions on the A12 but also that such congestion would increase, the Assessment Summary stating that the 'worst site for congestion' in the area was at Adastral Park (policy SP20: 6-7). How is this congestion eventually to be reduced? If the solution is to be found in the installation of traffic signals on the roundabouts on the A12 between the Bucklesham turn-off/roundabout and Martlesham Heath, then what guarantee can be offered that even longer queues will not follow as a consequence of such a measure? Where is the evidence to suggest that conditions will not disimprove? In 2004 the Atkins Report had highlighted the fact of long queues frequently forming, particularly at certain times of the day, on the A14 at the Nacton interchange, Orwell Bridge and the Bucklesham/Seven Hills roundabout. It is the belief of Suffolk Coastal District Council that such difficulties, which the presence of 2000+ additional new houses would exacerbate in increasing traffic by as much as 40%, could be mitigated merely by making footpaths and cycle tracks? Over the next few years as the recession recedes it could be very difficult for any developer to invest in infrastructure before gaining a reliable financial return on house sales. Infrastructure will be undermined and against a significant development, such as the one intended, it is likely that under funding could prove to have a greater effect. Too many instances of inadequate road infrastructure provision exist in the 'Ipswich Policy Area', most of which were developed and constructed in recent years but without the existing financial constraints. How do your published documents confront these factors?
Wild life: a lost cause?
There is a further issue which must be mentioned but all I can do in this letter is to touch upon it. It concerns the unacceptable impact the proposed development would have on wild life - path 51 from Spratt's Plantation at the end of Betts Avenue down to the lake and underneath the 33kv lines to BT has been a monitoring site for me since 2001 for butterflies, as indeed is the path down to the 'Moon and Sixpence' residential trailer site. the detailed yearly records of these observations are passed on to Suffolk Conservation. What is the justification for constructing a development that approaches to within 88m from an AONB? What does 'advanced planting' mean? What are 'large well-managed open areas for dog walkers'? However much Suffolk Coastal District Council fabricates a landscaping project, and creates artificial 'open spaces for dog walkers' and for 'tree planting', the character of this part of Suffolk - Brightwell and Waldringfield Heaths - will be lost forever. Thanks again.
SCDC Response: 1, 4, 7, 8, 9, 10, 11, 12, 13, 16, 17, 18, 20, 22
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mr Robert Stoner [153] Submission Agent Respondent ID: 153 ID: 153 ID: SUBMISSION I object to the Core Strategy and the effect it will have on Felixstowe. The number of houses to be built will destroy the subtle balance between port and retirement area that exist. I do not believe that the number of houses are required and that Felixstowe should be allowed to evolve to meet the immediate needs. A lot of the housing need could be achieved by allowing minor growth in the outlying villages where sustainable growth is required (and wanted)
SCDC Response: 4, 22
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Roger D Burrows [532] Submission Agent Respondent ID: 532 ID: 532 ID: SUBMISSION Dear Sirs
I strongly object to the new proposal to increase the number of houses allocated to the Ipswich Policy Area and I object strongly to the entire allocation of 2000 houses being built on the one site at Martlesham next to Adastral Park for the following reasons:-
Environmental concerns - The plans for the area would cause irreparable damage to the distinct landscape of the area. The Parish has strived to maintain a countryside feel to the whole of Martlesham which reflects our Suffolk Sandlings heritage which would be ruined by the proposed housing area and the necessary supporting infrastructure, eg. the loss of the well vegetated banks on either side of the A12. The diversity of wildlife would also suffer. The proposal would also increase the light pollution of the area.
The LDF seems keen to create a new community, they would in fact create a completely separate and isolated community far from the rest of the Martlesham. This would be detrimental to the social cohesion that is essential in community life and also enhances the lives of residents and improves community safety. It would also mean that many of the facilities that will be needed will not be easy for residents of the rest of Martlesham to use and vice versa.
Traffic and Highways - adding 2000 houses would require extensive changes to the A12 (at least what BT proposed in their planning application) which in turn will have a large adverse impact on the residents of Martlesham with larger traffic volumes and congestion which in turn could lead to traffic safety issues. In particular the residents of Martlesham Heath will have even more problems entering or leaving the only two access points (i.e. the BT and Tesco roundabouts). Increased traffic and congestion will also increase air and noise pollution. The road alterations needed will also have a devastating effect on the appearance and character of the entire area.
One of the justifications for the LDF proposal is that it will provide housing close to jobs. In practice if this development were to go ahead the houses would be occupied by people from anywhere who happen to be looking for a new home at the time and are just as likely to work elsewhere as is proved with Martlesham Heath where many residents work elsewhere. Being further out of Ipswich (a far bigger employment centre than BT) there could be more commuting traffic on existing roads to other parts of Suffolk, especially the A1214 and Foxhall Road both of which have heavy traffic which causes problems for drivers leaving side roads. New homes will also house extended family groups, many not working in the immediate area.
Public infrastructure and facilities - The LDF documents provides a list of what is thought to be needed but if a development of this size is to proceed in any way then there must be compulsion to provide all of the necessary facilities at the beginning or early on. Providing all of this infrastructure will also have an adverse impact on the area over and above that of the 2000 houses. For some infrastructure requirements this impact will have a serious effect on other parts of Martlesham away from Adastral Park (eg. providing foul sewerage facilities, extra upper school places, electricity supplies etc.). Of particular concern is that SCDC infrastructure studies have been carried out with conclusions in the LDF document without the promised consultation on the infrastructure appraisals.
Sports fields - a small but important issue is that the LDF documents appear to repeat the wrong assessment of public sports fields available for public use in Martlesham. If this is the case then the amount of space needed would be much greater because it seems that they may have included the Police HQ and Woodbridge Town FC, neither of which are publicly available.
If this development goes ahead Martlesham would be a very large village of almost 12000 people, only Felixstowe and Kesgrave will be larger! Martlesham will lose it's identity as a distinct semi-rural community, a key factor for people choosing to live here and a characteristic appreciated by all residents, and become just another urban sprawl with no clear focal points.
SCDC Response: 4, 7, 13, 16, 17, 18, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Ronan Doorly [264] Submission Agent Respondent ID: 264 ID: 264 ID: SUBMISSION The statements relating to how the effects of the natural environment will be minimised and infrastructure developed are clearly incompatible. How far does the minimisation go? What level of investment will be put into this minimisation? The report must be objected to on the grounds that no specific statements are made which provide for a measurable outcome. It is basically a lot of hot air which itself could do with being minimised, as it seems somewhat meaningless
SCDC Response: 4, 16, 17, 18
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Ronan Doorly [264] Submission Agent Respondent ID: 264 ID: 264 ID: SUBMISSION I strongly object to the use of the term "Preferred Option" as it is something of a lie. It does not represent the residents (council tax payers) views. The so called "standalone community" is an overly optimistic cover for an urban sprawl, which will have a servere detrimental effect on the environment. Will the council insist that all residents of this happy standalone club only use bicycles, to reduce pollution and infrastructure costs? How thoughtful
SCDC Response: 1, 17
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Ronan Doorly [264] Submission Agent Respondent ID: 264 ID: 264 ID: SUBMISSION I wish to strongly object to the housing development proposal for the BT site at Martlesham
As a local resident I already suffer from traffic problems in our area and am witnessing the gradual degradation of our environment.
The reports provide do not reassure me that realistic measures will be taken to make this development anything other than an urban sprawl spreading out from Ipswich.
I used to cycle in this area. It's not safe anymore, especially on the Foxhall Road between BT and Ipswich. The volume of traffic growth has far outpaced the development of infrastructure.
It would indeed be very helpful if you could also witness the destruction of the land around Suffolk Constabulary for the so called "Police Investigation Centre". If this is the approach to "minimising the effect" then why not just go flat out, save money and maximise the effect, it as does not seem to make a difference.
Please reconsider the scale of development. I would be grateful if you would bear in mind that there are many people in the area who will not object, simply because past history has given them little reason for optimism. I refer specifically to the approval granted for the building of Police Custody Cells in a residential area.
I hope in any case you will report honestly - it's very easy to find people who agree with a policy or plan (especially when investors see an opportunity), and to over report the enthusiasm. I am sure you would not do that.
PS we were once a "stand alone community", a concept to which the report makes such glowing reference. Oddly enough it doesn't feel like that since Tesco's arrived.
SCDC Response: 4, 16, 17, 18, 19, 20
8 YOUR COMMENTS
Respondent Name: Mr Roy Lambert [180] Submission Agent Respondent ID: 180 ID: 180 ID: SUBMISSION This consultation is to complicated and I think has been designed to put people off replying.
The community cannot support this number of houses without the appropriate infrastructure and I do not believe in the economic climate we are in the public services will not be able to provide the resources required to support the new development.
Enviromental issues are considerable there is no gas,water ,electric in the areas under consideration and new roads will have to be built causing great impact on wild life and the community at present.
The community can support 1,000 hoses but not 2,500.
SCDC Response: 1, 16, 17, 20
8 YOUR COMMENTS
Respondent Name: Mr Roy Lambert [180] Submission Agent Respondent ID: 180 ID: 180 ID: SUBMISSION The initial consultation was for a thousand homes and has now been changed to 2,500 in the form of a new community.
I think the area could have intergrated a thousand home but NOT 2,500. I object.
This is because of the infrastructure issues involved.
I have hardly touched on the enviromental effects because I believe the impact on the local population and community will be immense.
SCDC Response: 16, 17, 18, 20
KEY SERVICE CENTRES
Respondent Name: Mr Roy Lambert [180] Submission Agent Respondent ID: 180 ID: 180 ID: SUBMISSION I believe the consultation process is a tick in the box exercise and that permissin will be given whatever members of the public say.
I think the developers and B/T have more influence than the local community.
This will of course never be admitted to but I have seen how the committees operate and the representatives seem to always think they know best especially when dealing with public money.
SCDC Response: Noted
IPSWICH POLICY AREA
Respondent Name: Mr Roy Lambert [180] Submission Agent Respondent ID: 180 ID: 180 ID: SUBMISSION I object as I do not believe the appropriate infrastructure will be put in place whatever the council say.
The other public services will not be able to support the increase in population and strain on the loacl enviroment.
SCDC Response: 20
THE OVERALL STRATEGY
Respondent Name: Mr Roy Lambert [180] Submission Agent Respondent ID: 180 ID: 180 ID: SUBMISSION Where will the funding come from,all public services will have draconion cuts,there will NOT be enough staff for schools,doctors police etc.
All these services are under severe financial pressure and cannot cope now let alone with an influx of 2,500 homes.
Who will pay for the improvement required for water electricity, gas and the roads.
The last thing anyone would want would be to try and put this into place without the proper road structures and example of this is trhe Grange Farm Development.
I also say again who will buy all these homes or will the be housing association properties ?
SCDC Response: 20
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Roy Lambert [180] Submission Agent Respondent ID: 180 ID: 180 ID: SUBMISSION Who will pay for the infrastructure required to make this work.
The government have no money left they will be enforcing swinging cuts on the District council.
If the developers say they will pay haow will this be enforced.They will also put the costs onto the houses.
Who will buy all these houses,there is little or no employment in this area,
The hope was that B/T business park would provide that is not happening.
Because of the financial problems companies are reducing not expanding,this situation will exist for the next 2=5 years.
I repeat that public services will not cope because of the above reasons.
SCDC Response: 7, 20
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY?
Respondent Name: Mr Roy Lambert [180] Submission Agent Respondent ID: 180 ID: 180 ID: SUBMISSION As a result of the financal meltdown in public funds where will the money come from to fund the new roads,utilities, Doctors ,schools,medical services and police that will be required.
All public services face swinging cuts,there is not enough police now to police this area let alone another 2,500 houses.
The Suffolk Constabulary and being driven into collabaration with Norfolk as aresult of the drive to save money.
It will not improve operational policing at any level.
The police are not perform their basic role now because lack of supervision and direction.
Also who will but the houses in todays financial climate?
SCDC Response: 20
STEP 3 PRODUCE A HOUSING DISTRIBUTION STRATEGY BASED ON THE PRINCIPLES SET OUT ABOVE, WHICH MEET THE REGIONAL REQUIREMENTS AND COMPLY WITH NATIONAL PLANNING POLICY GUIDANCE.
Respondent Name: Mr Roy Lambert [180] Submission Agent Respondent ID: 180 ID: 180 ID: SUBMISSION
See previous comments re number of houses.
SCDC Response: Noted
STEP 1-THE SETTLEMENT HIERARCHY
Respondent Name: Mr Roy Lambert [180] Submission Agent Respondent ID: 180 ID: 180 ID: SUBMISSION To complete my last point with permission given for the new Police Detention Centre,it seems unless it is big business ordinary members of the public opinions mean little.
To this point, I understand that an allocation has to be decided upon but 2,500 for Martlesham is to many a thousand the area could cope with but not a community double the size of Martlesham Heath.
Why, because there will not be the infrastructure put in place to support the homes. Despite the comments of the committee stating that it will be put n place!
SCDC Response: 20
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT?
Respondent Name: Mr Roy Lambert [180] Submission Agent Respondent ID: 180 ID: 180 ID: SUBMISSION There has already been one consultation I believe the council are just going through the motion so it can say it has consulted and that permission will be given whatever we the public say.
As was the case with the permission for the new Police D
SCDC Response: Noted
3 BACKGROUND
Respondent Name: Mr Roy Lambert [180] Submission Agent Respondent ID: 180 ID: 180 ID: SUBMISSION Whilst I agree with the social comments regarding the need for housing it is a fact that the South East of the country and parts of Easy Anglia have proportionally more of the population than the Midlands and the North. This because of the belief of the the prospect of employment and I more affluent lifestyle.
However as a result of this the infrastructure is creaking and cannot cope with the population now let alone further substantially increases.
In the case of Martlesham 2,500 more houses which will probably have 2 cars per household.
The local roads are at maximum capcity now.
SCDC Response: 19, 20
3 BACKGROUND
Respondent Name: Mr Roy Lambert [180] Submission Agent Respondent ID: 180 ID: 180 ID: SUBMISSION Whilst acknowledging that more hosuing is needed because of the over population of the country and unchecked immigration.
I do not believe that enough brown field sites have been used to full capacity.
There are many sites withing Suffolk that could be redeveloped and used for housing.
SCDC Response: 4, 15
2 THE CONSULTATION IN BRIEF
Respondent Name: Mr Roy Lambert [180] Submission Agent Respondent ID: 180 ID: 180 ID: SUBMISSION I feel this consultation process is overly complicated and is designed to put off most people.
How are elderly people expected to negotiate this process when I am a recently retired professional man and have found it difficult to work through.
I believe it is overly complicated and will prevent true consultation.
SCDC Response: 1
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Russell Pope [141] Submission Agent Respondent ID: 141 ID: 141 ID: SUBMISSION The sheer scale & size of this development will swamp the local villages & have a devastating impact. The (approx) 5000 new residents will overwhelm the whole area and 'gridlock' will occur daily despite the proposed 'improved' road network. All villages will lose their identity and become part of the urban sprawl. Crime, rubbish, pollution etc will increase hundred fold. BT are quite capable of funding their own improvement from operating costs, and have no justification that they require income from the sale of land. Spread the LDF evenly over smaller projects throughout the County.DO NOT LET THIS DEVELOPMENT HAPPEN!
SCDC Response: 4, 13, 18, 19
IPSWICH POLICY AREA
Respondent Name: Mr Sean McGrath [430] Submission Agent Respondent ID: 430 ID: 430 ID: Mr Sean McGrath SUBMISSION We write on behalf of our client, Sainsbury's Supermarket Ltd, in respect of the recently published Housing Distribution, updated Preferred Option consultation document.
Indigo Planning has previously submitted representations on behalf of Sainsbury's Supermarket Ltd on both the Core Strategy issues and Options document and the Further Issues and Options document. These representations supported the allocation of new housing within 'Area 5', situated to the north west of the A14, as the broad area for the strategic housing growth to the east of Ipswich.
The updated preferred option does not 'Area 5' as a potential location for new housing. however, we still consider that allocating housing in this area would provide a sustainable and logical solution in accommodating the identified need for housing growth as it is in a location which is well served by its proximity to existing retail and employment opportunities, infrastructure and facilities.
Please keep us informed of the LDF process going forward. Should you have any questions or wish to discuss our representations further please do not hesitate in contacting me, or my colleague Leanne Croft.
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Simon King [512] Submission Agent Respondent ID: 512 ID: 512 ID: SUBMISSION Dear Policymaker,
We are writing to you register our opposition to the current proposals for development at Adastral Park in Martlesham. The proposal is based on Government estimates (made pre - recession) of the potential demand for housing. Clearly these estimates cannot now be relied on - the recession has impacted negatively on population and housing estimates. The number of empty properties in the area (eg Ipswich Waterfront) is proof not only of the slump, but also how an area with un sold housing stock can become a wasteland. We would ask that any decision about this development is delayed until new population and housing figures are published in 2010. People would then have a more accurate idea of the scale required.
Thank you
SCDC Response: 5, 16
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Simon Ruffle [259] Submission Agent Respondent ID: 259 ID: 259 ID: SUBMISSION As a frequent visitor to Waldringfield I wish to register an OBJECTION to the LDF housing changes. These are my reasons:
- It will swamp local amenities, character and quality of life.
- A previous, 90% smaller planning application (C/05/04930) was refused.
- Planning permission stipulates the existing quarry returns to Greenfield status. This is not addressed.
- The relevant SCDC committee holds two incompatible views on housing distribution policy.
- It is inconsistent with national and international policies on affordable housing, biodiversity, traffic and RAMSAR, AONB, SSSI and SSS sites.
SCDC Response: 9, 16, 17, 18
THE MARKET TOWNS
Respondent Name: Mr Stephen Beaumont [192] Submission Agent Respondent ID: 192 ID: 192 ID: SUBMISSION While agreeing with the increase in Minimum New Allocations (Greenfield) from 400 to 870 I do not believe the relevance of the probability of Sizewell C has been recognised. This is due to provide 4-600 new permanent jobs when opening in 2018 (current estimate). I believe this local requirement of new housing in Leiston should be recognised in the Second Phase (2015- 2020) if not the First Phase in order to avoid extensive travel and the accompanying environmental damage which would occur otherwise.
SCDC Response: 4
THE UPDATED PREFERRED OPTION REPORT JULY 2009
Respondent Name: Mr Stephen Clover [83] Submission Agent Respondent ID: 83 ID: 83 ID: SUBMISSION This ill-conceived afterthought is represented as a well-considered necessity. The idea that the expanded option is meritorious because it will make some public transport facilities more cost-effective (as a single example), is unreal. It is simple stuffing of the numbers - the Council appears to think that it might as well let the district be hung for a sheep as for a lamb, so long at they can dispose of the housing numbers. The impact of a sizeable, new town on neighbouring communities will be so much greater that the result will be one of very serious harm.
SCDC Response: 16, 18
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Stephen Clover [83] Submission Agent Respondent ID: 83 ID: 83 ID: SUBMISSION The East of Ipswich option, which the Council prefers, is one which the Council seeks to represent as the least bad option, having (in their assertion) various merits but which involves actually elementary, bad planning. By its proximity, it overwhelms neighbouring communities. It thrusts onto them a great burden which will undermine their fragile entities and stifle them. The vastness of its proposed housing numbers, on the edge of these communities, will destroy that which is demonstrably good and wholesome and important to East Anglian life. The Council appears to have become carried away.
SCDC Response: 16, 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Stephen Denton [125] Submission Agent Respondent ID: 125 ID: 125 ID: SUBMISSION Dear Sir/Madam Housing Distribution - Updated Preferred Option 7/09 I am writing to register my comments and objections in response to the consultation on the above document which closes today. (A 100 word summary is at the bottom of this letter) My grounds for objection are:- 1) The scale of the proposal is out of keeping with its location next to a rural area and very close to an AONB and protected sites 2) The implied housing density (45 per hectare) is far too high and will force a building form which is entirely out of keeping with all of its surroundings other than the BT buildings 3) Contrary to previously stated policy that new developments should not overwhelm existing settlements, this is what 2000 houses on that site will do 4) By agreeing to 2000 houses at this stage it will open the Council to pressure from BT to increase the number to 3500 as per BT's submission to the EERA call for developer proposals in their study up to 2031. 5) The Transport study is flawed. It contains no firm conclusion that the proposals it contains will work nor does it mention the impact of the planned growth on the Orwell Bridge, and does not cross refer to the LDF prepared by IBC council which calls for a northern bypass. 6) To position this as a very focussed consultation on merely a reallocation of numbers is unreasonable as doubling the allocation will have a much bigger impact on this area than the original 1050. 7) The consultation process is defective and has failed. The option of 2000 houses on the Adastral site was not one of the previous options put forward by the council. It has only arisen as result of reaction to pressure to reduce the proposed allocation for Felixstowe/Trimley. Had the figure of 2000 been quoted in the previous round then there would have been much more opposition to it, and the Council might have agreed to look at other options to meet the criticism voiced by residents in both the Felixstowe and Martlesham areas, and hence the current proposal would not have arisen. 8) The consultation process has been badly publicised and is unnecessarily complex. The arbitrary 100 word summary requirement makes it virtually impossible to produce a summarised objection which does not look like a NIMBY objection as reasoned argument cannot be put forward in the space of 4 text messages 9) It is clear that the decision making is being skewed by the site owners and the lure of short term S106 funding. The long term strategy for the whole of the Suffolk Coastal District should not be determined in this way 10) There is no study to validate that employers and other organisations will be drawn to this site as suggested by BT and apparently assumed by the Council. If it does not materialise then this would be the least sustainable option as it is furthest from other employment centres of the sites originally looked at. 11) There should be a full re-consultation based on real choice and which is not presented in a skewed fashion
SCDC Response: 1, 5, 7, 16, 17, 18, 22
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Stephen Double [516] Submission Agent Respondent ID: 516 ID: 516 ID: SUBMISSION Dear sir or madam
MY SUMMARY OF LESS THAN 100 WORDS IS BELOW IN CAPTIALS
THESE AREAS WOULD NEED UPGRADING
1 TRANSPORT LINKS
2 PUBLIC TRNSPORT LINKS
3 UTILITYS GAS, ELECTRIC, SEWAGE
4 FOOTPATHS
5 CYCLEPATHS
6 MARTLESHAM TOWN!
7 ENVIORIMENTAL IMPACT NOISE POLLUTION AIR POLLUTION
8 PEOPLE IMPACT
9 SAFETY FROM ROADS NO CRASH BARRIERS
10 EDUCATION & SCHOOLS
11 SOCIAL IMPACTS ON THE AREA
These are my comments to back the summary above
I really do not think this has been thought out. Martlesham has always tried to maintain its village status, to basically turn this village area into what can only be described as a town is unpractical. The infrastructure is just not here; we would have to build new road links as the Kesgrave road is virtually at a standstill at peak times as is A14, foxhall road and Woodbridge. There is not sufficient public transport any expansion to BT would only make this worse as it sometimes impossible to catch a bus at Martlesham heath as they are full of BT workers from 16:00 to 19:00.
As for the new proposed seven lane highway I hope the traffic lights work better than the system tried at Kesgrave and abandoned it is impossible to get out between 8:30 & 9:30 also in the evening There is not sufficient power supply so new pylons would have to be erected what an eye saw, we do not have enough facilities to treat effluent that is if we could even get it to the treatment plant. Currently the system overflow at black tiles when heavily loaded.
The new proposed bridge dose not link up with any of the existing foot or cycle ways.
The environmental impact is devastating loosing all our nature life trees and as for the noise pollution from the seven lane highway. Also my life was saved by the Orwell bridge crash barrier which will not be included I the seven lane highway!!
The people impact will be devastating as I am led to believe the same architect who was responsible for Ravenswood & grange farm has been commissioned to design adastrial new town the estates have social issues of people living too close parking is atrocious the estates are accidents waiting to happen with cars parked on the road and children playing in the streets.
Where are all these children going to go to school as our existing schools are all full !!!
Where are they going to socialise
I am not against change but it must be thought out and fit in with the current environment another development designed to fit in with the surroundings as Martlesham heath did with Martlesham with areas set aside for people not to see how many people we can fit in to the minimum amount of space this idea failed with high rise flats
SCDC Response: 11, 13, 13, 17, 18, 19, 20
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mr Stephen Hodgkiss [152] Submission Agent Respondent ID: 152 ID: 152 ID: SUBMISSION Whilst not without some issues the area east of the A12 would appear to be the least disruptive of the potential sites and most aligned with the applicable strategies and policies.
SCDC Response: Noted
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mr Stephen Hodgkiss [152] Submission Agent Respondent ID: 152 ID: 152 ID: SUBMISSION Section 5.10 appears to provide a very good framework around which to guide selection of potential sites - although I would add a further clause focused on ensuring that any potential development sites are suitable for sustainable building types.
SCDC Response: Noted
2 THE CONSULTATION IN BRIEF
Respondent Name: Mr Stephen Hodgkiss [152] Submission Agent Respondent ID: 152 ID: 152 ID: SUBMISSION It would appear eminently sencible to meet a substantial element of the housing numbers required by use of a single large developement i.e. a large development east of the A12, rather than potentialy spoil the character of the existing small towns and villages via backfil and infil development
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Stephen Videlo [300] Submission Agent Respondent ID: 300 ID: 300 ID: SUBMISSION Housing Distribution - Updated Preferred Option 7/09 response
Summary
I strongly object to the numbers proposed in the new LDF, which will make all the disastrous impacts of the proposed new town at Adastral Park even worse. This totally inappropriate development will urbanise a beautiful rural area and have an overwhelming impact on local communities, the road system and the environment. It is in close proximity to the Deben Estuary which is an internationally recognised and PROTECTED environmental site having SPA, SSI and Ramsar status and is within the Suffolk Coasts and Heaths AONB.
Response I strongly object to the housing allocation of 2,000 homes on the Adastral Park site on the grounds of the negative impact on the internationally recognised environmental site that is the Deben Estuary. The original allocation was totally unacceptable and this revision simply doubles the issues; the housing will be denser, no space for areas of heathland to regenerate and the new residents will be even more likely to look for recreation in the surrounding area. Moreover the runoff from the site will naturally drain through streams and creeks to the Deben Estuary with resulting effects on the chemistry of this highly sensitive ecosystem. The questionable premise that people walk, on average, 1km. from their homes (App. Ass. 6.2.35) brings Martlesham Creek within easy range at one side of the development. The premise is also undermined when, at a distance of only 2km. on footpaths, there is a beautiful riverside with a sandy beach and a pub to provide rest and refreshment, a circular walk along the river wall and a different route back mostly on footpaths. Furthermore, just over 1km. away on footpaths is the SSSI Newbourne Springs nature reserve, again with a pub a short distance away to act as a draw. Also in Appendix 6, the Suffolk Coasts and Heaths respondent states that even a 1% increase in visitor numbers would increase the harm done to the Deben SPA and the AONB. The "low to moderate level of terrestrial recreational activity at present" (App. Ass 6. 2. 26) already results in considerable disturbance to feeding birds. Increased human activity would result in even more disturbance, destroying one factor that gives the Deben Estuary its Ramsar status. Further disturbance on the banks of Martlesham Creek will result from the new sewage treatment works that will be required whether 1,000 or 2,000 houses are built. In sum, trampling and chemical contamination will adversely affect what is supposed to be a RAMSAR and a highly protected area. Other disturbance will be caused by light and noise pollution from the site itself.
The extra traffic generated by this development will cause major congestion to the road network causing even more problems on the Orwell Bridge and the Seven Hills roundabout especially during peak times and periods of bad weather. When accidents occur on these major roads the whole of Ipswich becomes gridlocked. The A12 struggles to cope now with current traffic levels and the replacement of roundabouts with traffic lights will exacerbate the situation and cause more congestion on other local routes with traffic trying to avoid them. Residents of Martlesham Heath will be subjected to the same problems as those at Grange Farm endured for many years.
Waldringfield already suffers from influxes of visitors in the summer months. There is officially no public car parks but people already park illegally and cause access problems. There are also no public toilets here and problems with human waste being deposited on the beach and around beach huts, already happens in hot weather. This is the nearest beach for the new town. This will not get any better with addition of 2000 houses.
The current job situation in this locality seems dire (I have been unemployed since finishing my University course last summer) and the addition of 2000 houses will not help the situation. BT have cut their workforce drastically over the last few years and there is as yet little sign of the situation improving. Where do I find work never mind the workers from 2000 more houses? Presumably we will all have to commute possibly to London or Cambridge, involving increased traffic movements.
I would urge SCDC to look again at the plans for houses at Adastral Park and not to pass this scheme that will have such a damaging effect on the surrounding communities and an internationally important wildlife site.
SCDC Response: 7, 9, 12, 13, 16, 17, 18, 19
LOCAL SERVICE CENTRES
Respondent Name: Mr Steven Lock [161] Submission Agent Respondent ID: 161 ID: 161 ID: SUBMISSION Physical Limits Boundaries to Local Service Centres such as Tunstall, upon which I have already made representations in February of this year, must be retained on their current alignment and not be subject to some form of 'flexibility when defining village envelopes' as is now proposed in the Updated Housing Distribution Provision Preferred Option 7/09. This notion will give rise to a great deal of uncertainty as to how potential sites outside the PLB's will be considered. It is an extremely vague statement and does not set out any criteria on defining village envelopes. It will give rise to a great deal of uncertainty to those affected by possible Site Specific Allocations. Villages such as Tunstall with limited facilities and certainly no shop or post office may cope with development within the existing PLB by way of infilling but nothing more. This revised proposal and wording are not justified and should be removed before the Core Strategy is finalised and published as a formal Submission document.
S.R. Lock FRICS
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Stuart Cooke [49] Submission Agent Respondent ID: 49 ID: 49 ID: SUBMISSION The area around Martlesham already congested at peak times (e.g. Tescos) and further development will substantially increase the traffic congestion. BT has been shedding staff for a number of years and the hope that a business park will provide suitable employment for the new development is unfounded especially considering the current economic climate with tax payers burdened with years of debt. The local wild life will detrimentally change for the worse with an adverse affect on the local villages. The original proposal for the number of houses may have been acceptable, this proposal certainly is not.
SCDC Response: 7, 16, 17, 18, 19
IPSWICH POLICY AREA
Respondent Name: Mr T Parkinson [408] Submission Agent Respondent ID: 408 ID: 408 ID: SUBMISSION I am writing to you concerning BT's proposed planning application for 2000 new homes on the outskirts of village of Waldringfield. There are many reasons why i feel that this development should be stopped, not least the effect it will have on the as yet unspoilt character of this rural community. The enormous increase in traffic travelling in and out of Waldringfield will undoubtably cause more congestion than the infrastructure of the village can now deal with . However the main reason why i oppose the new homes is the damage that it will do to the environment surrounding the village. It is almost impossible to imagine that the wildlife habitats at Newbourne springs and those that exist on the Deben estuary itself will be able to survive the huge influx of people, their cars, their pets and everything else that would come with a large volume of human activity to this site.
I urge you to reject the planning application on the grounds that this development would literally 'kill' the charm and rural character of the village of Waldringfield. Villages such as this have to be safe-guarded if we are not to end up with one whole swathe of suburban housing sprawling down the suffolk coast, with no space for wildlife or areas of outstanding natural beauty. i hope that you will agree with my concerns
SCDC Response: 16, 17, 18, 19, 20
8 YOUR COMMENTS
Respondent Name: Mr Terry Gaskin [129] Submission Agent Respondent ID: 129 ID: 129 ID: SUBMISSION I strongly object to the proposal from BT for 2000 houses at Martlesham Heath. This will have a serious environmental impact on everyone in the surrounding area, destroy the local habitat and the wonderful country side around Martlesham. I also believe this is being done purely on a how much money can we make out of this area by squeezing in as manty houses as possible. There has been no regard for the existing residents and this make me very angry and disgusted with the local council. I feel this has been done as quietly as possible to get this development in and approved...
SCDC Response: 1, 16, 17
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mr Terry Lomax [60] Submission Agent Respondent ID: 60 ID: 60 ID: SUBMISSION This is not consultation. This is merely lip service to the democratic process and takes no notice of the views of the people who will be most affected by these attempts to enforce superfluous housing onto the peninsula.
True consultation listens to the views of local ratepayers - without whose funding you would all be out of work.
True consultation is to dispute the dictat of political pygmies at EERA who insist that the eastern region MUST have extra housing - purely because their masters in Whitehall instruct them to do so.
The infrastructure is not here to justify this kind of expansion in the region. Insufficient employment and ever increasing mechanisation of the Port of Felixstowe is designed to decrease staff numbers, not increase them. Moreover, most of the local haulage companies have sold their interest to national corporations with the consequent disappearance of yet more jobs from the local environment.
We should become, as a nation, less dependent on imports which have seen this country brought to its knees through overborrrowing and an ever-widening trade deficit. That process has resulted in a slump in port activity. A trend for the future that will not change.
Furthermore, since much of the imported goods are foodstuffs, any attempts to narrow the trade gap will mean more productive agricultural effort by Britain's farmers and any scheme that lessens the amount of agricultural land through change of useage should be firmly resisted. Greebnfield sites shoul;d NEVER be used for building purposes.
SCDC Response: 1, 7, 22, 24, 25
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Thomas O'Brien [160] Submission Agent Respondent ID: 160 ID: 160 ID: SUBMISSION Dear SCDC,
I am a resident of Martlesham Heath and overall I am against the proposals for a new Adastral town (i.e East of A12 and adjacent to Adastral Park, Martlesham Heath). I would have hoped that the land behind the BT Research Labs (now called Adastral Park) would be used for further research and development employment, similar to the Cambridge science parks. These science parks create employment, yet have a small impact to local communities because they are so quiet at weekends etc. BT has tried to develop an innovation park but efforts so far seem to have been rather amateurish and small minded.
However I would like to endorse the building of a new footbridge crossing the A12 linking Adastral Park with Eagle Way on Martlesham Heath Village (passing through the gap between Coopers Road and Lancaster Drive). The new A12 footbridge is long overdue. It should have been built when the A12 dual carriageway was originally constructed to pass through Martlesham Heath. Its omission has meant that for many years residents to the South of Martlesham Heath, and who work for BT and other companies East of the A12, have had to take their cars to work instead of walking.
It is true that other residents in Martlesham Heath are objecting to the footbridge, but these people probably always drive everywhere and are blind to the benefits of walking. They complain of the nuisance caused by the footbridge, but overlook the fact that Martlesham Heath annually holds a pop festival and where alcohol is freely available. Wouldn't the pop festival cause more nuisance than a footbridge?
SCDC Response: 7, 16
IPSWICH POLICY AREA
Respondent Name: mr tim archer [351] Submission Agent Respondent ID: 351 ID: 351 ID: SUBMISSION the Adastral park development has a disproportionately high number of houses in comparison with the overall plan on a greenfield site. Infrastructure is inadequate. diversion of somehouses to the area near the suffolk showground is preferable
SCDC Response: 4, 16, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Tim Branch [531] Submission Agent Respondent ID: 531 ID: 531 ID: SUBMISSION Dear Sir,
Having made strong representations against the original proposal to develop the site for 1050 homes I am dismayed to learn of the new proposal to increase the number to 2000. All of my original comments will still apply but to reiterate I believe the "pepperpot" small development of 25 - 30 houses in a number of villages, rather than one village taking the complete development, makes a lot more sense.
Any new large development will make living in Martlesham for existing residents intolerable. Also the density required would mean new residents would have very little adjacent garden space and the local rural area would be devastated by an influx of so many people using it for leisure purposes.
It is absolutely obvious that the road system in this area is already up to capacity as can easily be seen during rush hour times around Martlesham and on the main roads into Ipswich during the early evening.
There are no local jobs for the new residents of the development. BT is looking to reduce numbers not growing. As any jobs will be away from Adastral Park then even more cars will be using the roads into and around Ipswich.
SCDC Response: 4, 7, 16, 18, 19
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Tim Elliot [388] Submission Agent Respondent ID: 388 ID: 388 ID: SUBMISSION AECOM Proposed Strategy Transport Appraisal This study is simply wrong, as it ignores the impact on Woodbridge and Woodbridge Bypass, which are already severely congested at peak period, and it ignores the impact of the proposed Ipswich Northern Bypass.
SCDC Response: 10, 14
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Tim Elliot [388] Submission Agent Respondent ID: 388 ID: 388 ID: SUBMISSION Housing Distribution - Updated Preferred Option 7/09 section 6.03 Comment 5 "However the impact of 2,000 homes as opposed to 1,000 on individual junctions etc when linked to new and improved transport infrastructure is limited but will help to secure the necessary developer funding to secure these upgrades to a good standard." This is simply wrong, as it ignores the impact on Woodbridge and Woodbridge Bypass, which are already severely congested at peak period, and it ignores the impact of the proposed Ipswich Northern Bypass.
SCDC Response: 10, 14
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr Tim Elliot [388] Submission Agent Respondent ID: 388 ID: 388 ID: SUBMISSION Housing Distribution - Updated Preferred Option 7/09 section 6.03 Comment 3 Adverse Impact, Council response: "Provision of structural landscaping can help with visual intrusion." Nonsense - the BT proposal calls for the construction of tenement blocks up to 6 stories high which will bring visual intrusion to every spot within a 5-mile radius
SCDC Response: 17, 18
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Tim Elliot [388] Submission Agent Respondent ID: 388 ID: 388 ID: SUBMISSION AECOM Proposed Strategy Transport Appraisal 4.3.3 "Traffic to Ipswich would disperse evenly along the Foxhall Road and Woodbridge Road corridors" - these routes are already congested in peak hours - the addition of more two thousand commuters (assuming as is typical today) more than two workers per household will create daily traffic jams
SCDC Response: 11, 13, 19
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Tim Elliot [388] Submission Agent Respondent ID: 388 ID: 388 ID: SUBMISSION AECOM Proposed Strategy Transport Appraisal: Likelihood of New Town Residents gaining employment at Adastral Park is near zero. The Council should note that BT's recent employment record is characterised by sharp reductions in the number of local residents employed, not just in recent months but as a process extending back years.The history of BT policy, and its likely future, is to move employment off-shore removing all opportunities for local residents.
The residents of the New Town will need to commute to work; this alone invalidates the Traffic Study as a basis for decision.
SCDC Response: 7, 10, 11
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mr Tim Elliot [388] Submission Agent Respondent ID: 388 ID: 388 ID: SUBMISSION AECOM Proposed Strategy Transport Appraisal 1.3 This Traffic Study is unacceptably inadequate as a basis for decision in that it is icomplete because of the restrictions listed.
SCDC Response: 10
1 INTRODUCTION
Respondent Name: Mr Tim Elliot [388] Submission Agent Respondent ID: 388 ID: 388 ID: SUBMISSION Likelihood of New Town Residents gaining employment at Adastral Park is near zero. The Council should note that BT's recent employment record is characterised by sharp reductions in the number of local residents employed, not just in recent months but as a process extending back years.The history of BT policy, and its likely future, is to move employment off-shore removing all opportunities for local residents.
SCDC Response: 7
1 INTRODUCTION
Respondent Name: Mr Tim Elliot [388] Submission Agent Respondent ID: 388 ID: 388 ID: SUBMISSION It is fundamentally wrong of SCDC to shape an LDF to one momentary situation when the LDF is a policy commitment lasting at least 15 years - in the proposed form it will set a precedent that poisons every planning decision until 2025.
SCDC Response: Noted
1 INTRODUCTION
Respondent Name: Mr Tim Elliot [388] Submission Agent Respondent ID: 388 ID: 388 ID: SUBMISSION Writing an LDF that effectively gives BT planning permission gives the company a huge windfall, but the costs both financial and environmental will be borne by existing residents of the area. This is fundamentally unfair. The SCDC does not exist for the purpose of increasing any company's profits at the expense of others, and must not permit this argument to carry any weight. The Council must not expect BT to show any loyalty to SCDC in the future, nor that it will keep to any undertakings that SCDC does not make legally binding.
SCDC Response: 16, 17
IPSWICH POLICY AREA
Respondent Name: Mr Toby Mace [275] Submission Agent Respondent ID: 275 ID: 275 ID: SUBMISSION A new town of 2000 new homes located East of the A12 would be disastrous for the village of Waldringfield. Waldringfield is a peaceful rural village within the AONB and its character would be changed by the close proximity of the new town. The new town residents would clog the access road to the river and the pub and they would park along Cliff Road. This is potentially dangerous, limiting emergency access to The Quay, where I live, and Deben Lane and Cliff Road. The peace of the village would be destroyed and the beach and river walls would become overcrowded. The river wall passing on front of my house would see a large increase in pedestrian traffic contributing to erosion of the river wall and impacting significantly on our privacy. It would also disrupt bird and animal life in the village where we have important habitats for barn owls, otters, avocets and other waders.
SCDC Response: 16, 17, 18, 19
THE OVERALL STRATEGY
Respondent Name: Mr Toby Mace [275] Submission Agent Respondent ID: 275 ID: 275 ID: SUBMISSION 2000 new houses will overwhelm Waldringfield and other existing communities. Quality of life of existing residents will be severely affected by pressure on all services and the new development would spoil the rural character of this area. It is far too close to the AONB and will adversely affect the wildlife habitat of the Deben and Waldringfield area and ruin the peaceful nature of the village. You should not allow a large development east of the A12 in this area.
SCDC Response: 16, 17, 18
3 BACKGROUND
Respondent Name: Mr Tom Coomber [41] Submission Agent Respondent ID: 41 ID: 41 ID: SUBMISSION I have read the document with interest but nowhere can I find any reference as to why additional housing is required. Apart from this pathetic government's insistence (for vote catching) that it is needed. I have yet to see a numerical housing waiting list for this or any other Suffolk areas. If one is available then I'm sure that existing residents would be more sympathetic to this proposal requirement.
SCDC Response: 3
THE OVERALL STRATEGY
Respondent Name: mr tom symes [272] Submission Agent Respondent ID: 272 ID: 272 ID: SUBMISSION The idea of a large new village/town here is misconceived. There is no need for it, other sites could be used to provide the houses needed without the huge disruption and cost that will be involved to support the development. Who will pay for the public transport links, community, social and health facilities?
SCDC Response: 16, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: mr tom symes [272] Submission Agent Respondent ID: 272 ID: 272 ID: SUBMISSION The idea of a large completely new settlement here is wrong. The scale will mean it takes more than 15 years to carry out. New homes will be built next to an operating sand quarry! Developers will only pay for the essential road improvements and social infrastructure as they sell houses. A secondary school costs c£27 million. The costs will have to be paid by the council and as we know for the forseeable future there will be no public funding so no money available. Result will be a vast isolated group of houses with no shops, transport or school.
SCDC Response: 4, 16, 20
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: mr tom symes [272] Submission Agent Respondent ID: 272 ID: 272 ID: SUBMISSION The selection of this as the preferred option seems to be purely because it fits with BT's application. This seems to mean that any other possible options have been rejected without any meaningful consideration. This cannot be acceptable.
SCDC Response: 4
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: mr tom symes [272] Submission Agent Respondent ID: 272 ID: 272 ID: SUBMISSION The objectives in 5.10 seem sensible. However, the suggestion of a very large new village/town under the BT proposals conflicts with many of them. There are no public transport links, no existing services or public infrastructure, the development will be separated from Martlesham Heath by the dual carriageway and from Martlesham by the Adastral Park Estate - hardly an easy place to get through. This will be an isolated development set down on its own and will take 15 years to to get built out. Hardly a location to make building a successful community easy.
SCDC Response: 4, 11, 16, 18, 20
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT?
Respondent Name: mr tom symes [272] Submission Agent Respondent ID: 272 ID: 272 ID: SUBMISSION Para 4.02 contradicts what is actually proposed. It talks about focussing development on existing settlements but what is proposed for the BT development is a wholly new large village/town in an area with no connection to existing settlements and no public transport links or any kind of services or social infrastructure. Just making it bigger doesn't make this any better.
SCDC Response: 11, 16, 18, 20
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mr Trevor C Mason [472] Submission Agent Respondent ID: 472 ID: 472 ID: SUBMISSION The Core Strategy, even with a reduced distribution of 1000 homes in Felixstowe, does not reflect local needs. Apart form a few affordable homes, the rest should be equitably distributed across the district to minimise infrastructure costs and maximise sustainability of smaller towns and villages which are being denied. I object to any new homes being built on valuable agricultural land and countryside.
SCDC Response: 4, 20, 22
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mr. Edward Pennington [324] Submission Agent Respondent ID: 324 ID: 324 ID: SUBMISSION Dear Sir,
I wish to protest most strongly to the proposal contained within the Core Strategy of your Authority`s LDF, to build approximately 2000 Residential Units on the Adastral Park site adjacent to Martlesham Heath.
Firstly, it is understood that the Core Strategy seeks to provide 1880 new homes to the East of Ipswich by the year 2025. As 800 can be accounted for by current planning permissions and opportunities within the urban areas, only 1000 homes will be required by specific allocation. Why, therefore, are 2000 residential units proposed at Adastral Park?
Secondly the deleterious impact upon the nearby AONB and Wildlife will be significant and irreversible, regardless of any attempts to provide or create protective measures.
Thirdly the Eastern expansion of Ipswich in planning terms, should be bordered by the A12 running North/South, i.e. no further development should be permitted to the East of the A12. This falls in line with any sound Planning Policy designed to protect and preserve the important green belt and open space between Martlesham Heath and Woodbridge.
Ipswich in effect has expanded eastwards via Kesgrave and Martlesham Heath to an absolute maximum and optimum level. Further eastern expansion of an already sprawling conurbation would inevitably cause a rise in crime, traffic congestion and all the other problems that over population of an area brings, thus reducing the quality of life for all its inhabitants.
In terms of employment, shopping and transport the further expansion of West Ipswich would be a much sounder Planning approach to the area. It is interesting to note that the A14 forms the Planning barrier to the West of Ipswich.
Please think again and try and preserve, and not destroy, what little amenity Martlesham Heath has left.
It is high time Planning Authorities pressurized the Government upon their very weak immigration policy, which in turn is putting so much pressure upon the demand for housing. Britain is too crowded and just cannot accommodate anymore people. This statement also applies to Martlesham.
SCDC Response: 4, 16, 17, 18
KEY SERVICE CENTRES
Respondent Name: Mr. Frank Noble [17] Submission Agent Respondent ID: 17 ID: 17 ID: SUBMISSION Dennington is a KSC. It has next to no employment in and around the village. There is therefore very little or no need for new housing to provide homes for local workers. New homes, affordable or not, will thus mainly house people employed out of the village. Thus more cars, more congestion,more pollution, because there is very little public transport. This situation applies to many other sites designated as KSC.
SCDC Response: 27
APPENDIX 5 - REVISED SETTLEMENT HIERARCHY
Respondent Name: Mr. Frank Noble [17] Submission Agent Respondent ID: 17 ID: 17 ID: SUBMISSION Dennington has been designated a Key Service Centre in the planning for the future of this area. I believe that this is inappropriate and request you to take account of my comments below in your planning deliberations with the appropriate Authority.
For a place to be designated as a Key Service Centre it should provide a range of facilities including the following:
A shop or shops for everyday needs. Post Office Doctor's surgery
Dennington has none of the above.
A Key Service Centre should also have employment opportunities of a greater extent than Dennington can offer. Dennington is surrounded by farms offering very limited employment and certainly insufficient to sustain the village let alone anywhere else. The single pub employs a chef and waiting help. There is teaching and cleaning at primary school and some domestic cleaning in private homes.
Public transport to and from Dennington is very limited and inappropriate for a place designated as a Key Centre.
At the most Dennington falls into the category of Local Service Centre and I request that it be re-designated as such.
SCDC Response: 27 Other comments noted
IPSWICH POLICY AREA
Respondent Name: Mrs A Maddison [535] Submission Agent Respondent ID: 535 ID: 535 ID: SUBMISSION Objections to the proposed increase in housing allocation on the area east of Ipswich.
Commenting on Assessment Findings and on Appropriate Assessments, plus wider comments.
SUMMARY My objections to the original proposal of housing on the Area East of Ipswich are even stronger with the proposed increase in housing numbers. Environmentally the scheme is detrimental to the AONB, SSSIs, SPA and Ramsar status of the area, this national and international recognition of the Deben Estuary must be respected by SCDC. Schemes to minimise the traffic, education and health care issues are poorly thought through. I urge SCDC to look again at whether so many new homes are really necessary and to examine alternatives with an open mind.
RESPONSE
Having strongly opposed the original housing allocation on "Area east of Ipswich", I find the proposed increase in housing numbers to be completely unacceptable.
The Deben Estuary is a highly protected area, both nationally and internationally recognised, but SCDC seems to be disregarding the warnings they have already received about the impact of increased pressure from visitors. App Ass Appendix 6 - the warden of Newbourne Springs SSSI comments on the already considerable disturbance to wildlife within the nature reserve and the Suffolk Coast and Heaths respondent states that even a 1% increase in visitor numbers would increase the harm done to the SPA and the AONB. The assertion is made (App. Ass 6.2.35) that people will only walk 1km from their homes. Martlesham Creek is 1KM from one side of the development as is Newbourne Springs on the other side and it has a pub as an added attraction. At only 2kms over footpaths, the riverside setting, sandy beach, and pub for rest and refreshment make Waldringfield an irresistible attraction with the possibility of a circular waslk home along the river wall and country lanes.
Car parking near the Deben is not as limited as is suggested (App Ass 6.2.37) Martlesham Church has a large parking area, Waldringfield has parking areas at the village hall, Church Field and the Church, as well as wide roadside verges. Hemley has wide roadside verges, beautiful views to Felixstowe Ferry and access to the river wall to get there. Cyclists are already using the river wall between Hemley and the Ferry - another tempting outing for the residents at Adastral park, which will create even more disturbance to the Dark- bellied Brent Geese whose presence feeding on the meadows alongside the Deben is one factor in the Ramsar status of the Estuary.
Green spaces within the housing development and the provision of a "Counctry Park" (Appendix 1 - List of LDF evidence base studies) - and where will that be? - are unlikely to outweigh the attractions afore mentioned.
The increase in sewage and grey water will require considerable work at Martlesham Creek water treatment plant with all the disturbance and pollution that is inevitable from such a project. The small snail, Vertigo angustior, found in the Creek (R.I.S. 22) is the second reason for the Ramsar status of the Deben Estuary, it is on the EU Habitats and Species Directive at the highest grade and international governments - let alone SCDC - are obliged to maintain favourable conservation status. The chemistry of saltmarsh and mudflats is in a very delicate balance which is easily tipped to unfavourable for the 14 named species of birds and plants which occur at levels of national importance (R.I.S. 21 and 22).
The Adastral park site sits on a high point at the 25m contour, run-off will naturally take place from the new roads, drives and roofs this will eventually get into the Deben Estuary, the closest point being the stream which runs through the Moon and Sixpence caravan park to the decoy below Howes Farm and thence to the saltmarsh and mudflats. Run-off will also occur to Martlesham Creek and into the stream in Newbourne Springs and thus to Kirton Creek and the river.
Aside from environmental issues, I object on the grounds of the inevitable increase in traffic on the small country roads which will be used as rat-runs to avoid the inevitable traffic hold ups on the A12 and A14. the proposed provision of 7 lanes at 3 junctions on the A12 which are only a few hundred metres apart cannot possibly maintain a good flow through the area. Expecting the new residents not to take to their cars for the journey to work but to walk or cycle into Ipswich which is the main source of employment (Assessment findings 2.2) is highly optimistic. The school run generates a huge amount of traffic and although the primary provision sounds adequate, the secondary provision on site will be late in coming. A disturbing feature of the proposed secondary education scheme is the suggestion that the school will be built for 420 pupils - the spectre of an even larger housing allocation hovers in sight.
Health care for this huge increase in population is commented on only in relation to an increase in GPs surgeries (App 1 - list of LDF evidence base studies). Ipswich Hospital had patients waiting outside in ambulances for 2 hours last spring because Accident and Emergency was full. With the increased population, not only will the ambulance be stuck on its way to the patient and again back to the hospital, there will be no space for treatment anyway.
As I understand it from Bretts they will quarry out the remaining aggregates and then hand over the site progressively to developers if the housing plans go ahead. Are the houses going to be built in the hole left behind or will there be infill with soil from elsewhere? If the former, what will prevent flooding of the houses in the hole? If the latter, will people want to buy houses on infilled ground liable to slippage and settlement?
SCDC Response: 4, 9, 13, 16, 17, 19, 20
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Mrs Alexis Smith [276] Submission Agent Respondent ID: 276 ID: 276 ID: SUBMISSION Although this consultation is "very focussed" it has a major impact on the whole LDF process. Planning for 2000 homes "East of Ipswich" forces the adoption of a single greenfield site which has many drawbacks.
The site is remote from any significant major employment - BT is not a significant factor in housing requirements locally. Development here will result in much more daily travel and journeys will be longer than from other sites. The sustainability analysis assumes that improved public transport and cycle paths will reduce this problem. This is an unwarranted assumption given the distances involved.
SCDC Response: 7, 8, 16
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Alexis Smith [276] Submission Agent Respondent ID: 276 ID: 276 ID: SUBMISSION Conclusion: "The area has lower negative impacts on landscape quality and public amenity overall than other potential alternatives. " This is contradicted by the sustainability report.
SCDC Response: Noted
5 HOW HAS THE HOUSING DISTRIBUTION BEEN DRAWN UP? AND HOW AND WHY HAS IT CHANGED?
Respondent Name: Mrs Alison Coote [309] Submission Agent Respondent ID: 309 ID: 309 ID: SUBMISSION Comments on the LDF Housing Distribution - Updated Preferred Option 07/09
Summary
This housing distribution ignores public opinion regarding the undesirability of a single large site for development. Furthermore in the case of the proposed site east of the A12 at Martlesham, it makes a number of unsubstantiated claims and conflicting statements which appear to be driven solely by a desire to match with the BT Planning Application and which take no account of genuine concerns raised by local residents.
Specific comments.
Note: These comments refer particularly to the proposal to build 2,000 houses east of the A12 at Martlesham (BT land).
Paragraph numbers refer to the housing distribution document.
2:05 'Substantial' increase in the allocation in the IPA east of A12 at Martlesham. So the document admits at this point that the increase is substantial. (Not trivial as implied elsewhere).
3:02. Figures quoted are from 2008 ie before the current Economic Crisis hit fully. It quotes 510 new homes per year to 2021, but then extrapolates this for a further 4 years to meet the requirements of the LDF - without any evidence for doing so. In the future anything could have changed. This paragraph also mentions BT at Martlesham and 'economic growth' - yet BT is currently laying off thousands of staff and has recently stopped its graduate recruitment programme - neither of these being actions of a company experiencing economic growth - rather the opposite.
This paragraph also claims that it 'broadly' recognises the quality of the Suffolk Coastal Countryside - in spite of being determined to dump a new town in the middle of it??
3:03 states 'the necessary infrastructure is there' - but it isn't!
4:02: 'Larger settlements where people already live and work' - but they don't already live and work east of the A12 at Martlesham south of Adastral Park, which is the location in question. 'Facilities and services are concentrated'... what facilities and services? Tescos???
4:04 mentions 155 homes per year in the IPA. (Ie east of the A12 at Martlesham). At what point in the development, ie in which year, would the infrastructure be upgraded: new schools built, public transport upgraded and road network (laughably) 'modified'??
Note: the transport studies provided are based on out-of-date figures and take no account of the full likely impact of all the proposals in this document, not to mention the proposed Ipswich Northern By-pass which is in the Ipswich LDF.
5:10 - 'new housing should not be provided in isolation' - but this would be isolated (a 'stand-alone community' as stated elsewhere). - 'New infrastructure should be provided in parallel or in advance' - no guarantees at all that this would happen - 'Brownfield sites should be used first, not countryside' - the proposed site east of the A12 at Martlesham is NOT a brownfield site. The mineral extraction planning permission was granted conditional on a return of the site to its natural state ie heathland, so this condition should be adhered to, which would make the proposed site countryside ie the last resort not a preferred option. - 'road networks should be able to cope' - there is NO evidence that they will and plenty of reason to suppose that they won't. - 'allow integration with existing communities' - how can dropping a stand-alone town on top of several small rural communities be described as 'integration'? - 'respect the quality of local countryside' - by flooding it with thousands more people?? - 'protection of wildlife and landscape' - the proposed site is within 1km of the Newbourne Springs SSSI and would totally destroy the Waldringfield Pit SSSI. Hardly protecting?? Newbourne Springs would be over- run by extra dog walkers and visitors. - How would the jobs be created? BT isn't providing any in the near future?
5:17 ignores public opinion ie the vast majority of the public are opposed to the idea of a large single-site development at all.
'Problems could be managed to an acceptable level' - Acceptable to WHOM?
6:03 Table re East of A12 (Martlesham) settlement.
Line 1 - actually you could meet the RSS requirements by having smaller developments spread throughout the IPA area. Line 2 - WHAT evidence? This is rubbish!! Traffic would grind to a standstill! Line 3 - 'provided it is the subject of a comprehensive development plan' - such as the provision of a Country Park - 'in Martlesham' - where on earth does anyone think there is space in Martlesham for such a park?? Is this really likely ever to happen? And what, realistically, chance does it have of 'mitigating the impact' on the local RAMSAR sites and local countryside and communities? Have the car journeys for people visiting such a park (if it existed) been taken into account in any of the traffic figures?? Most people will use cars rather than public transport (especially dog walkers!!) - see also BT's own transport survey - plus people driving their children to any new schools etc. Newbourne road - a narrow road with passing places - is already used as a 'rat run' as well as by walkers, cyclists, riders etc and cannot take much more traffic. Line 4 - 'lessen the impact' ie there will still be an unacceptable impact. Refer back to 2:05 'significant increase'. Line 5 - RUBBISH! The impact of 2,000 homes will be double that of 1,000 homes!! Upgrades will not solve these problems. The concluding row ignores the possibility of splitting the 1,050 homes across a number of smaller sites.
7:03. Is it just co-incidence that the new number is the same as that on BT's (initial) application? Or is the tail wagging the dog here, if not something more sinister?
8:02 Where is the evidence for 'large measure of agreement'?? - when the vast majority of the public DO NOT WANT a single large development??
Appendix 1 - why does this list of documentation not include the 'Appropriate Assessment'? Maybe because its findings are so nebulous and unlikely?
In summary:
This housing distribution ignores public opinion regarding the undesirability of a single large site for development. Furthermore in the case of the proposed site east of the A12 at Martlesham, it makes a number of unsubstantiated claims and conflicting statements which appear to be driven solely by a desire to match with the BT Planning Application and which take no account of genuine concerns raised by local residents.
SCDC Response: 1, 2, 4, 9, 10, 16, 17, 18, 19, 20
HOUSING DISTRIBUTION FELIXSTOWE/WALTON AND TRIMLEY VILLAGES
Respondent Name: mrs Angela Ashby [341] Submission Agent Respondent ID: 341 ID: 341 ID: SUBMISSION I live in Walton and use the A14 and High road regularly. I am concerned that the proposed large Tesco's and housing development will be too large bringing too many extra cars into an area only served by these 2 main roads which are vulnerable to traffic disruption. An accident on the A14 would leave just one road into the Felixstowe/Walton area which could rapidly gridlock leaving residents and emergency services effectively trapped. The proposed new school on the Orwell site will also have to increase in size if large numbers of homes are built in the catchment area, which now covers the whole of the Felixstowe peninsula. In my view Tesco's already has much too large a presence in this area of Suffolk and if a supermarket is felt to be necessary other companies should be given the chance to bid for a site, it begins to look to me as if Suffolk council are too cosy with Tesco's. A new supermarket (Lidl) is opening tomorrow do we really need another in Walton? Why does new housing have to be in such large numbers on a single greenfield site rather than distributed in smaller groups round the smaller communities in the county which need more people to keep their schools and shops going? Could it be because the council would then have to keep their rural services going instead of cutting buses and small schools and libraries?
SCDC Response: 4, 12, 26
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Ann Weidman [212] Submission Agent Respondent ID: 212 ID: 212 ID: SUBMISSION Dear Sir,
If the government insists new houses are built then they should be spread about surrounding villages to minimise the impact of congestion and air pollution.
If, however, a new village is to be built it should be designed to be independent from the beginning; not to put pressure on existing schools, roads and other facilities.
The A12 between Tesco, BT and the Foxhall roundabout is already too busy to be regarded as pleasant around peak times. I do not believe any solution, no matter how ingenious, will cause anything other than the congestion to get worse, with thousands of new houses.
One major, often somewhat overlooked result of congestion, besides delays, is air pollution and the consequential real negative impact on people's health. When financially assessing a project a huge cost should be estimated for effects on health and taken into account. It is clear that exhaust fumes are far worse for health, than cigarettes, for example. Only recently scientists announced a strong link between air pollution and reduced average life spans for people living in London.
Greed should not prevail when building new housing, i.e. building too many houses too close together, as buildings are in place for many many years.
People live in the countryside to get away from the hustle and bustle of town life. Already Grange Farm has caused congestion. It can only be considered as negative development if the area is to become more and more built up and congested, in the direction of a conurbation.
Please only allow fewer, larger, more spread out houses, as this has to be the direction to improve quality of life in the future.
SCDC Response: 4, 13, 17, 18, 19, 20
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mrs Anne Talman [47] Submission Agent Respondent ID: 47 ID: 47 ID: SUBMISSION We support the recognition of the case for locating housing development in the Trimleys (page 28) in so far as our two main identified areas are in line with all of the specified facilities. Our concern is that these have not been included in phase one though your update gives us optimism for phase 2 + 3. The sites identified on the attached plan in red and blue have the advantage of being "medium sized" and are in line with your requirements. They are already logged by you under ref. 383h. The plot coloured blue may be useful under an earlier phase being sited just before the Trimley boundary with access to a large roundabout end to the A14. We would also bring your attention to a small plot in Thurmans here where sheds are used for storage under a CLEUD - these could be dismantled if further non-green field sites are required under phase 1. As to phases 2 + 3 we remain strongly convinced that they meet all your criteria for housing development (red and blue on plan).
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Audrey Ruffle [367] Submission Agent Respondent ID: 367 ID: 367 ID: SUBMISSION Sirs As residents of Waldringfield, we thought we had made our objections very clear but they seem to have been totally disregarded.We said no to 1050 houses because of traffic problems, disturbance to wild life etc.etc.Now you want a plan for 2000 . Do the actual residents really have a say or are we ruled by faceless planners from Bedford. One very large field is at this moment planted and showing green crops. What has happened to Climate Change and the possible shortage of food. 2000 plus more mouths to feed in a small area. Absolute disaster.
SCDC Response: 1, 15, 16
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mrs Barbara Shout [258] Submission Agent Respondent ID: 258 ID: 258 ID: SUBMISSION Once again this Consultation contains flawed statements of fact.
Reduction in household size. This Peninsula already has a lower than average size of household but the SCDC figures quoted do not reflect this. The latest EERA study contains a graph which clearly shows that Suffolk Coastal has more deaths than births throughout.
Reduction in windfall sites figures. The only people advocating this are Developers, notable Mersea Homes. SCDC have used this suggestion in order to increase the number of new builds required. Convenient for them, but it is merely an exercise in 'figure manipulation'.
Affordable Housing. SCDC response to EERA is that they cannot deliver the amount of affordable housing required currently. With the infrastructure costs being mainly targeted at the developer this situation is very unlikely to change. The previous boast of 1 in 3 of all housing being affordable has now been downgraded to 'may' contain some affordable housing. This is unacceptable. Particularly as there has been NO consultation regarding stakeholder responses to Exception Sites. The LDF Chairman has been quoted as stating that there is no flexibility regarding possible development in the smaller villages and hamlets. This is incorrect. The Government has made provision for the flexibility of providing small business units and housing to meet local needs in these areas.
Housing imbalance. 6.03 Claims a significant imbalance between housing and demand. This is only a proven fact for affordable housing.
Employment figures were not met before the recession, this situation has only deteriorated.
Benefits. It is stated that the advantages of additional housing outweighs the disadvantages. This area already has an acknowledged deficit of infrastructure. Developers have failed in the past to deliver and there is no sound reason to believe that the same will not happen again. There is little evidence of government funding being available for infrastructure.
Regeneration is now the justification for over-development of housing on the Felixstowe Peninsula. We have a situation where 30 years have passed and, all that is in evidence is, a loss of amenities. This does not convince us that, under the current administration, good use would be made of any funding for regeneration. Given past history this is not likely to occur. This assurance by SCDC is unconvincing.
7.4 Here the word 'hub' could be substituted by 'linear development', something which SCDC have declared, on many occasions, is against policy. We now appear to have an application to consider before December 2nd. The David Locke Report did not identify any need for such as this. It appears to be a situation of 'planning request by the back door'. This is not an unjustified comment given that at the last LDFTG meeting the suggestion of
SCDC Response: 2, 4, 7, 22, 25 See affordable housing policies DM1 and DM2
8 YOUR COMMENTS
Respondent Name: Mrs Brenda Shakespeare [210] Submission Agent Respondent ID: 210 ID: 210 ID: SUBMISSION I cannot accept the reasoning that the site chosen is the preferred site given the protests raised on previous consultation. To build even more homes on Adastral park is ridiculous, there are no jobs there for so many, no infrastructure ready for such an influx. You say the A14 is overloaded from Felixstowe, it is far larger than the A12 which is already overloaded, and the 7 lane illustration looks graphically incorrect. What other way out from that site is possible given the Deben is one side!
SCDC Response: 7, 13, 16, 20
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mrs Carol Florey [166] Submission Agent Respondent ID: 166 ID: 166 ID: SUBMISSION Whilst welcoming the use of brown field sites I object most strongly to the possibility of the land behind Treetops possibly being used. It is GRADE 1 FARMLAND and under government directives should not be used for development (A Better Quality of Life and Planning Policy Guidance Note 7) I also object most strongly to a possible link road across this field. It is GRADE 1 FARMLAND The flow of traffic on Candlet Road would cause significant problems, likely to cause major congestion on the Dock Spur roundabout.
SCDC Response: 22, 23, 26
2 THE CONSULTATION IN BRIEF
Respondent Name: Mrs Carol Florey [166] Submission Agent Respondent ID: 166 ID: 166 ID: SUBMISSION
I support the reduced number of housing allocated to Felixstowe
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs caroline fulcher [234] Submission Agent Respondent ID: 234 ID: 234 ID: SUBMISSION
General objection, specifically concerns around the impact on education infrastructure.
SCDC Response: 16, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Carolyn Smith [366] Submission Agent Respondent ID: 366 ID: 366 ID: SUBMISSION Copy of Summary: (Details follow) The Council's response to this proposal does not appear to take the local community's concerns seriously. This substantial development should not be considered as a stand-alone community. The area is too close to Martlesham Heath and will have a severe detrimental impact on the local environment, local and national transport links and local community cohesion. The cost of providing services and altering the A12 will be much larger in comparison to sharing this housing load among existing towns and those smaller villages which are losing schools, shops and pubs due to falling numbers of residents.
Details: Environment: Martlesham Heath SSSI, lowland heath and a fragile habitat, already well used by residents from Martlesham Heath and Grange Farm. Proposed development leaves this site sandwiched between dense housing areas (with proposed pedestrian bridge across A12 providing easy access to SSSI and woods). Increasing numbers means increasing risk of damaging fires, more pollution from dog excrement and litter, and greater disturbance to ground-dwelling wildlife (including the nationally rare silver studded blue butterfly). Transport: proposed changes to the A12 would be disastrous. Well used as the main route from Felixstowe and Ipswich up to the east coast. Already very busy during rush hour (people gaining access to the BT site and industrial estate), in the summer and at bank holidays. Current proposals to develop the BT industrial site will further increase the traffic density. Then add the development of 2000 houses = 4000 cars on average, all using the A12 as their main exit. This will bring chaos. Proposed changes to accommodate extra traffic will not improve matters locally and nationally: 1. replacing 4 roundabouts with traffic light controlled junctions - well known to be less efficient in enabling smooth traffic flow - will result in gridlock on a main national route. Lorries will divert through unsuitable small country lanes affecting Kirton, Brightwell, Waldringfield Heath and Martlesham (just like Sproughton village and the A14/A12 junction). 2. increasing number of lanes from 2 to 4 will require more street lighting and reduce verge size alongside Martlesham Heath, cutting back on areas intended to reduce noise and vibration, severely affecting the existing residents, particularly in the areas bordering the A12. (Crossing the A12 on the footbridge from the industrial estate will demonstrate why the verge and mound are essential for noise reduction.) Standing traffic at red lights produces airborne, noise, vibration and light pollution, and moving off again produces more. Reducing verge size will affect local wildlife too, increasing the number killed on the road. 3. The A12 is the only traffic exit from Martlesham Heath. The proposed changes will make it very difficult to get to work and leisure activities, particularly in busy times. Buses will be held up too. 4. Managing traffic exit from the BT site via 2 sets of traffic lights will be very difficult. Local Community Cohesion: It has taken hard work to keep the communities in the parish of Martlesham as one. This will be unbalanced by adding another huge disconnected block of 2000 houses (with plans to increase to 3000). Large new communities in other parts of the country have had problems in generating a community feel, and vandalism, isolation and unrest have resulted. The current schools and transport links are sufficient and working well but the new schools etc will not be built until the houses are well developed and the local provision will be very severely affected in this time. This development will not contribute anything useful to the local scene and will instead bring tensions and extra costs and downgrade the amenities of the existing local residents. Will this be a 'green' development? It is a fallacy that people want to live near their work. This development will not be green in the way envisaged and the high density housing will not provide enough real space for people to want to stay within its boundaries for their leisure pursuits.
SCDC Response: 13, 16, 17, 18, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Christine Wass [249] Submission Agent Respondent ID: 249 ID: 249 ID: SUBMISSION We object to the new development because of the following: 1. It will destroy the areas rural character 2. Traffic congestion will be worse 3. The local education system is already over-subscribed 4. The houses will not necessarily be near to the jobs 5. The buildings will be a complete eyesore on the heath 6. Local villages will merge and become part of Ipswich town 7. Wildlife habitats will disappear 8. We need these fields to grow food in the future 9. Houses are not needed to create jobs 10.We have the right to walk on paths in open countryside where we live
SCDC Response: 16, 17, 18, 19, 20
7 THE UPDATED PREFERRED OPTION 7/09 HOUSING DISTRIBUTION SUMMARY
Respondent Name: Mrs D.V Shute [473] Submission Agent Respondent ID: 473 ID: 473 ID: SUBMISSION Dear Sir 1) While accepting that 1st time buyers need help very much, ensure that they are well provided for by building small units. 2) The infrastructure must be put in place before any houses are built, as the already existing parishioners suffer. 3) The charges for this development are not borne by existing parishioners.
SCDC Response: 20 Other comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Di Renselar [110] Submission Agent Respondent ID: 110 ID: 110 ID: SUBMISSION Re: Proposed changes to the LDF which would allow 2000 houses to be built at Martlesham
I am writing to object very strongly to the above change plus the original proposal to build a very large number of houses at Martlesham / Martlesham Heath.
This would now effectively allow a new town to be built which would destroy the identify and character of the existing villages in the surrounding area and place considerable strain on existing services (fire, hospital, water and electricity supply, etc).
We are frequent visitors to the area, mainly for the walking, cycling and sailing and feel that the building of a new town in such a large area of countryside will totally spoil the area itself, destroy large areas of wild life habit, plus totally spoil the surrounds for many miles, visually, with noise pollution and for recreation, to name but a few reasons.
There is no railway station nearby so all the massive increase in traffic would be via the A12 and surrounding roads. The greatly increased traffic would cause more noise and pollution. Not all the massive increase in traffic will use the A12. The existing smaller surrounding country roads will also be flooded with traffic and so will become more dangerous, than they are already. Cycling will also become very much more hazardous. The roads around the area are narrow with blind corners and bends and edged in some places with lovely old oak trees. The extra traffic may create a need for these roads to be widen which could result in the existing hedge rows and these old trees being lost, which would further destroy the character of the area.
Please reconsider, and if so many new houses are actually needed in the county, try to spread the effect by building much smaller developments within or around existing towns giving brown field sites priority, so the increase in traffic and strain on services is spread more evenly and the character of such a large area of countryside is not destroyed. Once it's lost, it's lost for ever.
Yours sincerely, D. Renselar
SCDC Response: 4, 15, 16, 17, 18, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs E A M Davidson [247] Submission Agent Respondent ID: 247 ID: 247 ID: SUBMISSION Objection to Adastral New Town Development
As a resident of Martlesham Heath I should like to register my objection to the revised LDF plans of SCDC for the development of "The area east of Ipswich", and in particular the creation of a town at Adastral Park.
With no opportunity for residents to comment, the housing distribution "East of Ipswich" was re-allocated. To the layperson it is highly suspicious that the chairman of this committee is so deeply involved with the area now relieved of many houses. Especially, when concurrently, the councillors of Martlesham were not consulted or included in this discussion and their housing allocation was almost doubled. A disgrace. One would question the moral integrity or the wisdom of allowing this. Common sense alone would dictate the requirement to consult with the very people with real ground and local knowledge. Everyone accepted that SCDC`s hands were tied by Governmental demands, but to select, from their own poll, the least popular solution to the problem of locating any East of Ipswich development is sheer madness. There have been one or two attempts to provide "local consultation" which have been both farcial and plainly, cosmetic. Conveniently BT and their architects are providing funding and ready plans which save SCDC effort and expense. That is obvious for all to see. Very few objected to a sensible "pepper potting" of new housing throughout the locality. We are not NIMBY minded but we do care about our neighbourhood. I note the sentence "Developer contributions will be sought to meet the need for increased facilities" - step forward BT presumably. I note the comment from SCDC that there is an intention to retain the character of individual settlements - clearly not in the Martlesham area!
There is a real anomaly in SCDC`s various statements that a) they wish "to create a stand alone community" and b)"integrate the new development into the remainder of the Martlesham community" and I resent the remark that Martlesham Heath - an acknowledged award winning New Village, is "little more than an overgrown housing estate." That is insulting, arrogant and frankly ignorant. Also, I note the comment," to integrate the development into the remainder of the Martlesham community." We do not wish to become part of a conurbation. SCDC should not place unacceptable demands on the local infrastructure, communities or environment. I cannot find any evidence of any real meaningful research into the assertion that residents of this new huge development will work locally. That falls into the category of assumption.
The thought of the already noisy and noxiously fume laden A12 having to deal with even more traffic beggars belief. Already, it takes little to cause a huge tail back when the Orwell Bridge is at a standstill. I should not imagine there are plans to widen that bridge. We do not want our stretch of A12 to be turned into an American Highway. 2000 extra houses will obviously prove double the original impact at the proposed site on our already hard pressed A12. It is unrealistic to expect any other outcome and any honest survey would reflect this fact.
Having spoken at length to some of our local Headteachers, I understand there is a united level of real anxiety among them about the lack of forward planning for schools. Our excellent local schools are not equipped with room to enrol any more pupils and indeed seem to have no desire so to do. They are already full. This whole enterprise will place our young, the next generation, at a considerable disadvantage educationally.
We need our council, who as taxpayers we employ, to develop a strategy which is sensitive to our needs. Housing should be dispersed over many sites, to reduce the damaging impact on any one area. It should only be sited where there is a genuine identified need, and local support. It should not place unacceptable burdens on the local infrastructure, communities or environment.
SCDC Response: 1, 4, 7, 12, 13, 16, 19, 20
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: mrs E Kennedy [444] Submission Agent Respondent ID: 444 ID: 444 ID: SUBMISSION I strongly object to the increase from 1050 to 2000 houses in area 4. Why should Felixstowe's allocation be reduced and the numbers in area 4 increased? Building eventually to the boundaries of the AONB risks spoiling forever a very special and unspoilt corner of Suffolk. The increase in housing will almost double the impact on Waldringfield.
Appendix 1, proposed strategy Transport Appraisal. 1. the road into Waldringfield is small and very busy already and increased traffic will compound this. There is no public car park and no spare land. It was said at one of your meetings, by a SCDC official, that because there was no public car park, people will not visit. This is ridiculous. It will mean that instead of parking the whole way up Cliff Road, on one side, at busy weekends, cars will park both sides resulting in gridlock. 2. The proposed roundabouts, between Martlesham and Seven Hills, will be too close to each other and cause queuing. 3. Newbourne will become a rat run to avoid the A12. 4. The pressure on the Orwell bridge, with increased housing and already increasing container traffic, particularly when stacking will be unsustainable.
Housing development. The increase of Housing in area 4 goes against public consultation e.g. Para 5.12 86% voted for two or three large sites or a number of small sites. Para. 5.17 The impact of 2000 homes over the original 1050 will result in an increase in congestion, light pollution and noise. The advantages of building 2000 houses in area 4 were quoted but never explained.
Could there possibly be a connection between the increase to 2000 homes and the proposed BT application for 2000 homes in the same area? It seems strange that BT are holding back, presumably waiting for the core strategy to be passed, enabling their plan to get the green light.
My point of view. You as a Council have a great responsibility not to turn this unique part of Suffolk into an urban sprawl. People choose to live in villages, despite the disadvantages. Please do not turn us into suburbia.
SCDC Response: 4, 12, 15, 16, 17, 19
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mrs Elaine Everitt [240] Submission Agent Respondent ID: 240 ID: 240 ID: SUBMISSION It is absolutely inappropriate to build such a large new development between Martlesham and Waldringfield. A "pepperpot" resolution would be better for the existing inhabitants and the newcomers. Schools are always built at the end of such large developments and pupils suffer in the meantime - Gorseland Primary and Kesgrave High schools have endured numerous "bulges" in the past. There will be little employment in the area, BT is constantly cutting jobs and the present traffic congestion will be made much worse. There is not the infrastructure to support a new stand-alone community. The natural environment would be ruined, surely AONBs and SSSIs are created for future generations to enjoy. Suffolk Coastal is a pleasant place to live and the residents should be allowed to put their case to protect this. There are already numerous empty properties, commercial and residential, in the Ipswich area so is there really a need for this development except to satisfy people in London who have no idea of the needs of Suffolk. Where will all these new residents come from? Where will they work? Our hospital is being downgraded already so we have to leave the county for some treatments. Where will the thousands of newcomers be treated? A Local Development Framework should surely be decided on locally. Do we not live in a democracy?
SCDC Response: 4, 7, 16, 17, 18, 19, 20
APPENDIX 4 - BREAKDOWN OF UPDATED DISTRIBUTION STRATEGY
Respondent Name: Mrs Ferial Evans [228] Submission Agent Respondent ID: 228 ID: 228 ID: SUBMISSION How will the infrastructure cope in particular the water resource? The widening of the A12 is alarming - more of the precious countryside destroyed. This push for extra housing is an ill-thought out policy of this Government and it is destroying all that is precious. This might seem an emotive response but quality of life is so important. That is not from a human point of view, but ecologically, this is destruction on a scale that is unsustainable.
SCDC Response: 16, 17, 19, 20
APPENDIX 4 - BREAKDOWN OF UPDATED DISTRIBUTION STRATEGY
Respondent Name: Mrs Ferial Evans [228] Submission Agent Respondent ID: 228 ID: 228 ID: SUBMISSION SC has done its best with distribution of the sites but it is still far too many on new sites, destroying the rural aspect and essentially farming land
SCDC Response: Noted 15, 22
APPENDIX 3 - HOUSING DISTRIBUTION CONSULTATION TIMELINE
Respondent Name: Mrs Ferial Evans [228] Submission Agent Respondent ID: 228 ID: 228 ID: SUBMISSION
The variety oh housing is well considered but far too many
SCDC Response: 3 Noted
APPENDIX 3 - HOUSING DISTRIBUTION CONSULTATION TIMELINE
Respondent Name: Mrs Ferial Evans [228] Submission Agent Respondent ID: 228 ID: 228 ID: SUBMISSION
I would caution restraint. Assessnment 'needs' may change with a new Government Policy after May 2010
SCDC Response: 5
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mrs Ferial Evans [228] Submission Agent Respondent ID: 228 ID: 228 ID: SUBMISSION This is a major development way too far. It is the thin end of the wedge of an ultimate conurbatio, in fact Martlesham will become an Ipswich suburb.
SCDC Response: 16, 18
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mrs G Esmarch [193] Submission Agent Respondent ID: 193 ID: 193 ID: SUBMISSION Apart from a small number of affordable homes for local needs, the rest of the homes to be built in Felixstowe, Walton and the Trimleys, should be distributed across the whole district, to minimise infrastructure costs and maximise sustainability of smaller communities. Therefore, I object to the core strategy in its entirety.
SCDC Response: 4, 22
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs G M Rea [484] Submission Agent Respondent ID: 484 ID: 484 ID: SUBMISSION My objections to the proposal are as follows:
1 Waldringfield and the surrounding area encompasses areas of Outstanding Natural Beauty and Special Scientific Interest. Any destruction of the natural healthland and countryside will also destroy these important sites.
2. Waldringfield is a small village with its only through road ending at the river Deben. The increase in traffic to the Maybush pub, situated at the riverside, is already significant. Outlying housing will cause immense strain on the already stressed small roads - there is no street lighting, neither are there pavements and the danger to pedestrians is considerable.
3. There is no public parking in Waldringfield. Naturally people living nearby will want to come to the river for sailing and walking but there will be nowhere for them to park; that leaves the likelihood of cars being left by the roadside which will cause bottlenecks.
4. This is a tourist spot where people come for its peace, tranquillity and beauty, as well as sailing and walking. This is not just about the problems additional large amounts of housing will cause the villagers, but rather the loss of an important 'green lung' for those who visit time after time.
5. Where are the jobs to sustain the number of proposed houses? BT is a large employer but it cannot possibly employ the number of inhabitants who will live in these houses.
6. By the time the building has been completed there will be no break from Ipswich to beyond Woodbridge - just one large urban sprawl. This is called 'Planning'? Our future does not look good in the hands of such short-sightedness.
SCDC Response: 7, 16, 17, 18, 19
IPSWICH POLICY AREA
Respondent Name: Mrs Gaynor Nichols [119] Submission Agent Respondent ID: 119 ID: 119 ID: SUBMISSION Dear Sir
We are writing to express our deep concerns re the expansion plans of Adastral Park
We feel very strongly that this is a very damaging proposal. It will generate an enormous amount of extra traffic on an already crowded road. This will lead to a massive increase in road noise and environmental pollution. Already in the mornings and evenings the volume of traffic leaving BT causes disruption to the whole area. And when Orwell Bridge is closed or has traffic works , which are due again soon, this impacts upon the area as well. We believe trying to access and leave the residential area of Martlesham Heath will become an impossibility, or at lest, extremely difficult. We understand the need for extra housing, but the impact of the enormous number of houses upon this area has surely not been properly thought out. The building of this new development will blight this are for many years, and the implementation of traffic lights and widened roads will just make traveling down the A12 a misery for other road users as well as the residents of Martlesham Heath and those employed by BT. We don't believe enough thought has been given to the nature of the grounds of BT which at the moment support abundant wild life. We don't believe the shopping facilities and local amenities will cope with this influx of people. Tesco's expansion has already impacted upon this area; this new development will sound the death knell for it. If we disliked the earlier proposal and this was for fewer number of homes we really dislike this proposal and we want to protest in the strongest way possible. We hope that you listen carefully to our views and resist the plans and either scrap them or reduce the size.
From Mr and Mrs Nichols
SCDC Response: 12, 13, 16, 17, 19
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mrs Gillian Hughes [215] Submission Agent Respondent ID: 215 ID: 215 ID: SUBMISSION Our comments are:
We object to the Core Strategy in its entirety as it affects Felixstowe, Walton and the Trimleys. Apart from a small number of affordable homes for local needs, the rest should be distributed across the district to minimise infrastructure costs and maximise sustainability of smaller communities.
SCDC Response: 4, 22
BASE REQUIREMENTS
Respondent Name: MRS HELGA BALLAM [269] Submission Agent Respondent ID: 269 ID: 269 ID: SUBMISSION The East of England plan needs to encompass a wider regional apportionment of housing need and those EMPTY dewllings already built or allocated in Ipswich especially at the Dock should be subtracted from the total required rather than extrapolating a previous increased housing need curve
SCDC Response: 3
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: MRS HELGA BALLAM [269] Submission Agent Respondent ID: 269 ID: 269 ID: SUBMISSION The existing water supply is subject to limitations in times of drought so it is hard to believe that there is sufficient existing capacity to deliver water to so many additional homes, especially as climate change is suggesting hotter, drier summers in eastern England, as elsewhere in the UK
SCDC Response: 20, 25
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: MRS HELGA BALLAM [269] Submission Agent Respondent ID: 269 ID: 269 ID: SUBMISSION Hospital care services are centred on Ipswich hospital which is already seriously over-burdened. GP facilities could well be installed with developer contributions but the hospital buildings, its staffing and carpark will not be funded by developers whi will be profiteering form a very large development. Other essential emergency services are similarly unlikely to receive funding to equip themselves to cope.
SCDC Response: 20
8 YOUR COMMENTS
Respondent Name: MRS HELGA BALLAM [269] Submission Agent Respondent ID: 269 ID: 269 ID: SUBMISSION This way of responding makes it very difficult for individuals to make coherent linked arguments, although it no soubt makes it easier for the council to "pigeon hole" comments in the appropriate areas
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: MRS HELGA BALLAM [269] Submission Agent Respondent ID: 269 ID: 269 ID: SUBMISSION "Unacceptable Impact on the primary and local road network" will inevitably occurr because the Orwell bridge is a bottle neck which is frequently closed or restriucted due to accidents. The roads into Ipswich are congested at peak times and a large influx of residents to the east of the town will struggle to gain access to health and town centre work or retail/entertainment facilities
SCDC Response: 12, 13, 19
SMALL WINDFALL PROVISION - REDUCE PROVISION FROM THIS SOURCE
Respondent Name: MRS HELGA BALLAM [269] Submission Agent Respondent ID: 269 ID: 269 ID: SUBMISSION Small windfall provision will contribute to energising existing communities. The broader view including all the empty units which have already been created in Ipswich and remain significantly empty must be taken into account before irreversibly damaging non-brownfield site locations
SCDC Response: 2, 15, 22
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: MRS HELGA BALLAM [269] Submission Agent Respondent ID: 269 ID: 269 ID: SUBMISSION Adverse impact on existing communities at Martlesham, Martlesham Heath and Waldringfield has not been mitigated in any way, indeed by doubling the number of houses the impact on such communities will be significant in terms of removaing the need for such few facilities remaining which keep the communities cohesive and distinct, such as schools, shop/post office and sporting amenities. The site when fully developed will adjoin an AONB the impact of so much human proximity and activity will have a significant detrimental irreversible impact. The road network will need to be extended to city sized proportions at key points to accommodate traffic
SCDC Response: 17, 18, 19, 20
HOUSING DISTRIBUTION FELIXSTOWE/WALTON AND TRIMLEY VILLAGES
Respondent Name: MRS HELGA BALLAM [269] Submission Agent Respondent ID: 269 ID: 269 ID: SUBMISSION "the key concerns raised by the public, namely to reduce the impact of one or two single large developments on any single community or the road network" have clearly been completely disregarded with the proposal to build a large development east of the A12. How can this be seen as a democratic planning process which takes account of public opinion?
SCDC Response: 16, 18
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: MRS HELGA BALLAM [269] Submission Agent Respondent ID: 269 ID: 269 ID: SUBMISSION In order to justify placing most of the housing allocation required into one site, this solution would need to be near perfect. It would be much less destructive to integrate housing into existing communities and in many cases this could contribute to some regeneration of communities, especially where the existing population is getting older with no "new blood" being able to move in
SCDC Response: 4
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY?
Respondent Name: MRS HELGA BALLAM [269] Submission Agent Respondent ID: 269 ID: 269 ID: SUBMISSION "concentrating strategic and large scale development at the main urban areas and towns" is set as an objective but the proposed development east of the A12 is a large scale development and is most definitely planned in a rural NOT urban area
"Limiting any adverse impact of new development on existing communities, countryside and wildlife" is set as an objective, but the proposed development east of the A14 will have a seriously detrimental impact on several communities - Waldringfield, Newbourne, Martlesham Heath, Martlesham
SCDC Response: 16, 17, 18
8 YOUR COMMENTS
Respondent Name: mrs j betts [126] Submission Agent Respondent ID: 126 ID: 126 ID: SUBMISSION I would like to object to the building of any number of houses on the BT site due to increased pressure on local infrastructures i.e. schools, services - health etc, roads. Our services are already under pressure and have been from 2005, especially health services with the return of the forces to the area which resulted in cuts of services to local residents i.e. maternity services.
SCDC Response: 16, 20
HOUSING DISTRIBUTION FELIXSTOWE/WALTON AND TRIMLEY VILLAGES
Respondent Name: Mrs J Catchpole [294] Submission Agent Respondent ID: 294 ID: 294 ID: SUBMISSION While there is a strong case for the proposal of new build housing there is also a strong case for protecting the environment and the flora and fauna of the local countryside. Brownfield sites must be used for housing, the amount of housing proposed could still be too many. The Gulpher Road area must be protected for future generations and the tourism attraction. The loss of countryside can never be reversed. it must be stated that alot of people who work at the Docks would never want to live in Felixstowe Especially people from the Ipswich area. These are two very different communities. There is still the problem of the A14 - it has been easier to travel on it while there is a reduction of lorries on the road due to the recession but I fear this will be short lived. There continues to be the problem of accidents and the closure of the A14 so access is a concern. In my opinion the emphasis of regenerating Felixstowe should be in developing the tourism side of the town and making it a pleasant place to visit with seaside, country and wildlife available to all.
SCDC Response: 22, 23, 26
8 YOUR COMMENTS
Respondent Name: Mrs Jacqueline Brinsley [383] Submission Agent Respondent ID: 383 ID: 383 ID: SUBMISSION We wish to object to the revised proposed development of a new town at BT Adastral Park, Martlesham, in the strongest possible terms.My husband and I treasure our rural way of life and will feel completely betrayed by our representative council, elected to serve it's existing residents, should the urbanisation of the villages east of the A12 corridor be allowed to continue in such an overwhelming manner.To approve this proposal, in whatever form,is utmost hypocrisy and will prove only that the powers that be are always in the pockets of the paymaster.Please listen to your people!
SCDC Response: 16, 17, 18
1 INTRODUCTION
Respondent Name: Mrs Jane Clifford [318] Submission Agent Respondent ID: 318 ID: 318 ID: SUBMISSION Before we even start, this whole process is flawed. The website is impossible for the public to work out.
There hasnt been enough publicity. The majority of people think the housing has already been approved and there is nothing they can do. This is a failure on the part of the council. Residents need to be made aware of this consultation.
Previously I believed in democracy and that our councillors acted on our behalf. Now it seems I was naïve. They are legally obliged to have consultations but there's no obligation to publicise effectively or listen to what's said.
SCDC Response: 1
APPENDIX 4 - BREAKDOWN OF UPDATED DISTRIBUTION STRATEGY
Respondent Name: Mrs Jane Clifford [318] Submission Agent Respondent ID: 318 ID: 318 ID: SUBMISSION This housing should be for a proven local need and there is zero PROVEN need for new housing in felixstowe.
We do not want or need housing on this massive scale in Felixstowe, Walton or Trimley. If we are forced to, we don't want it built on arable land, only brown field sites should be considered.
SCDC Response: 3, 22
APPENDIX 5 - REVISED SETTLEMENT HIERARCHY
Respondent Name: Mrs Jane Clifford [318] Submission Agent Respondent ID: 318 ID: 318 ID: SUBMISSION This is one of the most laughable parts of the document. Villages like trimley, with one road in and out and no facilities are boosted up and yet others like kirton who are the same are taken down in importance. It really makes no sense at all. And to make Walton a major center with its one, already congested road is simply laughable. I suggest you come down here at peak times and see how bad it is at the moment, let alone if you get your new housing wishes.
SCDC Response: 26, 27
THE OVERALL STRATEGY
Respondent Name: Mrs Jane Clifford [318] Submission Agent Respondent ID: 318 ID: 318 ID: SUBMISSION What i really object to is Walton continually being lumped with Felixstowe. We are not FElixstowe/Walton we are Walton! This goes to prove that our boundaries have been continuously eroded over the years. What will it be next6 Felixstowe/walton/trimley/ipswich/kirton just one huge urban sprawl??? Stop building on the greenland between us and keep us separate
SCDC Response: 22, 23
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mrs Jane Clifford [318] Submission Agent Respondent ID: 318 ID: 318 ID: SUBMISSION A few houses for the benefit of local residents, brown field sites, no problem, spread the rest fairly around the whole area, don't dump them on us. Some villages are crying out to be allowed to build a few houses. Dying due to a lack of young people living there. I work in education and last year there were 82 primary schools in Suffolk with more than 1/4 of places unfilled for lack of children. A few more houses in each village would make the schools and communities viable again.
SCDC Response: 3, 4
HOUSING DISTRIBUTION FELIXSTOWE/WALTON AND TRIMLEY VILLAGES
Respondent Name: Mrs Jane Clifford [318] Submission Agent Respondent ID: 318 ID: 318 ID: SUBMISSION Finally felixstowe council has woken up and decided to represent the views of its residents We do not want and we do not need housing of this scale in felixstowe, trimley or walton. If we are forced to, we don't want it built on arable land, only brown field sites should be considered. Has Walton has been targeted as the line of least resistance. STAG and SaveFelixstoweCountryside do a great job, do we need a 'save walton group?' I say it doesn't matter where you build in the area, it will affect us all.
SCDC Response: 22
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT?
Respondent Name: Mrs Jane Clifford [318] Submission Agent Respondent ID: 318 ID: 318 ID: SUBMISSION I object to Felixstowe being lumped into the larger settlement category when it is already full and overcrowded. I also object to other large towns being left out of the process
SCDC Response: 27
3 BACKGROUND Respondent Name: Mrs Jane Clifford [318] Submission Agent Respondent ID: 318 ID: 318 ID: SUBMISSION
There is no proven local need for housing. We are just bowing down to what is dictated to us.
SCDC Response: 3
2 THE CONSULTATION IN BRIEF
Respondent Name: Mrs Jane Clifford [318] Submission Agent Respondent ID: 318 ID: 318 ID: SUBMISSION I work in IT and this online consultation is stupidly hard to negotiate or to fill in. I have just spent 2 hours of my time just trying to find out how to fill in this application form. Aside from that fact
The overwhelming majority of people I meet think that the housing has already got the go ahead and that there is nothing they can do. I see this as a failure on the part of the council. The residents need to be made more aware of this consultation. No effort has been made to publisize the process
SCDC Response: 1
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mrs Jane Clifford [318] Submission Agent Respondent ID: 318 ID: 318 ID: SUBMISSION Walton had 2 fields left. One just went for development. Just one left! Protect this last valuable asset or build on it?
I don't want to see my town destroyed by becoming large like Ipswich. I wouldn't like to live there. I chose Felixstowe, I like the way it is and I want to protect it.
Some houses for local residents, brown field sites, no problem, spread the rest around the area.
Villages are desperate to build a few houses. 82 schools in Suffolk, more than 1/4 of places unfilled. Few more houses in each village would make the schools, communities viable.
SCDC Response: 4, 22
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES. Respondent Name: Mrs Janet Elliot [379] Submission Agent Respondent ID: 379 ID: 379 ID: SUBMISSION 1)Impact on wildlife The Deben Estuary is a PROTECTED environmental site having SPA, SSI and Ramsar status and is within the Suffolk Coasts and Heaths AONB. Development of 2000+ dwellings on Adastral Park would have an unacceptable and irreversible impact on this protected area. Run-off from roofs, tarmac and concrete will contaminate the water table and thus the streams that are tributaries of the river. Increased visitor numbers will increase wildlife disturbance and damage to this protected habitat. Ramsar status means that local governments are obliged to maintain favourable conservation status, not facilitate its destruction.
2) Lack of Infrastructure The is little or no employment opportunities on the East side of the A12, BT in particular is continuing to shed jobs by the hundred and have no plans to relocate other parts of their business to Adastral Park. Most people who would live in the proposed development will therefore commute to the Ipswich area in addition to travelling to Ipswich for shopping and entertainment.. There is no rail line, Foxall Road is a notoriously congested commuter route into Ipswich- it has one of the worst RTA and fatality records in the County. The junction with Bell Lane has previously been identified as an accident black spot and sign posted as such. The traffic level generated by the proposed increased numbers of resident would add to the existing poor conditions of this narrow and over used road.
3) Visual Impact Adastral Park is in the middle of a rural and agricultural setting and on the edge of an AONB. The few dwellings already in existence are of conventional construction and height. They are barely visible from the A12 and surrounding countryside. The plans for the proposed increase in dwellings includes tower blocks of up to 6 stories high. These would be entirely incongruous in a rural setting. They would be visible for miles in all directions, including the surrounding small villages and would totally dominate the surroundings. They would be the only such buildings on the entire Suffolk stretch of the A12 and would stand out like a sore thumb. There can be no justification for a development of this proportion and height in a countryside setting. This is not the middle of a city.
SCDC Response: 7, 9, 17, 19 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Janice Barter [194] Submission Agent Respondent ID: 194 ID: 194 ID: SUBMISSION This small corner of Suffolk cannot support such a huge development in ANY way. It wiil be detrimental in EVERY way to the quality of life of those who live here. It will create an increase in domestic and service traffic (already at capacity), and pressure on community facilities eg schools/health (already at capacity). It will cause a severe loss of environment eg increase in noise, light, air pollution, and decimation of green- space. The argument to increase numbers bears on a stand-alone community, yet the proposals constantly relate to the use of present falicities for at least the first 5 years.
SCDC Response: 16, 17, 19, 20
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mrs Jennifer Egan [329] Respondent ID: 329 Submission 329 Agent ID: ID: SUBMISSION Most people do not cycle or walk even when the are within one mile of work and will not do so in bad weather. EADT dated 7.11.09 an article reads FEWER BUSES AND THEY WILL COST MORE, services have been cut and fares increased, it is cheaper for a family to use the car. Families deserve a good quality of life and they will not receive it in the high density housing that is being proposed. When will SCDC start listening to their electorate.
SCDC Response: Noted
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY?
Respondent Name: Mrs Jennifer Egan [329] Submission Agent Respondent ID: 329 ID: 329 ID: SUBMISSION This development will not only be too large is size but also in height, 4/5 storey buildings will not blend into the existing environment (Note the dreadful BT building)Martlesham Heath, Martlesham and Waldringfield are examples of what should be built in this area, a village not a Town.
SCDC Response: 16, 18
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mrs Jennifer Egan [329] Submission Agent Respondent ID: 329 ID: 329 ID: SUBMISSION 1000 houses was too many but accepted with resignation because houses have to be built somewhere but 2000/3500 is an insult to everyones intelligence. Nowhere is there mention of a park,open spaces for dog walkers yes but what about the children and swings, football pitches etc. or will there not be any children in this New Town. You need a certain number of pupils to warrant a new school, the local schools are already full, where do the first influx of pupils go.
SCDC Response: 16
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mrs Joyce Johnson [319] Submission Agent Respondent ID: 319 ID: 319 ID: SUBMISSION Object to core strategy classification of Felixstowe as major centre. Object Felixstowe targeted for growth. Only housing for natural local need should be considered.
Object to development on any food producing land. Welcome dispersal but develop brown field sites only. We need to retain and expand, not contract, our capacity to feed ourselves. Fields on the Felixstowe peninsula are now all that are left after decades of development and should be preserved for health and well being of residents and attraction of visitors.
Tourism important.
Air quality already unacceptable.
Spread housing across districts to help smaller communities retain services.
SCDC Response: 4, 22, 23, 27
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: mrs julie goldsmith [208] Submission Agent Respondent ID: 208 ID: 208 ID: SUBMISSION Whilst I do not object to this site as such,the number proposed is simply too great for this area. The proposed development is far too urban for this site and is out of keeping with the surrounding countryside.It will have a huge detrimental effect on the countryside and the surrounding areas.The infrastructure cannot support that number of houses without there being huge changes.The identity of the surrounding villages of Martlesham and Martlesham Heath will be lost within the urban sprawl of the ever expanding area of Ipswich.There is not enough employment opportunities in this area to support this proposal.
SCDC Response: 7, 16, 17, 18, 20
8 YOUR COMMENTS
Respondent Name: Mrs Kate Johns [63] Submission Agent Respondent ID: 63 ID: 63 ID: SUBMISSION Whilst I do not object to 1,000 homes be being on the Adastral Park site, I do object to the increased number and the style of the development. It is all well and good that the Council thinks that this is a good idea but what about the provision of High Schools in an already crowded situation - Faylingale, Kesgrave, Thomas Mills and Northgate are all full and with the new development and education boundry changes in Felixstowe, where are the children from this development (middle class) going to be Educated? Martlesham, Bucklesham, The Heath and Waldringfield are villages, why do we need another town when we have Ipswich (which is poor for facilities), Woodbridge and Aldeburgh?
SCDC Response: 16, 20
2 THE CONSULTATION IN BRIEF
Respondent Name: Mrs Kathrine Cox [123] Submission Agent Respondent ID: 123 ID: 123 ID: SUBMISSION The increased number of houses in Martlesham will place undue strain on the local roads and infrastructure. The jobs in martlesham are limited and with the recession are unlikey to increase at any rate. This will mean greater commuting from Martlesham placing double the number of cars onto the local road including the A12, A12/14 A14 and main kesgrave road which all suffer from congestion already. The proposed road widening at the BT junction is out of keeping in the area and will cause bottle necks elsewhere when traffic returns to single lane.
SCDC Response: 7, 13, 19, 20
IPSWICH POLICY AREA
Respondent Name: Mrs Kathrine Cox [123] Submission Agent Respondent ID: 123 ID: 123 ID: SUBMISSION This si a stand alone community but here you say it will be intergrated with local community. Cant be both! Creating retail and leisure will not provide jobs for 2000 or more people.
SCDC Response: 16
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Kathrine Cox [123] Submission Agent Respondent ID: 123 ID: 123 ID: SUBMISSION What "evidence" the benefits outweigh the disbenefits? The new community can not be "stand alon" and "linked" to local community. d alone or it isn't. The development will moinimise effect neighbouring countryside- what about Martleshams countryside which will be lost- quality of life in Martlesham seems to be irrelevant to these plans. After mineral extraction is the land to be returned to countrysidee? hence this argument is irrelevant. Landscaping can not hide high rise buildings or noise, pollution and light pollution. Double number of houses+ double traffic- Not a limited impact. Increased deveolper contribution from BT who have a vested interest in increasing housenumbers
SCDC Response: 15, 17, 18, 19
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mrs Kathrine Cox [123] Submission Agent Respondent ID: 123 ID: 123 ID: SUBMISSION Felixstowe is not the only area to be affected by reduced jobs and although it relies heavily on the port for jobs this could also be true of Martlesham which relies heavily on BT for employment.There are few jobs available within Martlesham so would not support a large number of new people. These residents will need to work outside Martlesham hence increasing traffic on all local roads. The obvious direction for these new cars to take are onto the A12,A12/14 into Ipswich and the same issues with the A14 will applly as with building in felixstowe
SCDC Response: 7, 19, 24, 26
HOUSING DISTRIBUTION FELIXSTOWE/WALTON AND TRIMLEY VILLAGES
Respondent Name: Mrs Kathrine Cox [123] Submission Agent Respondent ID: 123 ID: 123 ID: SUBMISSION it would appear that the "impact of one or two large developments on any single community or the road network" is a reason to not place a large development in felixstowe, but the same concerns have not been considered as a reason for not putting the large development in Martlesham where the same road and single community issues exsist. Felixstowe has the preferred option of smaller, dispersed sites as this puts less pressure on infrastructure than deveolping 1 site. how does this relate to Martlesham 1 large development where the infrastrure will impact heavily on the local community
SCDC Response: 15
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY?
Respondent Name: Mrs Kathrine Cox [123] Submission Agent Respondent ID: 123 ID: 123 ID: SUBMISSION It would appear that Martlesham is considered an urban area as the impact on local community and wildlife appears to have been ignored.
SCDC Response: 17, 18
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mrs Kathrine Cox [123] Submission Agent Respondent ID: 123 ID: 123 ID: SUBMISSION Increasing road size in martlesham will have detrimental effect on the wildlife,countryside and change the area from countrry to urban. Large scale new housing in Martlesham does not reflect the current community or respect the character of the area.There are a number of SSi's locally that could be effected by the increased population size
SCDC Response: 17, 18
3 BACKGROUND
Respondent Name: Mrs Kathrine Cox [123] Submission Agent Respondent ID: 123 ID: 123 ID: SUBMISSION You mention that you have taken into account the infrastructure being able to cope with propoed development. However the current infrastructure in Martlesham is not sufficient to supply an extra 2000 homes. The schools are already full, the roads congestedm the health services over subscribed. This will necessitate building new infrastructure using up even more green land within the Martlesham area so increasing the urbanisation of the area and changing it character
SCDC Response: 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Kay Stephens [525] Submission Agent Respondent ID: 525 ID: 525 ID: SUBMISSION To whom it may concern,
I am emailing to register my objection to the Adastral Park development plans. I am objecting for the following reasons: a) I do not believe Ipswich and the local area can support such an expanding population in terms of employment (especially given the size of the recently built Grange Farm) - I also understand that there is already new property in the area that cannot be filled b) I do not support the use of 'green land' for large new housing developments - I am horrified at the speed with which we are chewing up our countryside c) I anticipate huge congestion difficulties - particularly via the Orwell Bridge, and via the other roads accessing Ipswich town centre d) I feel the design and size of the plans are not in keeping with the nature of the area - a place of small village communities surrounded by peaceful countryside.
I hope these views and those of neighbours will help to inform planning decisions for this area.
SCDC Response: 12, 15, 16, 17, 18, 19
THE OVERALL STRATEGY
Respondent Name: Mrs L Crisp [85] Submission Agent Respondent ID: 85 ID: 85 ID: Mike Bowen SUBMISSION We have no comments to make on the changes to the strategic locations for housing development. Nevertheless, I should like to draw your attention once again to the comments that were made previously in relation to the Core Strategy which can be found in my letter of the 12 February 2009 and in the accompanying Comment Forms.
SCDC Response: 1 Noted
HOUSING DISTRIBUTION EAST OF IPSWICH Mrs Louise Lennard (Louise Respondent Name: Lennard) [350] Submission Agent Respondent ID: 350 ID: 350 ID: SUBMISSION 5.17 - The BIGGEST impact problem is on the local road network serving the Area east of A12/A14. Upgrading essential.
SCDC Response: 19, 20
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES. Mrs Louise Lennard (Louise Respondent Name: Lennard) [350] Submission Agent Respondent ID: 350 ID: 350 ID: SUBMISSION
5.10 - Excellent aspirations IF adhered to.
SCDC Response: Noted
2 THE CONSULTATION IN BRIEF Mrs Louise Lennard (Louise Respondent Name: Lennard) [350] Submission Agent Respondent ID: 350 ID: 350 ID: SUBMISSION 2.06 - Object to concentration of one large community East of A12 at Martlesham. Road network already inadequate; encroach on countryside around Waldringfield; access to A14 congested; threat to Deben Estuary SPA; lack of infrastructure - yet to be built. Suggest - Better placed within the Ipswich Policy Area extending Grange Farm to Foxhall Road - North to Martlesham Heath using rest of derelict airodrome and providing extended facilities and widening existing roads into town.
SCDC Response: 4, 15, 16, 17, 19, 20
2 THE CONSULTATION IN BRIEF Mrs Louise Lennard (Louise Respondent Name: Lennard) [350] Submission Agent Respondent ID: 350 ID: 350 ID: SUBMISSION 2.05 - Infill rather than linear along A14 at Felixstowe. 'Modest' development of market towns/larger villages. Brownfield sites within the above.
SCDC Response: Noted
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009 Mrs Louise Lennard (Louise Respondent Name: Lennard) [350] Submission Agent Respondent ID: 350 ID: 350 ID: SUBMISSION SP26 - Woodbridge 'gateway' to the AONB. Factors that indicate wear and tear at present: 9 - Air quality due to extra traffic. 10 - River pollution and litter. 13 - Fly tipping 14 - Dead lock at peak times at traffic lights. 16 - Run-off from more hard standing = flooding. Essential that Woodbridge's character as a small market town is NOT jeopardised.
SCDC Response: 4, 16, 19 Noted
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009 Mrs Louise Lennard (Louise Respondent Name: Lennard) [350] Submission Agent Respondent ID: 350 ID: 350 ID: SUBMISSION SP20 - Area east of Ipswich - development and extensive population growth threat to Deben SPA especially Waldringfield and Felixstowe Ferry/Bawdsey Quay and Ramsholt. Increased visitor numbers 2009.
SCDC Response: 17
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009 Mrs Louise Lennard (Louise Respondent Name: Lennard) [350] Submission Agent Respondent ID: 350 ID: 350 ID: SUBMISSION 4.13.2 - Policy DC22 Airfields Private Planes using farm air-strips and Bentwaters. Regret DELETED as noisy activity throughout summer of 2009 especially weekends.
SCDC Response: Noted
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009 Mrs Louise Lennard (Louise Respondent Name: Lennard) [350] Submission Agent Respondent ID: 350 ID: 350 ID: SUBMISSION 2.1.2 - ALL affected by increase in visitors - Sandlings, SPA, Deben SPA, Deben Estuary (Ramsar Site), Alde & Ore (Shingle Street) and numerious SSSI's etc Open Public Access to Coast etc
SCDC Response: 17
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009 Mrs Louise Lennard (Louise Respondent Name: Lennard) [350] Submission Agent Respondent ID: 350 ID: 350 ID: SUBMISSION 7.2.12 - Should be a priority for SCDC to implement as soon as possible as it is already causing SEVERE PROBLEMS across the neighbouring AONB for the reason stated in 6.4.2 - easy reach of large numbers from within and outside the area. It's a good day out from Ipswich and further afield - well over the 8km trip - more like a 20km radius to say nothing of the sharp increase in B & Bs, holiday lets, camper vans, chalets - all to increase long stays.
SCDC Response: 9
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009 Mrs Louise Lennard (Louise Respondent Name: Lennard) [350] Submission Agent Respondent ID: 350 ID: 350 ID: SUBMISSION 5.4 - Total lack of up-to-date statistics makes this document invalid. The assumption that a huge 'new town' at Martlesham would have no impact on the Deben and its hinterland is LAUGHABLE! 2004 figures much increased.
SCDC Response: 9
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs M Atkins [463] Submission Agent Respondent ID: 463 ID: 463 ID: SUBMISSION I object to the proposal to build 2000 houses in the Adastral Park area of Martlesham. It is adjacent to an AONB site & would utterly destroy the beauty & tranquillity of this very special area on the banks of the river Deben.
SCDC Response: 16, 17
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mrs M Hall [451] Submission Agent Respondent ID: 451 ID: 451 ID: SUBMISSION We are in the process of buying a house at tree Tops. I feel the land is totally unsuitable for so much building. It is a green field site. Not a brown site.
SCDC Response: 22
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mrs Mary Farrow [151] Submission Agent Respondent ID: 151 ID: 151 ID: SUBMISSION Re: Consultation on the Updated Preferred Option 7/09 Housing Distribution Summary
1. East Anglia was known as the breadbasket of the country. We cannot afford to build on grade 1 and 2 farmland as the country's population rapidly increases.
2. If building goes ahead at Area 451g, how will the proposed new residents and businesses access the A14 without a flyover at the Dock Spur roundabout? Many of the people living in Felixstowe already work outside the area and many of the people that work in Felixstowe live outside the area.
3. More houses and businesses mean more vehicles and the proposed link between Walton High Street and Candlet Road to access the A14 will only make current hold-ups on Candlet Road worse.
4. I am concerned that if building goes ahead on Area 451g, access may be considered via Gulpher Road and Treetops. The Gulpher Road junction with Walton High Street is very narrow and virtually blind as cars and vans often park on High Street footpaths on both sides of the junction. Illegally parked vehicles just inside Gulpher Road can also make turning into the road positively dangerous.
5. Through traffic would make Treetops more dangerous especially at the current top end where there are two sharp bends within a few yards of one another. It would also be more dangerous for children, dog walkers and others using the popular amenity strip opposite the houses.
SCDC Response: 22, 26
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mrs Mary Shipman [78] Submission Agent Respondent ID: 78 ID: 78 ID: SUBMISSION Updated preferred Option 07/09 - Consultation
Further to our comments earlier this year on Site Specific Allocation for Friston, we write to comment further on the current proposals for housing distribution. A completed comment form is attached, together with our previous letter of 9 February 2009.
Step 1 - Settlement Hierarchy
We support the change for Friston from 'Local Service Centre' to 'Other Village'. This more accurately reflects the services, amenities, transport links and employment opportunities available in the village, as set out to you in our previous letter. We also concur with the proposal that no allocation of new homes will be made in settlements listed as 'Other Villages' and that development will be restricted to conversions, agricultural workers' homes or the occasional house for a local need.
Step 2 - Strategies and policies - Towns & Local Service Centres
We note that the needs of Sizewell may influence the strategy for development at Leiston and Saxmundham and also that there are some proposals for development in Knodishall as a local service centre. We note under your paragraph 5.10 that road, rail and other public transport networks should be capable of accommodating the traffic and journey requirements that new housing inevitably brings with it. Leiston has a poor transport network with no passenger rail link, the nearest station being at Saxmundham. There is no major road connecting the town with the A12 and Leiston relies on the B119 as a link to Saxmundham, the B1069, and the B1122 to Aldeburgh. Knodishall has even poorer transport links with several routes into the village on unclassified single-track roads. The siting of any development in Leiston and Knodishall should be very carefully considered with regard to the increase in traffic on these routes.
In conclusion we consider that the proposed change of designation for Friston is well justified, however further thought needs to be given to development at Leiston and Knodishall with regards to their transport links.
SCDC Response: 27 Noted
KEY SERVICE CENTRES
Respondent Name: Mrs Mary Wright [82] Submission Agent Respondent ID: 82 ID: 82 ID: SUBMISSION At Leiston Library I saw all the documents relating to the Updated Preferred Option. I found them difficult to understand with percentage figures etc but fortunately your Frequently Asked Questions sheet was more helpful with the attached sheets, especially 1 and 2. From these I see that Friston has a minus against it so presumably this means you have deleted the land in Church Road, Friston origininally in the proposals. That at least is something. It appears there is no change so far as Knodishall is concerned. This is a pity as some of the sites in the Judith Avenue/Fitches Lane areas were to say the least tight and would involve yet more traffic in an area that can become very congested. Knodishall is under a 'Key Service Centre' and yes it does have a pub (though this is up for sale), a burgeoning primary school and three good meeting places. The public transport consists of buses which ply between Aldeburgh & Beccles and in order to go to Ipswich you need to get a bus to Leiston or Saxmundhan and go on from there and hope the times jive! Yes, there is a shop but it can hardly be said to be thriving since the post office was compulsorily closed down nearly two years ago. This letter is because I did not feel it appropriate to fill in any of your forms for the way I wished to comment.
SCDC Response: Sites comments noted
IPSWICH POLICY AREA
Respondent Name: Mrs Meg Walker [414] Submission Agent Respondent ID: 414 ID: 414 ID: SUBMISSION I am writing to say how disturbed I am by the planned new developement at Adastral Park. The plan for such an enormous developement is unneccesary in such a quiet rural setting. The site is bordered on the east side by a dead end ...The River Deben which means all the traffic will be heading one way on to an already at peak times busy A12. I cannot believe that we need all this extra housing as there are lots of properties in Ipswich that are being mothballed! The Adastral Park site is simply not suitable for this level of housing.All the surrounding villages will be completely swamped by this developement.
SCDC Response: 16, 17, 18, 19
8 YOUR COMMENTS
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION How can SCDC justify supporting integrated development for Felixstowe and the Trimleys but not for elsewhere? If the effects of the recession on the Port means a reduction in housing numbers for Felixstowe, then the same should hold true at Adastral Park. SCDC emphasises the reasons which back up its main policy of pushing through this massive development and is paying lip-service to any potential problems.
SCDC Response: 15
IPSWICH POLICY AREA
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION The A12 and A14 are already very busy - any accidents on these roads can quickly lead to long delays and traffic gridlock. Adding 3,000+ more cars from a new development is only going to add significantly to the traffic congestion, not to mention the noise and environmental pollution. How will having traffic lights at the major roundabouts aid the traffic flow? After all, the traffic lights were removed from one of the roundabouts in Grange Farm to help the traffic along the main Kesgrave road.
SCDC Response: 19
IPSWICH POLICY AREA
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION Given the current economic situation, there must be concerns as to whether the appropriate infrastructure would be put in place whatever the council say.
SCDC Response: 20
IPSWICH POLICY AREA Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION Is this an opportunity for a stand-alone community or is this a development which must be integrated with the rest of the Martlesham area? SCDC would appear to be confused as to what they want. I feel SCDC are just trying to find reasons to justify giving BT planning permission. It solves problems for both of them - the sale of the land would make BT a LOT OF MONEY while SCDC would have half the number of houses they need to produce.
SCDC Response: 16, 18
IPSWICH POLICY AREA
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION A planning inspector turned down the application for 150 log cabins opposite the BT site. So how can SCDC justify recommending 2,000+ homes to be built on the Adastral Park site?
SCDC Response: 16
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION What is proposed is a stand alone community with a population the size of Leiston and larger than Saxmundham. Why is the A12 not considered a natural barrier to development? Keep the area to the east as countryside and villages, thereby also protecting the Deben Estuary with all its important wildlife.
SCDC Response: 16, 17
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION In these documents SCDC have yet to impress with how they plan to mitigate the definite (not potential) impact of such a development. I fail to see how a lot of planting and open areas for dog walkers would lessen the impact on the Deben Estuary.
SCDC Response: 9, 17
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION The original planning consent for the quarry was for the land to be returned to green fields - not a large scale housing development.
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION People are not going to want to remain within a new development to go on walks - whether they have a dog or not. They will want to explore the local countryside and probably go to the nearby river. The fact that Waldringfield now has no public car park will not deter them. People will want to use the countryside around them - not stay cooped up in their houses.
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION Although some people do use Woodbridge for shopping, many use the existing supermarket at Martlesham Heath. This is already extremely busy at certain times of the day and at weekends. Trying to use it at Christmas is a nightmare. It is unrealistic to have 2,000+ extra homes at Adastral Park with all the associated cars trying to park and then use the store.
SCDC Response: 19
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION It would appear that this consultation is because BT put in a planning application for 2,000 houses whereas SCDC originally were only looking to build 1,050 houses on this Adastral Park site. It seems that SCDC are trying to push through this enlarged development because it helps solve their problem of finding enough land for developing the number of houses allocated to the area. Any difficult areas, such as the Deben estuary being of national and international importance, they mention in passing but do not appear to be listening to Natural England's warnings about the possible "particularly negative effects".
SCDC Response: 9, 17
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY?
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION "To provide a high quality, sustainable living environment for all residents, new or existing" Life for the existing residents would no longer be high quality. eg. Martlesham Heath residents would have higher noise levels from the A12.
SCDC Response: Noted
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY?
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION "Limiting any adverse impact of new development on existing communities, countryside and wildlife" The development proposed at Adastral Park would have an enormous impact on Martlesham Heath and all surrounding villages. So much of the local countryside would be lost and of course the wildlife would be affected. The Council are proposing a development with a population the size of Leiston - not insignificant.
SCDC Response: 17, 18
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION "That housing and jobs should be provided in tandem" Given that BT have been in the news regularly for cutting thousands of jobs, there is no evidence that there will be the employment opportunities at Adastral Park or locally for the above.
SCDC Response: 7
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION "Protection should be given to wildlife and to the landscape, particularly those areas that are designated as being of national and international importance" The Deben Estuary is such an area of importance, yet the Council seems to have disregarded the devastating effect such a large development could have. I don't think people realise the true extent of what is being proposed.
SCDC Response: 9, 17
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION One policy objective is "To conserve and where appropriate enhance areas of historical and archaeological importance". The land next to Adastral Park contains a number of archaeological features so how are they going to conserve them?
SCDC Response: 20 Safeguarding sites of historical and archaeological importance will be addressed in the Area Action plan for Martlesham.
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION "Increased development, concrete and roads will exacerbate runoff and may increase risk of flooding" Something else to look forward to?
SCDC Response: Noted
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION
As the "Land abutting Adastral Park is Greenfield", it should remain so.
SCDC Response: 15
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION "Development likely to increase traffic considerably as this is already a heavily congested area however policy encourages use of public transport, foot and cycle provision and upgrades." New development residents may walk/cycle to the primary school, but when doing a supermarket shop, going into town, going to work etc the vast majority will use their car - not use public transport, walk or cycle.
SCDC Response: 19
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION "6.2.37 ... The car park at the Deben Estuary at Waldringfield is privately operated for users of the pub and sailing club, and is not available as a starting point for estuary-side walks." People still park in the car parks at Waldringfield whether they use the pub or not, whether they are sailing club members or not. They use the privately-owned jetty to launch boats. They park on the narrow side roads and use the footpaths to get to the river. The lack of a public car park does not stop them. Waldringfield cannot cope with increased visitors from massive development at Adastral Park.
SCDC Response: 9
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION "6.2.34 It therefore cannot be ascertained that an allocation of 2000 new dwellings at Martlesham willhave no adverse affect upon the integrity of Deben Estuary SPA near Martlesham, given the current level of detail available within the Core Strategy and Development Management Policies." Given that the Deben Estuary is a national and international area of importance, SCDC should be trying to preserve it for future generations - not destroy it.
SCDC Response: 9
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION Please could SCDC take heed. "6.2.32 ...The master-planning of new housing may also include a desire for new footpath links to the estuary. It is therefore possible that visitor recreation activity would substantially increase on the foreshore of Deben Estuary SPA, bringing in high levels of disturbance to what is currently little disturbed and a 'refuge' area for SPA qualifying birds."
SCDC Response: 9
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION Again are SCDC taking heed? "6.2.31 An allocation of 2000 houses at Martlesham could potentially cause problems to the Deben Estuary, from increased visitor use causing significant disturbance to SPA birds; trampling of water-edge habitat in Martlesham Creek containing a rare snail might also occur."
SCDC Response: 9
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Mrs Nickie Wellingham [235] Submission Agent Respondent ID: 235 ID: 235 ID: SUBMISSION Are Suffolk Coastal taking heed? "6.2.22 It is considered that the impact of the increased visitors due to the combination of the Ipswich Borough and Suffolk Coastal District Core Strategy and Development Management Policies will have a significant extra impact... The increase in visitors from Ipswich, predicted at 0.8% compared to 1.68% from Suffolk Coastal, is not insignificant... It is consequently not possible to ascertain that there will be no adverse effect upon the integrity of the Deben Estuary SPA."
SCDC Response: 9
IPSWICH POLICY AREA
Respondent Name: Mrs P Goldfinger [452] Submission Agent Respondent ID: 452 ID: 452 ID: SUBMISSION I continue to be concerned about major increases in car pollution, light pollution along the road to Woodbridge and beyond. Traffic has been increasing constantly since we came here 14 years ago and there is no doubt there will be major hold ups aswell and traffic lights are not helpful. We live in a beautiful area and are fortunate to do so but it will go if Adastral park is built on. Urbanisation will increase an the rural area will decline and these changes will open the door to further buildings or holiday chalets/houses. I am also not clear where the new secondary school will be built.
I would also put in a plea for some more innovative decent design and architecture of the buildings such as Peter B Architects have done at the Circle Anglia Housing Gp or John Lyall of the Thill (docks) at Ipswich. Good design is the key to environmental sustainability.
SCDC Response: 16, 18, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Pam Crawley [533] Submission Agent Respondent ID: 533 ID: 533 ID: SUBMISSION Summary I object strongly to a poorly conceived Core Strategy, doubling the number merely doubles the problems. It is inconsistent between areas, based on faulty appraisal conducted with erroneous, inadequate information. Underlying objectives are not met, development principles violated. The option selection methodology is not objective. Transport and infrastructure studies highlight serious issues which have been ignored. The impact on the AONB and Waldringfield is severe, guidelines on greenfield building and affordable housing are ignored. Infrastracture cannot be pre- provided, especially waste water and health. Prospects for employment growth at the site are limited and highly uncertain resulting in further traffic. The underlying objectives are NOT met by this option Limiting any adverse impact of new development on existing communities, countryside and wildlife * The impact on wildlife sites is seriously adverse * Mitigation proposals are wholly inadequate Strategies are different and inconsistent * dispersed strategy of "organic and evolutionary growth for Felixstowe & Trimley * concentrating housing at major centres - East of the A12 is NOT a major centre. To make best use of known "brownfield" development opportunities * BUT East of the A12 is Greenfield * So use non IPA brown field instead * There is, however, no justification for not using the brown field land OUTSIDE the IPA. A high quality, sustainable living environment for all residents Development principles have been violated. New housing should not be provided in isolation * Prospects for employment growth are highly uncertain. * SCDC claim houses will be built near employment BUT they will not only 3% of the people working at Adastral Park live within 1 mile the vast majority of residents of the new town will work elsewhere but should be built where facilities already exist or could be upgraded or provided ; * There are major difficulties in providing infrastructure. * East Anglia is one of the driest regions and least able to cope with increased demands for water. * The local electricity network has no capacity for any significant development * No case can been made for building a third secondary school * No consultation has taken place with either Kesgrave or Farlingaye high schools about the need for a third school Any new or improved infrastructure should be provided in advance of or in parallel with new development; * Waste water treatment may not be resolved until 2019 * Doubt regarding S106 funding after 2015 * Acknowledgement of a 'lag time' between recognition of health service need and the funding * Education We should look first to re-developing old "brownfield" sites * Preference for Greenfield land not in line with government guidelines The road, rail and other public transport networks should be capable of accommodating * Residents will not work locally * Transport Study - Delivery Of A Sustainable Transport Solution depends on improbable assumptions. * Transport Study - Omission Of Cross References To Adjacent LDFs * Transport Study -Site 4 Poor road access, furthest from employment. * Transport Study - 1.3 No new surey, no modelling, no specific consultation. * Transport Study - The Orwell Crossing is not discussed or considered. * Overall Growth Arising From Doubling The Housing Allocation is not assessed. New housing should allow integration with existing communities * Affordable Housing is ignored * Uneven distribution of Affordable Housing * allocation falls far short of meeting the need for affordable housing in rural areas * It is not possible to integrate 2000 houses with Waldringfield without destroying it. New housing should respect and maintain the character of individual settlements and communities * East of the A12 is a rural not urban environment. In deciding where new development should go, it should respect the quality of the local environment; * levels of growth proposed for the area would typically give rise to an increased incidence of crime * Deficiency in accessible natural green space in the study area Protection should be given to wildlife and to the landscape, particularly those areas that are designated as being of national and international importance * Unacceptable impact on the neighbouring wildlife and countryside * Adverse impact on the landscape and loss of biodiversity." * An increase in the number of visitors to the Deben Estuary is inevitable * Disturbance from additional visitors will accelerate decline * 'Mitigation' will not prevent damage * Mitigation funding is difficult and uncertain Building on high quality agricultural land should be avoided as far as possible. * This is agricultural land * The quarry should be returned to agricultural land (agreement exists). Doubling the allocation makes all of the above twice as bad.
SCDC Response: 4, 7, 10, 15, 16, 17, 19, 20 See affordable housing policies DM1 and DM2
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Mrs Pam Stone [243] Submission Agent Respondent ID: 243 ID: 243 ID: SUBMISSION We are totally against the Local Development Framework and it's implications on the surrounding area. I cannot think of any justifiable reasons to put this into action. There is absolutely no benefit to the community in this area and would totally destroy Waldringfield and the surrounding communities.
SCDC Response: 16, 18
THE OVERALL STRATEGY
Respondent Name: Mrs Patricia Thompson [500] Submission Agent Respondent ID: 500 ID: 500 ID: SUBMISSION i write to rpotest about your proposed amendment to the LDF, thus enabling you to grant BT permission to go ahead with their plans for Adastral park.
Martlesham Heath is an attractive, low level development, not visibile from the A12.
The effect of a 'new town' being developed accross the road from it with some premises being 6 storeys high, very visible, plus the need for sewage works and electricity sub stations etc etc. 'In-filling' and small developments would surely be more attractive and new families possibly able to have normal amenities, such as gardens, for children to play in and room sizes bigger than boxes.
The effect of a 'new town' development on other villages such as Kesgrave, which has already been developed and in particular Waldringfield, a very attractive village with narrow roads and lanes, the usual village hall and riverside attraction. Any large scale development would seriously affect this pretty village which is also a tourist attraction along with Woodbridge. Coach firms all over the country bring trippers to Woodbridge, for the attractive riverside town it still is, with its pubs, restaurants, coffee houses, private shops and its history.
How much Council attention has been paid to the chaos at the Gloster Road/A12 junction and the Gloster Road/Anson Road/Felixstowe Road junction during the rush hour?
Is the Council intending to buy up land along the A12 in order to create more lanes and multi land chaos at roundabouts, reminiscent of those approaching some of the countrys motorways, resulting in chaos and accidents.
I wonder when authorities will wake up to the fact that 'BIG' is not beautiful - look at our schools, prisons, hospitals - all too large and problematic.
SCDC Response: 13, 15, 16, 18, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: mrs penelope smail [150] Submission Agent Respondent ID: 150 ID: 150 ID: SUBMISSION I wish to object to the above proposals very strongly indeed. First, I have tried to object using your online consultation procedure which I have found impossible to use. It does not make the consultation process easily available to the ordinary resident and I can't help feeling that it may have been designed specifically for this purpose. I have therefore had to resort to writing. Then I object to the proposals because of the negative environmental impact they will have on the surrounding villages, particularly Waldringfield and Martlesham Heath. The air pollution, light pollution and traffic they will create will have disastrous consequences for local residents and foe wildlife. There will be huge pressure on local services. An area of Outstanding Natural Beauty, the Deben and it coastline, will suffer greatly and the peace of the area will be personally lost. I believe the new proposals will open the way for the expansion of Ipswich until the whole are will be swallowed up in one large new town. Why is greenfield land being used for housing development when plenty of brownfield sites are available in Ipswich? Finally, you state the previous consultation (to which I responded) produced broad agreement. I only know that there were many objections. Can you please make the previous figures public?
SCDC Response: 1, 15, 16, 17, 18, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Rachel Mitchell [335] Submission Agent Respondent ID: 335 ID: 335 ID: SUBMISSION I strongly object to the proposal of a substantial increase in the amount of new housing east of the A12 at Martlesham. A development of the proposed size would adversely affect existing communities, particularly Martlesham Heath, Martlesham and Waldringfield which at present have their own individual identities. It would join these villages in to one large urban area destroying countryside and wildlife as well as causing unacceptable disturbance to residents of the area in terms of increased traffic, noise and pollution. The housing need should be dispersed around the district rather than creating another Ravenswood style development.
SCDC Response: 16, 17, 18
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Mrs Rachel Travers [310] Submission Agent Respondent ID: 310 ID: 310 ID: SUBMISSION Felixstowe Infrastructure Study: Of the 15 aspects examined, 10 are assessed as needing 'developer contributions'. Experience suggests such contributions rarely fully materialise, so developments risk being underprovided. New homes are unlikely to be built at average of 80 a year but will be completed in groups, putting unpredictable strain on services such as nurseries/schools. The identified 'deficiency in natural green spaces' will be worsened by further loss of allotments, stables and countryside already used as a sports and leisure amenity. 'Various projects' will not address this shortfall: major reduction in housing allocation can at least prevent it becoming worse.
SCDC Response: 25
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mrs Rachel Travers [310] Submission Agent Respondent ID: 310 ID: 310 ID: SUBMISSION Strategy of more dispersed, evolutionary growth is welcome, as is emphasis on brownfield land. 'Modest greenfield allocation' is an unquantifiable term and in Phase 3 it seems to cover possibility of unlimited increase in scale of development. Almost all use of greenfield sites here entails loss of good agricultural land and negative impact on environment. Land north of A14 and north of Felixstowe should not be developed, thus safeguarding remaining wildlife habitats, natural setting valued by tourists and countryside used by residents as leisure amenity. This is consistent with reducing housing allocation to this increasingly congested peninsula.
SCDC Response: 22, 23 Noted
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Mrs Rachel Travers [310] Submission Agent Respondent ID: 310 ID: 310 ID: SUBMISSION Point 3: The traffic studies mentioned do not correspond with local experience and appear flawed. The A14 at exit to Felixstowe and at intersections up to and including Orwell Bridge - which is almost at capacity according to other studies - is unlikely to cope despite planned improvements. It will be dangerously congested for HGVs, residents' cars, buses and emergency vehicles. The concept of major population growth at the end of a peninsula with one exit route cannot be justified.
SCDC Response: 12, 26
THE OVERALL STRATEGY
Respondent Name: Mrs Rachel Travers [310] Submission Agent Respondent ID: 310 ID: 310 ID: SUBMISSION Revised housing distribution is step in right direction but percentage of allocation to Felixstowe+W+T still too high. Clear need for housing in Felixstowe but proposed number well above local requirements - this cannot be justified on small peninsula with one busy access road and limited green hinterland. Serious congestion and impaired quality of life would ensue. Developments at Market Towns should be less restricted - they are subject to similar 'negative aspects' as Felixstowe and some have better access. Allocations - particularly of affordable housing - to Key and Local Service Centres should be increased to ensure local services thrive.
SCDC Response: 22, 26
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Rita Starling [162] Submission Agent Respondent ID: 162 ID: 162 ID: SUBMISSION We wish to record our objections to the new Local Development Framework, the reasons for which are as follows:
2,500 homes is too many; many unsold new homes exist in Ipswich, and this illconceived proposal gives no thought to the surrounding countryside.
Disregard for the detrimental effect on villages, Kesgrave, Martlesham, Martlesham Heath, Waldringfield, Newbourne, Hemley, and Woodbridge.
Insufficient work in the area to support increased population: inadequate road system and schools.
Public services, i.e. sewage system, hospitals, are already overstretched.
Wanton destruction would be caused to farmland and natural habitat.
BT's overriding short term interest is raising money to improve its balance sheet which must not take precedence over the local community.
SCDC Response: 16, 17, 18, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Mrs Rosalind Mary Bennett Respondent Name: [200] Submission Agent Respondent ID: 200 ID: 200 ID: SUBMISSION Dear Sirs
I am strongly opposed to the development of Adastral Park as it will create much more traffic and congestion.
In particular, I object to the bridge across the A12 which will end up at the bottom of my garden and introduce more cyclists along these paths and through the woods where many accidents have happened in the past.
I realise cyclists should not ride along these footpaths, but they do - and at high speed - often round completely blind corners!
Apart from this, we have a nice village-style life on Martlesham Heath and I do not want that to change.
Please leave us alone.
SCDC Response: 18, 19, 20
IPSWICH POLICY AREA
Respondent Name: Mrs S Ford [538] Submission Agent Respondent ID: 538 ID: 538 ID: SUBMISSION I object strongly to the proposal to develop 2000 dwellings south and east of Adastral Park for the following reasons:-
The Core Strategy does not take account of the Ipswich LDF Proposed Submission Core Strategy of September 2009. Specifically there is no mention of the possible northern by-pass or possible development of 1000 dwellings on the Ipswich Northern Fringe (adjacent to Blob 1 of SCDC's earlier consultation).
A better strategy would be to devote some or most of the dwellings to the many villages or small towns in small numbers where homes are needed for local families in such a way that the major impacts would be avoided and with the positive benefits of increased support for local facilities currently under threat such as shops, pubs and schools.
Damage to the Deben Estuary, an internationally protected site within an AONB, with inevitable intrusion by more visitors, and by the impact of possibly contaminated surface water emerging into the streams leading to the river and by increased flows from the sewage works outfall at Martlesham Creek with consequent hazard to wildlife, flora and fauna.
BT's presence has diminished in recent times and with this trend the hoped for employment at Adastral Park may not materialise. Should this happen, more journeys to work would be made out of the development than predicted.
The transport Appraisal is based on old data and approximate methods (this is acknowledged in the Appraisal) and there is a risk that the traffic predictions may not be accurate enough to ensure that the junction "mitigation measures" will work in practice.
The development will give rise to increased congestion on the A14, including the already near capacity Orwell bridge.
The traffic signal "mitigation measures" proposed in the Transport Appraisal for the A12 between A1214 and A14 do not mention the probably increase in severity of road traffic accidents at signals compared with roundabouts, even with graduated speed limits.
The loss of amenity and the effect on the health of residents living adjacent to the A12 as a result of increased traffic noise and air pollution, thus lowering the quality of life for those residents.
The proposed footbridge south of Barrack Square would result in the loss of woodland which at present provides a screen between the properties and the A12 and the BT buildings beyond. The footbridge would form a significant visual intrusion when viewed from the adjacent properties. It would also lead to intrusion by non resident walkers and cyclists into the larger woodland owned on behalf of the residents by MHHLtd and maintained at the expense of the residents of Martlesham heath. The woodland wildlife, flora and fauna would be threatened in that case.
SCDC Response: 4, 7, 10, 12, 13, 16, 17
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs S Hancock [397] Submission Agent Respondent ID: 397 ID: 397 ID: SUBMISSION Dear Sir/Madam, As a worried resident of Martlesham Heath I strongly object to the proposals for a New Town (2,500 houses +) for the following reasons:- Not enough research into the proposed infrastructure & realistic solutions. Existing roads are saturated with traffic already, especially at peak times. My own experience is one of increased traffic noise especially over the last 5 years. No examination of nearby rail link. Insufficient analysis of the environmental impact on Martlesham Heath AND nearby settlements such as Waldringfield, Newbourne etc
SCDC Response: 17, 19, 20
IPSWICH POLICY AREA
Respondent Name: Mrs Sally Musson [534] Submission Agent Respondent ID: 534 ID: 534 ID: SUBMISSION My daughter Elizabeth Musson, Northcliff Road, Waldringfield and myself of the above address strongly object to the building of 2000 homes etc on land between BT and Waldringfield for the following reasons:
1. Increased light and noise pollution 2. Insufficient road structure 3. Pressure on local schools 4. Affect visual local beauty of Deben area. 5. Toxic dust from bull dozers on Quarry area
SCDC Response: 9, 18, 19, 20
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Mrs Sandra Jackson [73] Submission Agent Respondent ID: 73 ID: 73 ID: SUBMISSION I object to the Core Strategy in its entirety as it affects Felixstowe, Walton and the Trimleys. I would consider a better option is to build a small number of affordable homes to meet the needs of local residents with the remaining homes being built across the district to minimise infrastructure costs and maximise sustainability of smaller communities.
SCDC Response: 4, 22
KEY SERVICE CENTRES
Respondent Name: Mrs Sandra Spirling [111] Submission Agent Respondent ID: 111 ID: 111 ID: SUBMISSION Sir
We do not feel that Peasenhall meets the requirements of a Key Service area. It does not have a proper bus service and if it did then the post office would almost certainly close. It does not have a pub and there are no employment opportunities. It is more suited to being a Local Service Area and the feeling at the public meeting held last year supported this.
SCDC Response: Noted
8 YOUR COMMENTS
Respondent Name: mrs serena gold [260] Submission Agent Respondent ID: 260 ID: 260 ID: SUBMISSION On what does SCC base their statement of a 'large measure of agreement'. There has been almost unanimous oppostion from local residents in the IPA (and Felixstowe) to the broad strategy originally commented on - for 1050 houses (ignored?). 2000 houses would have a huge impact on the local and wider area. They argue for integration, and counter argue that such a large development would be self-contained. How could that number of people not impact on the neighbouring ANOBs and SSIs less than a mile away? It will forever spoil a unique and cherished corner of Suffolk.
SCDC Response: 1, 17, 18
LOCAL SERVICE CENTRES
Respondent Name: mrs serena gold [260] Submission Agent Respondent ID: 260 ID: 260 ID: SUBMISSION I am in favour of the creation of small numbers of houses within the village envelope, carefully planned to fit in with the exisiting community. However I am concerned by 'some flexibility in defining village envelopes'. My concern is that this could lead to unwanted property development that does not enhance the village or answer the need for affordable housing in rural areas.
SCDC Response: Noted
KEY SERVICE CENTRES
Respondent Name: mrs serena gold [260] Submission Agent Respondent ID: 260 ID: 260 ID: SUBMISSION
Affordable housing is needed in all areas, not just Key Areas
SCDC Response: Noted See policies DM1 and DM2
THE OVERALL STRATEGY
Respondent Name: mrs serena gold [260] Submission Agent Respondent ID: 260 ID: 260 ID: SUBMISSION It is difficult to avoid the conclusion that the LDF Core Strategy has been designed to fit with BT's planning application for 2000 houses. We should not be taken in by the offer of meeting local needs (what are they?) and affordable housing. Affordable housing is desperately needed and should be provided where it is needed, NOT all in one area where there will be little or no extra employment. How are these poor people meant to get out of this ghetto?
SCDC Response: 4, 16, See also affordable housing policies DM1 and DM2
BASE REQUIREMENTS
Respondent Name: mrs serena gold [260] Submission Agent Respondent ID: 260 ID: 260 ID: SUBMISSION How can these numbers be expressed as minima, what are we being asked to comment on - if it is minima these numbers can be exceeded by any property developer who has permission to build a 'minimum' of ... houses. Brownfield sites, well the BT land has permission to be quarried with specification that it should be returned to heath and agricultural land.
SCDC Response: Noted The RSS sets out minimum housing targets which the district must provide. The Council, if it wishes, could seek to provide a higher number than this minimum. The proposed housing distribution tables show that SCDC is proposing to provide the minimum number necessary to meet the RSS. Therefore, only sufficient land to provide for this number will be allocated.
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: mrs serena gold [260] Submission Agent Respondent ID: 260 ID: 260 ID: SUBMISSION Why is it that 1,050 houses were thought to be sufficient to create a sustainable community in 2008, now apparently 2000 are needed. The 'improved range of community facilities' would not be needed if the genuine number of houses were built and dispersed over the rest of Suffolk Coastal. Creation of such a large development would swamp Martlesham Heath and the surrounding villages, urbanise and destroy for ever a rural area. Who is going to provide, and how, the new road infrastructure, schools etc. The argument for 2000 houses concentrated in IPA East of Ipswich does not stand up.
SCDC Response: 4, 17, 20
IPSWICH POLICY AREA
Respondent Name: Mrs Sheila Page [220] Submission Agent Respondent ID: 220 ID: 220 ID: SUBMISSION This is described as a 'large development' Plans to improve the infrastructure are inadequate to overcome the problems of access roads to Ipswich where employment is more likely to be found. Suggestions that people will use bicycles is not supported by current evidence that numbers who cycle beyond Martlesham are miniscule. The development will change a rural landscape to an urban one out of keeping with the environment.
SCDC Response: 16, 17, 18, 20
THE OVERALL STRATEGY
Respondent Name: Mrs Sheila Page [220] Submission Agent Respondent ID: 220 ID: 220 ID: SUBMISSION The development east of the A12 is described as a 'large development'. This will overwhelm existing communities and quality of life of existing residents will be severely affected by pressure on all services. Current infrastructures are inadequate to cope with existing demands as evidenced by current problems with excessive traffic loads on roads entering Ipswich from Martlesham by car and bus. Planned improvements to infrastucture are inadequate.
SCDC Response: 16, 18, 20
APPENDIX 5 - REVISED SETTLEMENT HIERARCHY
Respondent Name: mrs susan harvey [253] Submission Agent Respondent ID: 253 ID: 253 ID: SUBMISSION
I support KIRTONs move to local service centre.
SCDC Response: Noted
APPENDIX 4 - BREAKDOWN OF UPDATED DISTRIBUTION STRATEGY
Respondent Name: mrs susan harvey [253] Submission Agent Respondent ID: 253 ID: 253 ID: SUBMISSION Proposal is for too many houses on the penninsular, both Felixstowe Walton and Trimleys and Martlesham (Ipswich policy area). The impact on the WHOLE area needs to be re-examined. Villages will loose their identity,areas ajacent to AONBs will be ruined. Suffolk tourism will suffer.Beautiful areas of countryside are under threat.
SCDC Response: 4, 16, 22
LOCAL SERVICE CENTRES
Respondent Name: mrs susan harvey [253] Submission Agent Respondent ID: 253 ID: 253 ID: SUBMISSION
I support the change for KIRTON from Key service centre to local service centre.
SCDC Response: Noted
THE OVERALL STRATEGY
Respondent Name: mrs susan harvey [253] Submission Agent Respondent ID: 253 ID: 253 ID: SUBMISSION 1000 houses proposed on greenfield sites in Felixstowe Walton and the Trimleys and Martlesham is unacceptable.Surrounding villages will suffer. Prime agricultural land should not be lost FOR EVER in this way. A new infrastructure, would struggle to cope with increased numbers of vehicles. When the Orwell Bridge/ A14 has to close major problems arise in Ipswich and the surrounding areas.
2000 extra houses (equivalant to a new town) in Martlesham is far too many for this whole penninsular to take.
Everyone on this penninsular has to go to Ipswich for various services, hospitals,theatres, amusements and trains. Please think again.
SCDC Response: 22, 23, 26
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Susan Moss [440] Submission Agent Respondent ID: 440 ID: 440 ID: SUBMISSION I disagree with the opinions expressed in these sections. I'm objecting strongly to the proposal to increase numbers of the Ipswich Policy Area, East of the A12/ I live next to Mr Pipes Field, main Road, Martlesham. The LDF indicates on the Suffolk Coastal maps that Mr Pipes Field and the coop land, which adjoins the Old Felixstowe Road, Martlesham, has been put forward as land for development. The map also indicates my land/garden at the OAKS is also included for development. I strongly oppose my land to be used for development.
I already live in 'a good sense of place' I do not wish for the existing community to dramatically change with a burden on Our Village and an increase of 2000 houses. Mr Pipes field is a Greenfield site and development would see an end to the space between Ipswich and Woodbridge - on that side of the road.
Number of houses is too great - when I walk my dog daily. The smell of sewage on the common Martlesham and field is sometimes over whelming, with the sewage running in the wood. The present structures can't cope at the moment, what and how will it cope in the future.
Wildlife in the field we have had nightingales, ducks, housemartins nesting. Unacceptable impact on the countryside with increased number of people - unacceptable impact on the local road - Main Road. Increased number of vehicles trying to leave the road onto the A12 causing tailbacks and the use of more traffic lights.
SCDC Response: 17, 18, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: mrs valerie mair [289] Submission Agent Respondent ID: 289 ID: 289 ID: SUBMISSION I wish to strongly object to the proposed new development at Martlesham Heath:
1. The initial consultation was made regarding 1050 proposed new houses. The new proposals for considerably more houses have had limited consultation with residents and previous objections and representations have been ignored. This is unreasonable and unacceptable since the new strategy fails to take account of the huge impact this would have on Martlesham Heath.
2. The Council has not provided any evidence to support the statement that the L.D.F. for 2000 houses at Adastral Park has ' achieved a large measure of agreement. '
SCDC Response: 1, 16
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES Respondent Name: Mrs Vera Bird [231] Submission Agent Respondent ID: 231 ID: 231 ID: SUBMISSION This proposed housing takes up all the remaining green fields which seperate Felixstowe and Walton from Trimley St Mary and I don't think it should happen. This might eventually lead to the loss of identity of Trimley. There is little enough green space around and surely this should be used for food production; particularly in the light of how much we have to import to feed ourselves. What with food prices steadily rising throughout the world, the increasing worldwide erosion of fertile coastal plains and the value of the £ constantly diminishing, cheap foreign food might become a thing of the past. Where are all the people coming from to occupy these houses? The small growth in the local population cannot account for this. Are we simply taking on someone else's surplus? Felixstowe and the Trimleys seem to have had more than their fair share of new housing over to last few decades, some of which may have been justified by the expansion of the dock workforce, but current trends no longer support further massive expansion. Whatever happened to letting places grow naturally?
SCDC Response: 22, 23
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Veronica Falconer [202] Submission Agent Respondent ID: 202 ID: 202 ID: SUBMISSION Dear Sir:
(REG 25) Consultation on Suffolk Coastal Local Development Framework Core Strategy: Proposed Changes to Housing Distribution Further to your letter dated 23rd September enclosing the latest round of Consultation Documents with regard to the Proposed Changes to the Preferred Option 12/08 document re. Changes to Housing Distribution. I list below my comments with regard to the various sections:
Summary:
I strongly object to the Stand Alone Housing Estate at Adastral Park being increased to 2000 houses on BTs 116 Hectares of Greenfield land, East of Ipswich on the Felixstowe Peninsula.
It will have a detrimental impact on the rural flat landscape displaying an urban conurbation, alien to Suffolk. The proposed mixture of housing including several Highrise dwellings in an isolated estate will be divorced from the A12 and the long established communities of Martlesham and Martlesham Heath.
Housing should be dispersed around the district as agreed for Felixstowe/Trimleys, allowing more small towns and villages to carry on growing and accommodate more fairly much needed Affordable Housing.
General Comment re Updated Preferred Option 7/09 (UPO):
In the main most of my comments/concerns below apply to the increase in housing in Suffolk Coastal's Ipswich Policy Area - 2,000 dwellings against 1,050 as mentioned in the original Preferred Options Document.
I would reiterate words from my Presentation made at the beginning of the LDF Task Group Meeting on October 15th last 'My Ward adjoins Adastral Park and it is important that you know and understand that there are great concerns and much opposition by nearby residents about the process of the LDF which is believed to be flawed'.
Page 3 UPO 3.2. 4) If the RSS took into consideration 'the quality of much of the Suffolk Coastal countryside, its soils and the wildlife it supports are of national and in some cases international importance' Why of Why has SCDC not taken this more into account and realised that such a huge development - 2,000+ -will devastate this area - ANOB, Triple SIs and Ramsar sites.
Page 4 4.01 Though SCDC say the consultation is very focused and asks whether or not the reasons behind the changes are:
- Justified
- Will ensure that the necessary broad housing strategy for the District will be better met as a result of these changes and
SCDC Press Release dated 23.9.9 gave the only reason for the change in distribution of housing as 'taking account of the changing economic circumstances' . Also on Page 5 UPO Para. 5.02 glosses over the changes and presumes we the residents of Suffolk District's IPA know in detail the Regional and National Guidance that SCDC have to adopt.
I do not think these are good enough reasons and both statements above are misleading.
In July/August 08 when the LDF Task Group Meetings were held, Appendix 3 UPO Page 25 it was proposed and later agreed that 1660 houses were to be dispersed in the Felixstowe area, BUT 1050 houses to be CENTERED on one area at Martlesham's Adastral Park This was done much to the consternation of residents. WHY, WHY, WHY Could not this housing l050 now increased to 2,000 be dispersed round the majority of villages in Suffolk Coastal's District as in Felixstowe/Trimleys.
Page 4 UPO Para 3.06 Appendix 3 Though SCDC thank all those that made comments to help them 'shape and re-shape the Core Strategy'. With the total of 10,200 houses now being required in the District - 2000 at Martlesham - There is much anger that so many of the comments submitted, most of which were highly 'justified', were not taken on board.
Ever since then my constituents and many others that live on the Felixstowe Peninsula have honestly felt that then, and now having the chance to make comments on the recent Housing Distribution Document Updated Preferred Options 7/09 that it has been DOVETAILED to meet BT Planning Application C09/1725 of 12 September 2009 for 2,000 houses etc. which has been postponed.
Page 5 UPO Settlement Hierarchy 5.06 Barr Felixstowe/Trimleys and the Market Towns Suffolk District is made up of approximately 100+ small towns and villages Appendix 5 Page 28 of UPO Revised Heirarchy. Most of them would benefit from a small amount of growth. They do not wish to die or be forgotten this is afterall the 21st Century and they have grown since the late 1970s and have emerged into modern day life since the 1940s, 50s, 60s, and wish to carry on expanding and contributing.
Most of my constituent's feel that the Housing required by the RSS and SCDC should be distributed throughout the whole County. SCDC Officer Hilary Hanslip in a recent reply to a question by Cllr. Slater at a recent Task Group Mtg. on the 15 October 2009 and in a letter to Mr Cowan of STAG said that 'Government Policy does not specify the number of houses to be allocated to a particular type of settlement.... It sets out an approach which Local Planning Authorities are required to follow'.
I believe the public have been mislead and Hilary Hanslip's comments are highly valid. She went on to say;
'The Regional Spatial Strategy too have stated that they 'require 3,200 and 7,000 houses to be provided. How these houses are then distributed across the District is then a matter for this Council (SCDC) following consultation with the general public and other consultees to determine. It is a matter of judgement set within that national and regional framework and which has regard to the views submitted in respect of these individual settlements'.
Yes, we would be happier to go along with the RSS view.
It should be noted that David Lock Associates on behalf of BT mention that the land could accommodate 3000 to 3,500 dwellings by 2031 eg 45 dwellings per hectare so SCDC know that 2000 houses on BT Adastral Park's 16l hectares is possible and this opens the doors to a future of a further 1,500 houses later.
The majority of residents in the Nacton Ward are strongly against the new proposal of 2,000 houses at Adastral Park and the thought that this could lead to another l,500 dwellings is horrendous - its impact will be dreadful on the road infrastructure and adjoining landscape destroying precious habitat and wildlife.
Page l1 - IPA UPO - Proposal to increase numbers 6.01 - One would not have to reduce the number of houses if the dispersal option was adopted around the District's villages (see my comment above Page 5 Settlement Hierarchy).
6.03 - I feel the Council's response is blinkered - a Stand alone community will result in unbelievable problems for the supporting network of roads and the lack of Secondary Education despite additional services and road infrastructure funding being contributed by the Developers. More public transport provision will not resolve the problem of isolation.
No amount of mitigation will preserve the nearby countryside landscape from the huge increase in people, dogs, joggers, cyclists and water sport enthusiast wishing to use the nearby River Deben. It is fool hardy to think mitigation is the answer.
It is inaccurate to say 'that much of the land ..... is scheduled to be used for mineral extraction'. The amount of land that is still going to be used for mineral extraction up until 2016 is minute, and nearly all the land that has been extracted over many years has been, as required, returned back to agricultural land. It should be noted that it is predicted that there will be a great shortage of agricultural land to grow the crops that Suffolk most famously produces in the future with the huge rise in the countries population.
6.04 Again no amount of mitigation will preserve the nearby flat, scenic countryside landscape from the huge increase in people, dogs, joggers, cyclists etc. and watersport enthusiasts wishing to use the nearby River Deben. It is fool hardy to think mitigation will preserve the natural habitat and landscape.
It is acknowledged in the Appropriate Assessment 6.2.20 that 'A general increase in visitors of 2 - 5% is equivalent to one extra person for every 20-50 existing visitors. This increase may have varying impacts on the European sites in the study area' and further on in 6.2.32 'but the estuary-side path between Martlesham Creek and Waldringfield is in poor repair ...... the nearest public car parks being in Woodbridge to the north and Waldringfield to the south.
It should be pointed out that Waldringfield has NO public car park. The only car parks are for clients of the Maybush Pub and Members of Waldringfield Sailing Club.
As mentioned in the submitted document Appropriate Assessment 6.6.2 SP17 Green Space Policy 'The Core Strategy will provide well-managed access to, and involvement in, green space in and around communities, including the countryside and coast, in order to benefit health, community cohesion and greater understanding of the environment without detriment to wildlife and landscape character'. Etc.
The Council's approach for 2000 houses now on the Adastral Site. I believe contravenes this Policy.
6.05 I disagree with the Council's response. Again they are glossing over the impact Traffic generated by 2,000 houses at the proposed Stand Alone Community Adastral Park will make plus the increased traffic from those using the Business Retail Centre and the proposed Innovation Centre. The traffic will double if not treble that originally talked about in 2008. The junctions on the A12 at Martlesham, Foxhall and the Seven Hill Roundabout will end up looking like an urban network of roads. The present Highway system is not wide enough to accommodate several more highway lanes and traffic lights comfortably or giving a countryside setting. There will be a huge loss along the present A12 of Gorse, a bush that has become synonymous with the area. Improvements can only be for a short distance too and will add to the congestion of traffic backing up or down further along the A12 and A14.
Conclusion I would argue that the Council's response is flawed in that the reasons given are not Justified. There is no guarantee that because the site proposed is to be doubled this will generate more 'developer contribution'. Afterall only a Primary School is envisaged on the Adastral Park Site, there is no guarantee of a Secondary School and only lately have three sites for one cropped up.
It is extremely short sighted to think that the 'nearby ANOB and nature conservation interests of the estuary will remain as at present. Such huge numbers will impact. Consideration should be given to an alternative distribution - yes - disperse throughout the County.
Page 13 UPO Summary 7.03 East of the A12 - All the objections made in my previous comment letters of 8.4.08 and February 2009 apply, but doubly so. - - - It is not believed that the objectives can be achieved.
Page 15 Your comments 8.01 and 8.02 You ask for our comments but I do not find this Updated Preferred Option 7/09 document has 'soundness' of production. There are too many residents in my Ward - Waldringfield, Newbourne, Hemley etc. that feel the document has not 'achieved a large measure of agreement' as a result of the changes shown in this latest document.
Though SCDC say the consultation is very focused and asks whether or not the reasons behind the changes are:
- Justified - Will ensure that the necessary broad housing strategy for the District will be better met as a result of these changes
Residents feel that the Justification for increasing 1050 houses to 2,000 in Suffolk' District of the IPA are not accurately given.
Act in haste - regret at leisure.
The motto of 'Where Quality of life counts' will if this proposal of 2,000 houses in Suffolk Coastal's IPA goes ahead will soon have to be revised. It will be an area difficult for tourists to get to and they wont want to spend their leisure hours and weeks in an urban area.
Assessment and Appraisals
General comments These documents are both very in depth and informative and I wish the majority of residents in SCDC had had the opportunity to peruse them earlier or more time had been allowed to digest them, as they are very pertinent to the development of the LDF, and only recently, an addendum by AECOM to the original Transport Study was issued.
Continued:
Pages 16 and 17 Appendix 1 Ipswich Eastern Fringe and Felixstowe Infrastructure Studies - September 2009 My main comments mainly apply to the Suffolk District of the IPA - Option 4
Para Key Findings it says 'The options tested have differing needs but all options have some significant infrastructure requirements that could reasonably be expected to be paid for by funding and developer contributions'.
I believe it is quite unrealistic to expect a Developer building 2000 houses at Martlesham and 1000 in the Felixstowe areas to provide funding towards 14 Major services each over a 3 year Phase period. Two Services - Fire and Telecommunications are able to cope with the existing set up seemingly.
I can find no reference to Well or Bore Hole water Services in the Infrastructure documents and I would add that on the Felixstowe Peninsula there are a large number of residents on the Felixstowe Peninsula that are dependent on Well water and have no access to Mains water. Bore Hole Licences have reached capacity and further extraction will cause unacceptable environmental damage especially in the light of climate change. This aspect too should be taken into consideration by the Developers bearing in mind that such huge earth works could destroy their supply of natural Spring Water.
The new proposed site is on agricultural land some of which is used for mineral extraction. Agricultural land is and will be, of the utmost importance for the survival of man. Recently The Daily Telegraph said 'that agricultural yields are expected to decrease for most crops in all regions once the global average temperature rises more than three degrees Centigrade or 5.4 degrees Fehrenheit' This is a major concern .
Ipswich Eastern Fringe Infrastructure Study - September 2009 Document says it 'will underpin the spatial development strategy of the Core Strategy which is required to deliver approximately 2,000 dwellings in the Ipswich Policy Area within Suffolk Coastal district'.
Page 1 Introduction I would be interested to know why this document was only forthcoming in September this year and not available to everyone in the Spring of 2008 when various Policies and Core documents were being established?
Page 19 Appendix 1 Proposed Strategy Transport Appraisal - September 2009.
I find that there is little mention of the Orwell Bridge and the Seven Hills Roundabout - a major transport link . Page 3 of the actual Appraisal 1.3 Study Restrictions SCDC mention that the Study has been progressed with the following restrictions and mentions five bullet points ' where no consultation or new network modelling work has been undertaken' and in bullet point 6 admit that 'trip generation and distribution calculations are largely based on 2001 census data which is considered the most appropriate date available ...... it should be highlighted that it is now 9 years old and mode splits in particular are likely to be slightly different now'.
That is an understatement - even in recessionary times traffic both domestic and HGV using the Orwell Bridge and 7 Hills Roundabout is excessive and it only takes a minor accident to bring the major part of Suffolk Coastal district to a standstill. The County cannot cope with its present demands let alone those envisaged in 2025 or 2031.
Considering the amount of congestion that at present takes place on the Felixstowe Peninsula leading to the Orwell Bridge, I have little confidence that the road infrastructure will be able to cope with 3,000 extra households on the Peninsula generating about 6,000 commuting and residential cars in the area, let alone all the service vehicles. Life on the Felixstowe Peninsula will come to a grinding halt.
In addition
TEUs - HGV Container Traffic
The documents submitted are flawed in that they do not mention in detail that at present 3 million TEU (Containers) use the A14 and Orwell Bridge. Because of the recession it may be the case that less than 3 million are at present using the A12/14. But that will no doubt be rectified in the not too distant future However, it is forecasted that 5 million containers (TEUs) will be leaving from or arriving to The Port of Felixstowe in 2015. God knows what the figures will be in 2025.
No plans seem to be in the pipeline to alleviate the Orwell Bridge and it should be noted that when Operation Stack or an accident near or on the Orwell Bridge occurs, it brings unbelievable headaches not only to the motorist, but to the Police, fire and ambulance services.
I mooted in July 2008 at the LDF Task Group Mtg. that a bridge or tunnel should be built from Felixstowe Docks to take HGVs only, in and out of Felixstowe Docks West and South over to the Harwich Peninsula and its road system. This idea has seemingly fallen on deaf ears though BT did in fact seem fairly interested at the time. I believe this idea should be considered as it would leave the present A14/A12 and Orwell Bridge to cope with only the incoming and outgoing of HGVs driving North and East. An engineering feat quite possible in this day and age.
Page 72 Proposed Strategy Transport Appraisal East of Ipswich 8.3 that 'Local Walking and cycle routes will need to be improved and though SCC has a long term goal for a pedestrian/cycle link across the A12 to provide key linkage from Site 4 ( BT) and Site 3'.
Again this is misleading as Walking and Cycle routes are also elsewhere in the District not just over the A12.
Page 19 Appendix 1 Future Secondary Schools Provision Alternative Sites Assessment IPA
On Page 5 of this Assessment under Regional and Local Policy 3.1.3 Colin Buchanan has mentioned that 'Adastral Park is recognised as a Key employment location, accommodating an established and expanding ICT cluster and proposed Innovation Centre' - this may well be the view of the past, is it the view of the future bearing in mind the present problems that BT is experiencing?
And on Page 7 3.2.3 Education 'As a result pupil forecasts, including future planned growth, indicates that additional secondary school capacity is required. Demand for one new Secondary School would normally be required for 5,000 new homes' and in 3.2. 8 ha are required to accommodate a new 11-18 secondary school with capacity for 1,050 pupils including playing fields.
The present proposal for 2000 houses no where meets this criteria. The present Secondary Schools both in Felixstowe and at Kesgrave cannot cope with present day demands and many families are being caused great distress in having their children going to Secondary Schools that are not in their catchment area. Again it is only since June 2009 that many residents have become aware of three sites where a new Secondary School could be built in the Martlesham area see 1.1.3. of Page l of the above Assessment. This particular demand should have been taken into consideration when the Core Strategies were developed.
Sustainability Appraisal of Core Strategy and Development Management Policies Document
Page 7 No. 17 under SP20 Area East of Ipswich Development will reduce overall value of the area to biodivisity and geodiversity, retention of Suffolk Sandlings respected; improved access to countryside for large numbers of residents may have impacts here too. Eg. Adjacent River Deben'.
And later on in the Assessment Summary it is acknowledged that 'Increasing the level of housing anywhere will lead to the generation of more traffic that could impact air quality depending on location .....preferred option being confirmed as land immediately abutting Adastral Park - considered in site specific assessment as the worst site for congestion and environmental impacts but good for employment/linkages related indicators'.
The two above statements sum up enormously the feeling of residents living in and around Martlesham, Waldringfield and some the surrounding villages and should influence the approach of the LDF..
Most residents on the Peninsula have no objection to the expansion of Adastral Park's key employment location and expanding the ICT cluster and the future Innovation Centre but the road infrastructure cannot accommodate the amount of traffic both domestic, business and school runs that will be generated by 2,000 houses. The many local services that will also be needed as the result of a completely new stand along community built over a 15/20 year period, will destroy the rural and agriculture landscape of Suffolk District of the IPA on the Felixstowe Peninsula.
It is a wrong old fashioned assumption, that people want to live near their work place. People today have a choice of where they wish to live and as a result of Broadband, working from Home has become very acceptable and the norm for a number of organisations and tele-working, and tele-conferencing has made long distance meetings easier. Who wants to work and live in a congested area. Not many.
There is much more that I could say on the increased Housing for Suffolk's District of the IPA but I am sure I am not alone in voicing my strong objections.
SCDC Response: 1, 4, 9, 10, 11, 12, 13, 15, 16, 17, 18, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Mrs Wendy Sexton [356] Submission Agent Respondent ID: 356 ID: 356 ID: SUBMISSION Dear Sirs I am writing to express my objections to the revised plan in respect of the proposal for 2000+ house to be built near Adastral Park.
It seems like the Council have taken an approach by BT to develop their land as an answer to the Council's prayers to have to find a way to comply with an unelected quango's demands for housing, and then formulated a plan to justify the action to be taken.
There is a contradiction in reasoning in that for the developments at Felixstowe small areas are proposed whereas for Martlesham the bigger the better seems to be the object.
There seems to be hardly any specific and concrete evidence to support the "benefits" of such a large scale development at Martlesham.
No detailed consideration has been given of the effect that such a large development will make to the air quality, light pollution, traffic congestion, the unique qualities of Martlesham Heath village and existing local services. Surveys on habitat and surrounding country areas report a detrimental effect.
No account has been taken of the wishes or quality of life of the existing habitants of the adjoining areas.
Surely the requirement of such a large scale house building program in the SCDC area should provide opportunities to revitalise the smaller villages and communities to help sustain their infra structure of shops, pubs etc and thereby spread the demands on existing infrastructure and services over a much wider area and with less adverse impact.
It is disappointing that the planners seem to be placing the wishes of BT above the communities they are supposed to be serving.
SCDC Response: 4, 15, 16, 17, 18, 19
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Ms Carol Florey [303] Submission Agent Respondent ID: 303 ID: 303 ID: SUBMISSION 1. We welcome the reduction in housing numbers allocated to the Felixstowe Peninsular 2. We welcome the proposed management of housing numbers at Felixstowe/Walton and the Trimley Villages to reflect appropriate scale and development (Point 7.02). 3. We object strongly to Point 7.04 'land at present separating Walton and Trimley St Mary be used to create a 'hub' of community and commercial facilities' on the following grounds: if this refers to area 451g as referenced in your last proposal, this is GRADE 1 FARMLAND and therefore should not be developed as directed by Government Policy set out in 'A Better Quality of Life' and 'Planning Policy guidance Note 7'. These clearly state that quality farmland should be 'protected from inappropriate development' and 'where significant development of agricultural land is unavoidable, local planning authorities should seek to use areas of poorer quality land (Grades 3b, 4 and 5)'. Present Government Policy also promotes greater self-sufficiency for both individuals and the country as a whole, thus stressing the importnace of maintaining all quality farmland. This plot of land forms a natural boundary between Walton and The Trimleys and has been actively protected as such by the local council for many years. Planning Policy Guidance Note 7 states that planning should 'enhance local distinctiveness.' 4. We object strongly to the proposal of a link road between Candlet Road and the High Road if this should be sited on the above piece of land (Site 451g) for the following reasons: Candlet Road is already beyond capacity at peak times, traffic queueing from the Dock Spur roundabout to Garrison Road roundabout. The main flow of traffic to use this new road would logically be from the Dock Spur roundabout, hence requiring a right turn across this already substantial traffic flow. The resulting queues would cause blockages on the Dock Spur roundabout, already a black spot area. The suggestion of a commercial area in this area implies heavy traffic to add to congestion. Money has not been available in the past to make the much needed improvement to this area so is unlikely to be found now. 5. If all of the above points are to be ignored, we object most strongly to treetops being considered as a through road for the following reasons: Access to and from Gulpher Road is already dangerous due to the increased traffic to the new industrial area, which travels at speed, and poor road visibility. It would serve no purpose other than to provide potential as a 'rat run'. As identified in the David Lock Associates report 'an issue to avoid at all costs is the potential for rat runs'. The trend in recent developments supports planning that incorporates enclosed areas rather than through roads. We strongly wish to retain our present identity as a close.
SCDC Response: 22, 23, 24, 26
THE OVERALL STRATEGY
Respondent Name: Ms Janette Brown [281] Submission Agent Respondent ID: 281 ID: 281 ID: SUBMISSION 2000 new houses will overwhelm Waldringfield and other existing communities. Waldringfield is at the end of a no through road, so what comes in will have to go out again. Quality of life of existing residents will be severely affected by pressure on all services and will spoil the rural character of this area. This new town is far too close to the AONB and will adversely affect the wildlife habitat of the Deben and Waldringfield area and ruin the peaceful nature of the village. You should not allow a large development east of the A12 in this area.
SCDC Response: 17, 18
IPSWICH POLICY AREA
Respondent Name: Ms Janette Brown [281] Submission Agent Respondent ID: 281 ID: 281 ID: SUBMISSION A new town of 2000 new homes located East of the A12 would be disastrous for the village of Waldringfield. Waldringfield is a peaceful rural village within the AONB and its character would be changed by the close proximity of the new town. The new town residents would clog the access road to the river and the pub and they would park along Cliff Road. This is potentially dangerous, limiting emergency access to The Quay, where I live, and Deben Lane and Cliff Road. There is no public parking in Waldringfield, and no public WC, so the village is not prepared for a mass influx of visitors. The peace of the village would be destroyed and the beach and river walls would become overcrowded. The river wall passing in front of my house would see a large increase in pedestrian traffic contributing to erosion of the river wall and impacting significantly on our privacy. It would also disrupt bird and animal life on the sea wall where we have important habitats for barn owls, otters, avocets and other waders. The access road into Waldringfield is narrow and has dangerous bends. I already do not allow my children to cycle on it and it would get even more dangerous. There have already been several accidents at the crossroads with the golf club, one two weeks ago involving two cars, which completely blocked the road out to Foxhall. This again impacts on emergency access and Waldringfield has had three fires this year alone.
You have a stated objective of respecting the quality of the local environment and this new development flies in the face of this objective.
SCDC Response: 17, 18, 19
THE OVERALL STRATEGY
Respondent Name: Ms Janette Brown [281] Submission Agent Respondent ID: 281 ID: 281 ID: SUBMISSION 2000 new houses will overwhelm Waldringfield (and other existing local communities). Quality of life of Waldringfield residents will be severely affected by pressure on all services and will spoil the rural character of this area. This new town is far too close to the AONB and will adversely affect the wildlife habitat of the Deben and Waldringfield area and ruin the peaceful nature of the village. You should not allow a large development east of the A12 in this area.
SCDC Response: 17, 18
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION I OBJECT TO HOUSES BEING BUILT ON THE FELIXSTOWE PENINSULA. RE:APPENDIX 2, SUSTAINABILITY APPRAISAL OF REVISED POLICIES, JUNE 2009. PAGE 36 OF 90. RE:SP5 - EMPLOYMENT LAND. OBJECTIVE 9. TO MAINTAIN AND WHERE POSSIBLE IMPROVE AIR QUALITY. MITIGATION: EMPLOYMENT LAND CAN SOMETIMES CAUSE AIR QUALITY CONCERNS.
MORE AQMA'S !!!
SCDC Response: 22 Noted
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION I OBJECT TO MORE HOUSES ON THE FELIXSTOWE PENINSULA. RE:APPENDIX 2, SUSTAINABILITY APPRAISAL OF REVISED POLICIES, JUNE 2009. PAGE 35 OF 90. SP10 - A12 & A14. OBJECTIVE 9 - TO MAINTAIN AND WHERE POSSIBLE IMPROVE AIR QUALITY. MITIGATION : ADDITIONAL ROADS MAY ENCOURAGE INCREASED USE OF PRIVATE CARS AND SUBSEQUENTLY INCREASE POLLUTION. AND YOU LOT WANT MORE HOUSING WHEN THE AIR QUALITY (IF MONITORED PROPERLY) IS BAD NOW!
SCDC Response: 22
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION I OBJECT TO MORE HOUSING ON THE FELIXSTOWE PENINSULA. APPENDIX 2 - SUSTAINABILITY APPRAISAL OF REVISED POLICIES, JUNE 2009. PAGE 22 OF 90 - OBJECTIVE 13 - TO REDUCE WASTE. MITIGATION - MORE HOUSING WILL RESULT IN INCREASED WASTE.
SCDC Response: 22
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION I OBJECT TO MORE HOUSING ON THE FELIXSTOWE PENINSULA. RE: APPENDIX 2, SUSTAINABILITY APPRAISAL OF REVISED POLICIES, JUNE 2009. RE: SP2 - HOUSING DISTRIBUTION - PAGE 22 OF 90 - OBJECTIVE 14 - TO REDUCE THE EFFECTS OF TRAFFIC ON THE ENVIRONMENT. MITIGATION - MORE HOUSING WILL RESULT IN INCREASED TRAFFIC. THE A14 IS AT CAPACITY NOW AT PEAK TIMES!
SCDC Response: 22, 26
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION I OBJECT TO MORE HOUSING ON THE FELIXSTOWE PENINSULA. RE: APPENDIX 2, SUSTAINABILTY APPRAISAL OF REVISED POLICIES, JUNE 2009. RE: SP2 - HOUSING DISTRIBUTION ITEM 9 - OBJECTIVE: TO MAINTAIN AND WHERE POSSIBLE IMPROVE AIR QUALITY. MITIGATION: MORE HOUSING WILL RESULT IN INCREASED TRAFFIC AND HOUSEHOLD AIR POLLUTION. THE AIR QUALITY IN FELIXSTOWE IS NOT GOOD AT THE PRESENT, IS IT?
SCDC Response: 22, 26
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION I OBJECT TO MORE HOUSING ON THE FELIXSTOWE PENINSULA. RE:APPENDIX 2 - SUSTAINABILITY APPRAISAL OF REVISED POLICIES , JUNE 2009 RE: SP2 - HOUSING DISTRIBUTION PAGE 22 OF 90, ITEM 4 -OBJECTIVE: TO REDUCE POVERTY AND SOCIAL EXCLUSION. MITIGATION: SUSTAINABLE MIX OF HOUSING TYPES MAY INCLUDE SOME AFFORDABLE HOUSING. WHAT HAPPENED TO A "THIRD" OF ALL NEW DEVELOPMENTS WHOULD BE AFFORDABLE?
SCDC Response: 22 Noted. See Affordable Housing Policies DM1 and DM2
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION I OBJECT TO MORE HOUSING ON FELIXSTOWE PENINSULA. RE: AIR QUALITY IN FELIXSTOWE. APPENDIX 2. SUSTAINABILITY APPRAISAL OF REVISED POLICIES, JUNE 2009. PAGE 10 OF 90 - ITEM 9.OBJECTIVE: TO MAINTAIN AND WHERE POSSSIBLE IMPROVE AIR QUALITY. MITIGATION - SIGNIFICANT DEVELOPMENT LIKELY TO HAVE SOME NEGATIVE EFFECT ON AIR QUALITY.
SCDC Response: 8, 22
IPSWICH POLICY AREA
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION GREENFIELD SITES SHOULD NOT BE BUILT ON IN FELIXSTOWE OR MARTLESHAM. EAST OF ENGLAND REGIONAL ASSEMBLY PLAN (RSS - REGIONAL SPATIAL STRATEGY - DEC 2004) STATES: 2.14 IT IS NOT POSSIBLE TO PREDICT THE EXACT SOURCES OF FUTURE MIGRATION BUT IF RECENT TRENDS CONTINUE, THE MAJOR GROSS FLOWS INTO THE REGION WILL COME FROM LONDON (APPROX 40% OF ALL IN-MIGRANTS), FROM OVERSEAS (20%) AND FROM THE SOUTH EAST REGION (15%). SO THESE HOUSES ARE FOR LOCAL PEOPLE?
SCDC Response: 15
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION GREENFIELD SITES SHOULD NOT BE BUILT ON IN FELIXSTOWE OR MARTLESHAM. EAST OF ENGLAND REGIONAL ASSEMBLY PLAN (RSS - REGIONAL SPATIAL STRATEGY - DEC 2004) STATES: 2.14 IT IS NOT POSSIBLE TO PREDICT THE EXACT SOURCES OF FUTURE MIGRATION BUT IF RECENT TRENDS CONTINUE, THE MAJOR GROSS FLOWS INTO THE REGION WILL COME FROM LONDON (APPROX 40% OF ALL IN-MIGRANTS), FROM OVERSEAS (20%) AND FROM THE SOUTH EAST REGION (15%). SO THESE HOUSES ARE FOR LOCAL PEOPLE?
SCDC Response: 22
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION I OBJECT TO HOUSING ON THE FELIXSTOWE PENINSULA. WHY DON'T YOU ALLOCATE SOME OF THESE HOUSES TO AREAS WHERE THERE ARE LOTS OF SECOND HOMES (IE,WALBERSWICK 34%, ALDEBURGH 27%) SEE EADT WEBSITE 27/10/09 WHO SAYS ALL THESE HOUSES HAVE TO BE BUILT AS ONE OR TWO BIG ESTATES?
SCDC Response: 4
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION I OBJECT TO HOUSING ON THE FELIXSTOWE PENINSULA. NOISE, LIGHT AND AIR POLLUTION IS BAD ENOUGH NOW. I WOULD LOVE TO SAY I CAN HEAR THE THE AEROPLANES IN THE SKY BUT DUE TO THE CONSTANT DRONE DAY AND NIGHT FROM THE A14 THIS ISN'T POSSIBLE!
SCDC Response: Noted
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION I OBJECT TO HOUSING ON THE FELIXSTOWE PENINSULA. GULPHER ROAD AREA IS LOCATED IN AN AREA OF FOCUSSED SEARCH AT DISTRICT LEVEL(20HA+) FOR OPPORTUNITIES TO CREATE A NEW ANG (ACCESSIBLE NATURAL GREENSPACE), IN ORDER TO ADDRESS CURRENT AND PREDICTED DEFICIENCIES. THE SITE MAY PROVIDE OPPORTUNITY TO ADDRESS THE DISTRICT LEVEL ANG DEFICIENCY(IDENTIFIED AS PROJECT NO.41: FELIXSTOWE ANG DEFICIENCY). HAS THIS IDEA BEEN BINNED TOO!!!
SCDC Response: 22, 23
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION I OBJECT TO HOUSING ON THE FELIXSTOWE PENINSULA. "RE:- PROJECT NO.40: NORTH FELIXSTOWE FRINGE GREEN CORRIDOR.TO THE NORTH A POTENTIAL GREEN CORRIDOR PROJECT HAS BEEN IDENTIFIED WITHIN THE HAVEN GATEWAY GIS" WHEN WILL THIS PROJECT BECOME REALITY? OR HAS THIS BEEN BINNED BECAUSE IT DOESN'T FIT IN WITH THE LDF MASTERPLAN?
SCDC Response: 22, 23
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION I OBJECT TO HOUSING ON THE FELIXSTOWE PENINUSLA. "IT HAS BEEN IDENTIFIED IN THE HAVEN GATEWAY GREEN INFRASTRUCTURE PLAN THAT FELIXSTOWE HAS THE LEAST ACCESSIBLE NATURAL GREEN SPACE AT PRESENT. THE TOWN'S LOCATION TOGETHER WITH THE SCALE OF THE PORT MEANS THAT THERE ARE LIMITED OPPORTUNITIES TO GAIN EASY ACCESS TO THE COUNTRYSIDE." SO WHY RUIN WHAT WE ALL READY HAVE LITTLE OF!!!!!
SCDC Response: 22, 23
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION I OBJECT TO ANY HOUSES BEING BUILT ON THE FELIXSTOWE PENINSULA BASED ON THIS LDF REPORT. THE EVIDENCE BASE HAS BEEN PROVEN TO BE FLAWED FROM START TO FINISH. IN MY OPINION, WE SHOULD NOT HAVE TO LOSE ANY GREENFIELD SITES DUE TO THE WHIM OF ONE TUNNEL-VISIONED COUNCILLOR!
SCDC Response: 22, 23
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION INFO "ZOOPLA" 16.11.2009
AVERAGE HOUSE PRICE/PROPERTIES SOLD OVER THE LAST 3 YEARS:- FELIXSTOWE £184,585 1,428 WOODBRIDGE £259,748 1,811 ALDEBURGH £341,657 255 SOUTHWOLD £331,644 323 STOWMARKET £190,162 2,046 SAXMUNDHAM £241,924 569 DISS £216,330 1,385 IPSWICH £179,536 10,408
I OBJECT TO BUILDING MORE HOUSES WHERE THEY ARE ALREADY THE CHEAPEST AND NOT NEEDED!
SCDC Response: 22 Noted
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION So,the PORT OF FELIXSTOWE is concerned about housing impact on the A14! RE:FSR public inquiry-November 2004 Statement of Common Ground. It states "The link Capacity assessment demonstrates that the links along the A14(T) between Seven Hills and Copdock Interchanges would become over capacity with or without the FSR scheme in place within the FSR assessment period". (2003-2031) HPUK is concerned that 'piece-meal' development will result in traffic impacts on the A14/A12. This is an area of major concern to the future success of the Port in an increasingly competitive UK market for container handling and can not be understated.
SCDC Response: 12 Noted
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: ms julie cornforth [172] Submission Agent Respondent ID: 172 ID: 172 ID: SUBMISSION I OBJECT TO MORE HOUSING ON FELIXSTOWE PENINSULA. IF YOU BUILD MORE HOUSES ON THE FELIXSTOWE PENINSULA, IT WILL HAVE A BAD KNOCK-ON EFFECT FOR THE PORT OF FELIXSTOWE. THE A14 IS AT CAPACITY NOW, AS HAVE BE PROVEN AND BY BUILDING MORE HOUSES HERE WILL MEAN MORE TRAFFIC ON THE A14 (THE ONE ROAD IN/OUT OF FELIXSTOWE!) LORRIES/WORKERS STUCK IN QUEUES MEANS TIME WASTED AND MONEY BEING LOST. WHAT WILL HAPPEN IF AN AMBULANCE WANTS TO GET THROUGH IN AN EMERGENCY? WILL THE LDF TASK GROUP BE RESPONSIBLE FOR KILLING THE GOLDEN GOOSE THAT KEEPS FELIXSTOWE IN EMPLOYMENT!
SCDC Response: 12, 22, 24
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Ms Louise Limb [28] Submission Agent Respondent ID: 28 ID: 28 ID: SUBMISSION Thank you for the opportunity to respond to the policies.
Regarding the following: SP2 2.2, iii and SA 1,3,4,5. These are very closely connected and I would like to try to put a case for a MASSIVE upgrade and promotion (and investment in new ones) of foot and cycle paths because this will (if done thoughtfully) correspondingly; improve the health of the population overall, reduce crime and anti-social activity, reduce the effects of poverty and social exculsion, and improve access to key services for all sectors of the population.
This next part is just a copy of the relevent SP and SA, then my attempt to combine the two, so supporting and further reinforcing the already stated requirement for investment in foot and cycle ways, which could go a long way to achieving the objectives in SA1,3,4, &5.
SP2, 2.2, iii "provision and foot and cycle paths can be upgraded and promoted to minimise the need to use private motor vehicles with the major service centre of Ipswich nearby"
(We also visit Woodbridge - its nearer, and Felixstowe)
SA 1), 3) 4) & 5),
1. To improve the health of the population overall + Minimise need for motor vehicles, upgrade foot and cycle paths for access to employment, schools etc, maximise access to green space
3. To reduce crime and anti-social activity
4. To reduce poverty and social exclusion + Sustainable mix of housing types may include some affordable housing
5. To improve access to key services for all sectors of the population + Allocations reflect access to services
I feel that the plan needs to go WAY BEYOND MERE UPGRADING for foot and cycle paths. Especially to create and improve access to green space, and especially, access to visit friends and family by foot, cycle or 'electric powered wheelchair'. Children making friendships in secondary schools drawing from a mixture of catchment settlements need to be able to visit one another, meet up in actual space rather than cyber space.
Yes there is a need to have adequate foot and cycle paths (for whole families to use at once - safely) into Ipswich (and Woodbridge!), but also for access to leisure spaces and leisure destinations that are of a more natural and environmental kind, eg friends homes & gardens, park, forest, seaside, riverside, woodland - the great outdoors! I think it is unhealthy for both adults and children alike to be continually be encouraged to go to relatively expensive consumer facilities for leisure time. ( ie. leisure centres, entertainment complexes, shopping. Mental and physical health goes beyond the confines of a leisure centre, gym, shopping centre, entertainment complex.
New cycle and walk ways, other than being attractive routes in themselves -attracting and sustaining rural wildlife, also need to connect people within different communities and as well as connecting them with and amenity/leisure spaces to enjoy.
On points SA 3 & 4. Please give us more to do that is fun, outdoors with some adventure and excitement that doesn't necessarily involve spending money AGAIN. (Like being able to travel by cycle or foot to free, restorative, restful outdoor spaces). Many of us just can not afford to keep paying out 2 - 4 (often much more) per hour per person per 'go' for something to do during a weekend. Eg, swimming, cinema, bowling, having a snack while trailing round the shops, bus fare. There really is not much that is exciting and affordable for children to do independently for entertainment. Eg.2 hours entertainment for one child = 5 - 8, then there are another 16 waking hours to fill for that day!
Leisure must be a key service, and there is so much more that could be done to give access to the countryside for youngsters, starting with attractive, adequate cycle and walkways to outdoor spaces where they can be themselves, have some privacy, adventure and the security of adult presence nearby. (thats why they hang around near shops or stay indoors - people, food supply, light).
Will new cyclepath developments allow us safe walking/cycle access to eg. Woodbridge Skate Park , Rendlesham, Waldringfield Beach, Newbourne Springs, Woodbridge, Felixstowe Beach etc to give us some choice and variety (Ipswich is not the only retail place needing customers).
Park and Ride is great if you have got a car to get to it, is within walking distance, and goes to where you want to go. It excludes alot of the population. Rural bus routes are usually contorted, lengthy and inconvenient, please consider investing for the true health of the community and not only for the rates returned from retail outlets.
Please ensure that this SP2 is fully exploited in the light of SAs 1,3,4,5. so that we provide more that an 'adequate' or 'token' amount of money into cycle and walkways and fulfill the deeper value of finding a way to connect people with other people within and between local communities and the natural environment.
On point 5. LEISURE SPACE in the Natural Environment and AMENITY AREAS are SERVICES. Please, when the new housing developments go ahead we can stay connected with one another and our local environment the local area other than by motor vehicle.
Regards, Mrs Louise Limb
SCDC Response: 8, 11
APPENDIX 5 - REVISED SETTLEMENT HIERARCHY
Respondent Name: Ms Mary Skelcher [80] Submission Agent Respondent ID: 80 ID: 80 ID: SUBMISSION I object to Peasenhall being designated as a key service centre. As a matter of fact it does not meet the criteria. There is no pub, public transport, minimal employment, no Doctor's surgery. At a packed public meeting there was overwhelming opposition to this designation by residents.
In summary, neither the facts nor local opinion support the designation of Peasenhall as a KSC. SCDC should take note and re-designate it as a LSC.
It is not clear which part of Sibton has been included, nor why this has been done. The parishes are separate. Sibton should be kept as a whole, not divided.
SCDC Response: Noted
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES
Respondent Name: Ms Ruth Breton [72] Submission Agent Respondent ID: 72 ID: 72 ID: SUBMISSION I object to the Core Strategy in its entirety as it affects Felixstowe, Walton and the Trimleys. Apart from a small number of affordable houses for local needs, the rest should be distributed across the district to minimise infrastructure costs and maximise sustainability of smaller communities. As the police service is now based in Woodbridge and we only have a small response team in Felixstowe, perhaps the bulk of the new housing should go to Woodbridge.
SCDC Response: 4, 22
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: ms sarah northey [268] Submission Agent Respondent ID: 268 ID: 268 ID: SUBMISSION The increase in housing numbers will leader to greater adverse impacts not less! There will be more traffic passing through surrounding communites particularly Waldringfield where more visitors will go to the Maybush Pub and to visit the river and casue damage disturbance to the SSSI/SPA- no mitigation will be able to stop this. Also this represents overdevelopment of this site leading to increased visual impact and greater urbanisation of a currently open landscape. SCDC should not try to justify the increase on the back of more money/ mitigation to be provided by the developer - bigger is not better. Also the increase alone does not justify a new secondary school - just increases the need for one.
SCDC Response: 17, 19
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: ms sarah northey [268] Submission Agent Respondent ID: 268 ID: 268 ID: SUBMISSION Development of this area would not satisfy the stated objectives. There would be an unacceptable adverse impact on surrounding communities from the additional road traffic and countryside and wildlife from the huge increase in visitor numbers to the Deben SSSI/SPA which it would not be possible to successfully mitigate against.
SCDC Response: 17
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY?
Respondent Name: ms sarah northey [268] Submission Agent Respondent ID: 268 ID: 268 ID: SUBMISSION Increasing the housing in the IPA, east of the A12, at Martlesham does not limit the adverse impact on communities, the countryside and wildlife - in fact it increases the adverse impact.
SCDC Response: 17, 18
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: ms sarah northey [268] Submission Agent Respondent ID: 268 ID: 268 ID: SUBMISSION Increasing the housing in the IPA, east of the A12 at Martlesham does not comply with the points set out as the reason for the LDF housing distribution. Namely the local roads are not capable of accommodating additional traffic, particularly narrow single lane roads through surrounding villages; the new housing will have a detrimental impact on the character of settlements and communities that are currently surrounded by open countryside and will have a detrimental impact on landscape and wildlife of international importance.
SCDC Response: 17, 18, 19
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT?
Respondent Name: ms sarah northey [268] Submission Agent Respondent ID: 268 ID: 268 ID: SUBMISSION There is no justification for the increase in housing within the IPA, east of the A12 at Martlesham. This is just an easy option for the council to provide the required housing needs set out in the RSS, as BT is offering the land and has already submitted a planning application.
SCDC Response: 16
3 BACKGROUND
Respondent Name: ms sarah northey [268] Submission Agent Respondent ID: 268 ID: 268 ID: SUBMISSION The document states that the RSS recognises the quality of the Suffolk coastal countryside and that its soils and wildlife are of national and in some cases international importance. This is not recognised in the LDF as the signficant increase in housing east of the A12 will increase visitors and disturbance to the Deben SSSI and SPA which will have a detrimental impact. Also the development of this area would lead to the loss of open countryside.
SCDC Response: 17
2 THE CONSULTATION IN BRIEF
Respondent Name: ms sarah northey [268] Submission Agent Respondent ID: 268 ID: 268 ID: SUBMISSION Object to the unjustified substantial increase in houses in the IPA, east of the A12 at Martlesham. This has not been changed in response to previous concerns raised but has been done to support BTs submitted planning application and because it provides SCDC with an easy (but not the right) option to meet housing needs.
SCDC Response: 16
8 YOUR COMMENTS
Respondent Name: Ms Susan Donaldson [278] Submission Agent Respondent ID: 278 ID: 278 ID: SUBMISSION I object strongly to the way this site is deliberately difficult to use. The number of houses proposed for this site is unwarranted, the scale is out of balance and character with the area and will blight the landscape. This new proposal has been introduced without the detailed consultation of the first consultation and the current plan is effectively a totally new plan. This is the easy option for council without necessary forethought to consequencies. No local councillors were on committee making decision. This is certainly NIMBYism as councillors have ensured development is outside their areas.
SCDC Response: 1, 16, 17
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES Natural England (Mrs Pat Respondent Name: Williams) [345] Submission Agent Respondent ID: 345 ID: 345 ID: SUBMISSION Natural England previously expressed concerns over development in this area impacting on the Orwell Estuary designated site. Any potential impacts will be lessened if the housing allocation is reduced as will the impact on the AONB, which is to be welcomed.
SCDC Response: Noted
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES Natural England (Mrs Pat Respondent Name: Williams) [345] Submission Agent Respondent ID: 345 ID: 345 ID: SUBMISSION We fully support the development of projects included in the Haven Gateway Green Infrastructure Study to address the shortfall in natural green spaces and, further, to offset potential impacts on sites of national and international importantance for biodiversity.
SCDC Response: Noted
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES. Natural England (Mrs Pat Respondent Name: Williams) [345] Submission Agent Respondent ID: 345 ID: 345 ID: SUBMISSION With the increase in housing to 2,000 in area East of Ipswich it will be even more important that 'Protection should be given to wildlife and to the landscape, particularly those areas that are designated as being of national and international importance'.
SCDC Response: Noted
WHY ARE THE NEW HOMES BEING SHARED OUT IN THE PROPOSED WAY? Natural England (Mrs Pat Respondent Name: Williams) [345] Submission Agent Respondent ID: 345 ID: 345 ID: SUBMISSION Increasing the housing allocation East of Ipswich to 2,000 will make 'Limiting any adverse impact of new development on existing communities, countryside and wildlife' harder to achieve.
SCDC Response: Noted
IPSWICH POLICY AREA Natural England (Mrs Pat Respondent Name: Williams) [345] Submission Agent Respondent ID: 345 ID: 345 ID: SUBMISSION Natural England in previous consultations put forward our concerns with this area for housing development due to the proximity to the AONB and the Deben Estuary nationally and internationally important sites. Doubling the housing allocation will increase the potential for impacts. However, if the allocation is to be confirmed then we welcome the Area Action Plan as provision of green infrastructure and other mitigation will need to be carefully considered.
SCDC Response: Noted
ORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009 Natural England (Mrs Pat Respondent Name: Williams) [345] Submission Agent Respondent ID: 345 ID: 345 ID: SUBMISSION WE agree that the decrease in amount of development allocated in Felixstowe is more sustainable, but that the AONB needs to be protected from negative impacts.
SCDC Response: Noted
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009 Natural England (Mrs Pat Respondent Name: Williams) [345] Submission Agent Respondent ID: 345 ID: 345 ID: SUBMISSION We support the comments made in 2.4 re concerns about the proximity of the proposed higher level of housing in the area East of Ipswich to the Deben Estuary SPA. Detailed mitigation will need to be put in place following an Appropriate Assessment.
SCDC Response: Noted
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009 Natural England (Mrs Pat Respondent Name: Williams) [345] Submission Agent Respondent ID: 345 ID: 345 ID: SUBMISSION (Reg 25) Consultation on Suffolk Coastal Local Development Framework (LDF): Core Strategy: Appropriate Assessment
Thank you for consulting Natural England on the above. Your letter was received by this office on 28 September 2009.
We have the following comments to make on the Appropriate Assessment of the Core Strategy:
Section 5 Methods of assessing European site visitor increases from an increased human population 5.1 Introduction * 5.1.3 refers to sites not being in unfavourable condition according to Natural England's website. Sites can become unfavourable at any time and although some of the designated sites may currently be recorded as favourable, this does not mean there is no impact from visitor pressure. Although it may not be possible at this stage to attribute disturbance to specific SSSI units, Natural England is concerned that recreational disturbance to birds and habitats may represent a significant impact on designated sites on the Suffolk Coast. Trampling by people of fragile shingle vegetation, and disturbance to wintering and breeding birds by dogs are of particular concern. It is for this reason that Natural England and others devised and funded the study carried out by the Suffolk Coast & Heaths Unit on 'Disturbance to waterbirds wintering in the Stour-Orwell Estuaries SPA' (2007).
5.2 Existing condition assessments of European sites * 5.2.6 refers to disturbance to birds from human recreation not being a reason for unfavourable condition. We would repeat our comments of 27 July 2009 that Natural England does not monitor disturbance to birds on SSSIs; it is not a mandatory attribute as it is poorly understood and meaningful targets cannot be set. Human impacts may therefore not be included as a reason for unfavourability (see also comments above about the study Natural England funded).
5.3 Visitor surveys to predict additional visitors to European sites across the Suffolk Coast and Heaths AONB * The analysis of visitor numbers seems unnecessarily complicated and we are unsure of their mathematical validity. We appreciate that the actual numbers of people visiting the AONB is not known, however the calculations would be more meaningful if this figure was obtained. If there is to be a 9.1 % increase in housing in the area (Table 4) then it seems likely that there will be about a 9% increase in visitors to the AONB/European sites from the local area. We therefore suggest an increase of 5-10% to be more reasonable.
5.4 Impact on specific sites * 5.4.2 refers to studies in Dorset to investigate the impact of development on European sites there. These studies referred to Dorset Heathlands and Natural England advises that coastal sites cannot be treated in the same way as the coast holds a greater lure for the population. * 5.4.4 Natural England therefore advises that development sites more than 1km (for people walking) and 8km (for people driving) could have a cumulative impact on European sites.
Section 6 Assessment of each policy 6.2 Policy SP2 Housing numbers * 6.2.15 refers again to sites not being recorded as unfavourable as a result of visitor activity. Please see our comments above in 5.2.6. * 6.2.16 Natural England feel the comment 'This view is inconsistent with the organizations which employ the site managers.....' is not helpful and should be removed. * 6.2.26 again refers to the unfavourable condition of the saltmarsh being due to erosion by water rather than due to visitor disturbance or trampling. See our comments in 5.2.6 above. * 6.2.26 and 6.2.37 both mention the lack of car parking at Waldringfield. However, the car park at the pub in Waldringfield is a large one and popular with walkers along the estuary who finish their walk with a visit to the pub. * 6.2.32 and 6.2.34 state that the allocation of 2000 new dwellings at Martlesham could substantially increase visitor recreation activity on the foreshore of Deben Estuary SPA bringing in high levels of disturbance to what is currently little disturbed and a 'refuge' area for SPA-qualifying birds, and that it cannot be ascertained that there will be no adverse impact on the integrity of Deben Estuary SPA. * 6.2.35 Bearing in mind the above point and our comments for 5.4.2 and 5.4.4, Natural England advises that the appropriate assessment is not taking the precautionary approach recommended in the Habitat Regulations by saying that provided development is greater than 1km from a Natura 2000 site and that accessibility to the greenspace provision is adequate, it is unlikely that visitor recreation activity would substantially increase on the foreshore of Deben Estuary SPA at Martlesham. * 6.2.33 It would have been helpful if location of high tide bird roosts has been further investigated. * 6.2.41 please see comments above re '1km from a Natura 2000 site'. * 6.2.43 and 6.2.44 please see comments above re housing development being 1km and 8km from the Deben Estuary. * 6.2.46 Given our comments above re the 1km distance, Natural England cannot agree with this conclusion.
Section 7 Mitigation * Natural England fully support the recommendations in this section for improvements to accessibility of natural greenspace and the proposal of a new Country Park, but, as discussed above, we cannot agree with the statement in 7.2.4 and 7.2.5 re impacts from housing proposals being mitigated for by being sited more than 1km from the SPAs. * 7.2.12 Natural England would emphasise that the monitoring programme will need to be detailed and assurances provided that action would be taken if the monitoring proved there was an impact. Natural England advises that the monitoring should include a study of the disturbance to waterbirds wintering in the other Suffolk estuaries SPAs not included in the study already carried out for the Stour and Orwell Estuaries SPA.
Section 8 Conclusions of the Appropriate Assessment 8.6 Final conclusion * We disagree with the conclusion for the reasons in 6.2.35.
Section 9 Limitations to the assessment 9.1 The evidence base * 9.1.2 . Natural England agrees that the evidence base is poor and recommends detailed recreational disturbance studies like the one for the Stour-Orwell mentioned above for the other Suffolk estuaries, as part of the monitoring and mitigation package.
9.2 Further work needed * 9.2.3 We disagree that Natural England is the appropriate lead for further studies - however it is clearly Natural England's role to provide advice to the competent authority on the need for such studies, their scope and conclusions. * 9.2.6 It states in the Habs Regs in section 28 that 'The appropriate nature conservation body may make byelaws for the protection of a European site under section 20 of the National Parks and Access to the Countryside Act 1949 (c) (byelaws for protection of nature reserves). Although Natural England have the power to make byelaws, we disagree with this approach as it is our opinion that there are other measures that can be employed to reduce disturbance to estuarine birds, such as wardening and dogs allowed off leads in certain specified locations only. Partner organizations are working towards better understanding of the scale and issues surrounding recreational disturbance to birds on estuaries.
SCDC Response: Noted, 9 Comments from Natural England were considered and addressed by Cabinet in their meeting of 24 April 2010.
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES
Respondent Name: Nikki Ribbands [246] Submission Agent Respondent ID: 246 ID: 246 ID: SUBMISSION I support the recommendation in "Future Secondary School Provision" document in that a secondary school should be built on the BT Adastral Park site. No other site in Martlesham is of a suitable size without damaging wildlife area's or tree's protected by preservation orders. I also feel that building a secondary school at the Adastral Park site is a key element to creating a self contained and sustainable community.
SCDC Response: Noted
THE OVERALL STRATEGY Respondent Name: Nikki Ribbands [246] Submission Agent Respondent ID: 246 ID: 246 ID: SUBMISSION Whilst I object to the overall concept of building so many homes in Martlesham, from my perspective a development at the BT Adastral Park site is the least worst option
SCDC Response: Noted
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009 No Adastral New Town (NANT) Respondent Name: (S Denton) [449] Submission Agent Respondent ID: 449 ID: 449 ID: SUBMISSION Due to the length of the comments submitted, only the summaries are shown here. The full text has been attached to the comments and is available to view via http://suffolkcoastal.jdi-consult.net/ldf/
TRANSPORT SUMMARY (100 words) The Transport Assessment is based on old data and makes no reference to the Orwell bridge, BT roundabout (key pinch points) or Northern Bypass mentioned in IBC's LDF. Sustainable transport is a timid wish list with no real substance or vision - clearly driven by limited funding. There is no research on likely migration inwards of businesses, and the trip analysis is flawed as the onsite employment is based on guesses - therefore the sustainability claims do stand up to scrutiny. Its conclusions are framed in the negative - no reason to say the plan won't work, but can't confirm it will.
EDUCATION SUMMARY (89 words) The case for a full-sized secondary school at the Adastral site has not been demonstrated and may not be the most beneficial option when looking at the wider picture, taking into account Ipswich BC's housing development and schools in NE Ipswich. Removing 6th form provision from existing high schools to create 11-16 capacity will be strongly resisted and is unwarranted. How the siting of a secondary school on the Adastral site will impact on housing density, numbers and location is unknown, but could be more detrimental than current plans.
SCDC's consultation process is fundamentally flawed - its scope did not reflect strategic nature of what is proposed and the process did not communicate and involve the community effectively. NANT believes that the consultation process should be extended to allow the Council time to inform people about the proposals, engage the community in meaningful dialogue about the Council's vision and seek feedback in a fair and accessible manner.
SCDC have provided no credible justification for the proposed increase in IPA housing numbers from 1,050 to 2,000. The evidence that has been provided is contradictory, poorly argued and in some cases missing vital information. The decision to put all the allocation in a single site, and the choice of the area around Adastral Park, will be disastrous for the area. Local communities will be overwhelmed, a beautiful rural landscape will be urbanized, traffic congestion will increase and nearby sensitive environments will be seriously harmed. All these problems will be made far worse by doubling the number of houses.
SUSTAINABILITY SUMMARY (73 words) The evaluation method used in the Sustainability Appraisal is not fit for purpose. It contravenes the principle of rigour. The evidence base is inadequate. The reliability & validity of the document’s ‘sustainability’ argument and conclusions are seriously undermined therefore. A second and fully independent expert opinion is recommended. Another Appraisal should be undertaken based on a valid and reliable methodology, with appropriate specialists included in the team well-versed in relevant up-to-date theory and methodology.
APPROPRIATE ASSESSMENT SUMMARY (98 words) The Appropriate Assessment recognises serious limitations to the methods used to predict impacts of the proposed housing development. The need for further fully independent and rigorous evidence-based studies, done before any housing development proceeds, is imperative and is supported by a study of heathland in Dorset (Liley et al. 2008). The conclusions drawn contradict the evidence that the integrity of the Deben Estuary would not be adversely affected by extra visitors. Insufficient weight has been given to the concerns of local site managers. Mitigation measures proposed will not prevent damage to fragile wildlife habitats and their endangered species.
SCDC Response: 1, 4, 5, 7, 8, 9, 10, 11, 12, 13, 16, 17, 18, 19, 20
APPENDIX 5 - REVISED SETTLEMENT HIERARCHY Orford & Gedgrave Parish Council (Mrs Alison Keeble) Respondent Name: [191] Submission Agent Respondent ID: 191 ID: 191 ID: SUBMISSION Orford & Gedgrave Council considered the document at the P.C meeting on October 21st 2009 It was discussed that Orford is capable of accommodating more starter homes, providing an up to date needs survey is carried out.
SCDC Response: Noted
THE MARKET TOWNS Ortona Ltd. (C/O Mr Andy Respondent Name: Scales) [118] Submission Agent Respondent ID: 118 ID: 118 ID: Mr Andy Scales SUBMISSION Welcome the emphasis on the take up of brownfield sites in the 'built up area' designation in all market towns, especially Saxmundham. This approach recognises the urban potential of unidentified windfall / brownfield sites in the built up area of towns. The approach should be used to prioritise site that will enhance the character and appearance of the town centre including those sites where mitigation can be provided to ensure no net increase in flood risk, regardless of their flood zone designation.
SCDC Response: Noted
KEY SERVICE CENTRES Otley Parish Council (Mr R J Respondent Name: Treloar) [46] Submission Agent Respondent ID: 46 ID: 46 ID: SUBMISSION We have read with interest the proposed changes to housing distribution outlined in your consultation document. Whilst having no specific argument with the proposals we are naturally concerned at the anticipated increase in the development of greenfield sites around the market towns and key service centres. There appears to be an element of short termism as far as Felixstowe is concerned. The current recession will have little long term impact on the growth of the port and it is infinitely sensible to develop those areas which in the longer run will sustain employment within the County, whilst having regard to the surrounding environment. The transport infrastructure provided by the A14 and A12 easily outstrips that serving the market towns and villages and the problems experienced on the B1078 and B1079 will not go away until planning legislation is properly imposed and sensibly maintained. Experience proves that infrastructure issues in the smaller settlements are often not addressed when developments are considered and undertaken. The comments contained in our original response to the plan remain unchanged and we see the modest development within the Village being undertaken on the Hubbards site. This was the feeling overwhelmingly expressed in the recent parish plan.
SCDC Response: Noted
IPSWICH POLICY AREA
Respondent Name: P Rains and H Hook [477] Submission Agent Respondent ID: 477 ID: 477 ID: SUBMISSION We are writing to object to the proposed revisions to the above plan where it embraces the Adastral park development in and around Martlesham Heath.
We do not consider that this development is justified because: a. There is no current local demand for the additional housing and infrastructure. b. Neither central government requirements for developments of this kind not BT's wish to put the land it owns in this area to better commercial use are in themselves sufficient reasons for allowing such a develoment in this sensitive location. c. If the development is permitted, it and the inevitable development creep that will follow in future, will irreversibly destroy the unique chaarcter of the upper Deben estuary. Woodbridge will become a suburb of Ipswich.
SCDC Response: 3, 16, 17, 18
IPSWICH POLICY AREA
Respondent Name: P White [412] Submission Agent Respondent ID: 412 ID: 412 ID: SUBMISSION I wish to add my family's objections to the plans for the new town at Adastral Park. This will have a severe adverse effect on what remains a pleasant rural area, in particular the nearby SSSI's, and the additional traffic will add to the existing difficulties on the A12 at this location as well as at Seven Hills and the Orwell Bridge. A lights-controlled roundabout will do nothing to ease the flow of traffic at rush hours, and there will also be problems at Waldringfield, which will not be accessible from the new development other than by car.
SCDC Response: 12, 13, 17, 19
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES Parburch Medical Developments Respondent Name: Ltd (Mr Robert Parker) [65] Submission Agent Respondent ID: 65 ID: 65 ID: SUBMISSION Dear Sirs,
I am not being a NIMBY but I think the whole process is flawed and figures quoted are projections based on past and present facts and figures which we all know do not always live up to what may happen in the future. To qualify this I remember the time as Chair of Kirton & Falkenham Parish council at the time that the last master plan was out for the Hemley, Brightwell,Newbourn, Bucklesham & Kirton development using similar criteria to justify such expansion, the figures did not materialize and the scheme was dropped. This may have been partly due to the lack of developers willing to put up the cash to start such a scheme and this may happen again as at the end of the day no scheme will go ahead unless there is profit at the end of it. I am also very surprised that if this scheme was so good some 20 years ago why does it not stack up today ?
In this set of current proposals I feel you need to look for a much longer term solution and look at the wider picture. If you insist in expanding population based on the fortunes of Felixstowe dock then if the dock doesn't expand in terms of labour all you will achieve is a bigger commuter traffic jam on the A14 as the additional population will commute to Ipswich. It is worth bearing in mind that all companies are operating with fewer employees per £1 of turnover in return for grater investment in machinery, technology and general consolidation within a given market segment.
For the larger picture I feel you should considering a tunnel linking Harwich to Felixstowe. The amount of brown field sites for development together with the ready pool of labour this would create an expanding region at the mouth of the River Orwell. As Hutchinson Ports owns all the dock infrastructure on both locations it makes sense to link both these sites as one and develop the potential accordingly.
I sit on The Chamber transport group and we have had many discussions on the question of congestion and I feel that any more large development at the end of the A14 means that traffic can only go one way and that is back along the A14 so any development on this side of the river Orwell should be in and around Ipswich as traffic can travel to any point 360 degrees from around the area. In Ipswich we probably have the largest amount of empty housing and housing in building developments at any time since then end of the last war and it will take a long time to fill them. Any further pressure on the A14 would be disastrous and act as a funnel as it doesn't matter what you do to improve traffic at either end you still have two lanes over the bridge but by constructing a tunnel linking Felixstowe and Harwich you have links in from both thenorth and south relieving the A14 and the bridge. This would save funding for proposed road improvements as the traffic flow would decrease.
I know from you own perspective this would mean making sacrifices as it would mean working with Essex and perhaps pooling resources, aspirations and a bit of power, but development of this scale needs looking at with a wider picture, not looking just inside your own authority, as this can be very selfish and whilst you solve your own problems and satisfy the demands from Central Government it can create problems for our neighbors and very often provides short term solutions ending in long term problems.
Yours sincerely
Robert Parker
SCDC Response: 22, 24, 26
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES. Parham Parish Council (Mr Respondent Name: Raymond Catchpole) [39] Submission Agent Respondent ID: 39 ID: 39 ID: SUBMISSION Thank you for your circular letter of 13 July. It has been placed before members of this parish council and the advance warning is noted. The matter has returned to our future agendas. I have been asked to register the council's ongoing concerns, particularly with reference to developments proposed for Framlingham and the apparent lack of infra-structure in dealing with schools, health, transport, flood water and increased traffic through Parham. I hope you will continue to keep us closely advised of all stages in this consultation process.
SCDC Response: Noted
BASE REQUIREMENTS
Respondent Name: Patricia Shipley [498] Submission Agent Respondent ID: 498 ID: 498 ID: SUBMISSION A) These proposed changes are not justified
Summary of comments: The theoretical argument put forward for the link between the development proposed & matching infrastructure is circular. There is also a dearth of necessary figures and statistics needed in support of the proposed changes. What limited data are available are insufficient and need updating.
Comment 1.
(See Sections 7.01, 7.02, 7.03).
I cannot see the justification for doubling the housing allocation. The Council's argument underpinning the 'updated preferred option' is unconvincing. I find the documentation to be confused & confusing, and at times logically incoherent. It is understood that the reason for doubling numbers at the East of Ipswich Martlesham site is to obtain funds for infrastructure to support the development. The theoretical argument put forward for the link between the development proposed & matching infrastructure is circular, however. Relevant supporting infrastructure needs to be in place in good time, should the plan be approved. A single site development on this scale and in this location will require large infrastructure investment. From what reliable sources will that funding be found? To double the housing numbers planned is to at least double the degree of support required. It is implied that to a great extent this support will be heavily dependent on substantial contributions from the developer/s. Developers may go out of business, or the business decline significantly during the critical period, especially in a time of prolonged recession. Public finding on this scale will also be a problem. To assume that funding will be made available in the right amounts at the right time to meet this need would be unrealistic. A much more certain funding plan is needed. A dispersed housing strategy on several sites would require far less funding than this single site in this location and by that token is far less uncertain.
Comment 2.
(See Section 3.03, 6.03,)
The evidence base for the general argument is also worryingly inadequate. There is a dearth of necessary figures and statistics needed in support. What limited data are available are insufficient and need updating. Traffic figures, for example, will need to be more up-to-date, more so for a development of this size, which will, as the Council acknowledges, inevitably lead to congestion and pollution in the area. The Traffic Appraisal Study Sept 2009 presumably used as a base for the proposal has a number of serious restrictions admitted in the study. It omits an appraisal of many adverse impacts, for example. Reliable statistics are needed on the specific accident risks and potential adverse health effects of the proposal, including risks to the network of local narrow country roads which are regularly used by slow and cumbersome farm vehicles, and increasingly by other vehicles, cyclists and walkers. The roads into the 'honeypot' village of Waldringfield, for example are congested at weekends and often dangerous, especially at the acute right angle bend on entry to the village. There is no street lighting and hardly any paving. Local roads are single track in many places.
Future car usage is grossly under-estimated. To double the houses is to double the risks to the safety and well-being of the new residents and of local people. How then would their claimed quality of life be improved, rather than impaired? (Section 3.03). Or 'carbon control' objectives be met?
*General Comment/Objection
B) The updated proposal does not better meet the broad strategy for development in the district.
Summary of Comments: a dispersed housing strategy has much to recommend it, particularly where it includes benefits to rural areas. Logically also, what is recommended for Felixstowe and the Trimleys should apply to Martlesham.
Comment 1
( Section 5.08, 5.17, 5.19, 6.03)
A strategy of dispersed housing among several sites which would share risks, costs, and benefits would better meet the need than the proposed large single-site plan at Martlesham. Supporting documents for the Council's plan reinforce this conclusion. If housing is dispersed there would be less need for the scale of infrastructure noted in comment 1 in A) above. It is understood that there is actually a specified need for only 1050 dwellings. So, there is a serious risk of over-development with all its attendant costs to the environment etc.
Comment 2
(See Section 5.08, 5.09, 6.0)
I do not understand what is meant in this context by the vague jargon 'a stand alone community' and a 'good sense of place' (section 6.0). Smaller settlements and villages should be included in a dispersal strategy because of their need for regeneration and rejuvenation, and, also importantly, because mature communities can offer an already settled and cohesive community life to new residents; there is a better chance of new residents being integrated comparatively quickly. There are also other benefits. (See Taylor Review 'Rural Economy & Affordable Housing).
Comment 3
(See section 5.19)
I haven't found in the documents a comprehensive comparison of the broad housing placement strategies. Also, as a matter of logical consistency the dispersal strategy recommended for Felixstowe and the Trimleys should therefore be recommended for the area East of Ipswich at Martlesham. A consultant's survey was done for Felixstowe, but where is the comparable survey for Martlesham?
Comment 4
With the doubled numbers there is a strong risk of over-development, & this at a time where the carbon costs of over- development are an increasing and major concern.
Comment 5
(Section 4.02, 5.12, 5.17, 6.0, 7.01)
I am not convinced that sufficient employment opportunities in the Ipswich/Martlesham area exist to support this plan, nor will be made available by this plan. An alternative view is that residents of this new development will be different from those employed in the area. Home-based trends also suggest that future employees at Adastral Park will not live there or near there. Nor am I convinced that insufficient other job prospects exist, nor could be helped to exist with the encouragement of new SMEs, in areas covered by a dispersed strategy. There are a number of local sites which would lend themselves to the development of light industry, and low carbon jobs in 'renewables', especially at this time of urgent need to combat global warming. At the same time, all agricultural land has to be preserved to tackle the issue of growing food shortage. Why is building proposed for existing agricultural land? Why is the potential 'disbenefit from damage to the landscape, loss of agricultural land and the like from the increased size of this allocation ...limited'? (section 6) It would constitute severe damage to these aspects if numbers were half of that proposed.
If you are objecting to any area of the documents, please indicate what changes you would like made (please continue on a separate sheet if necessary)
Summary of Comments: A reliable survey of the Martlesham area is a pre-requisite before a final decision is made about housing location/s and their numbers.
Comment 1
I welcome a robust, full and independent survey be conducted of the Martlesham area before the decision is finalised about housing location/s and housing numbers per location. This survey needs to more carefully consider than heretofor the employment implications and the need to protect the natural environment and any potential impact on local wildlife which is special to this area (See 3.02, para 4 '...the RSS also broadly recognises the quality of much of the Suffolk Coastal countryside, its soils and the wildlife it supports are of national and in some cases international importance'. )
Comment 2
The survey should include full appraisal of a strategy of housing dispersed among several sites which would share risks, costs & benefits to confirm it would better meet the need than the proposed large single-site plan at Martlesham.
SCDC Response: 4, 7, 15, 16, 17, 18, 19, 20
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Patricia Shipley [498] Submission Agent Respondent ID: 498 ID: 498 ID: SUBMISSION The method used in the Sustainability Appraisal for the evaluation of its specified variables and objectives is not fit for purpose. It contravenes the stipulated principle of required methodological rigour. The reliability and validity of the conclusions are seriously undermined therefore by limitations to the method used to underpin the 'sustainability' argument. The evidence base is inadequate. The facts and estimates made available are seriously limited. We are left instead with largely a collection of value judgements. Worryingly, the method's limitations are not addressed in the document.
Comment 1 (See Section 1 'Introduction', & Appendix 1.0. Also see 'Non-Technical Summary', section 1.1-1.4, & 'Method of Appraisal' section 3.0 in 'Sustainable Appraisal of the Suffolk Coastal LDF Core Strategy - Preferred Options', Dec. 2008.)
The claim made that the LDF proposal of 2000 dwellings on a single Greenfield site in a rural area close to the Deben river, which harbours protected sites of special natural interest, is chosen and preferred because it is 'the most sustainable and to offer the most potential benefits...' is wholly unconvincing because of the flawed methodology used in the Sustainability Appraisal to undergird the claim. [quoted from cross reference to 'Updated Preferred Option 7/09 Housing Distribution. Consultation - Frequently Asked Questions' para 6]
The reason given for why so many houses is proposed at Martlesham (east of the A12) and why this has changed to 2000 dwellings is that 'The land to the east of the A12 is considered, when taking all the relevant factors into consideration to be the most sustainable and to offer the most potential benefits...' But the credibility of SCDC's LDF plan - particularly in relation to SP20, the area East of Ipswich at Adastral Park, is damaged to the extent that it depends on such a flawed subjective appraisal method, dependent as it is on a subjective code ( +,0,- ) which appears to be arbitrary. Too much depends on the judgments of the raters which may in reality be little more than value judgments. Were inter-rater reliability tests done between raters to see if agreement was high? Unfortunately, therefore, the evaluations (+,0,-) of each of the Appraisal's objectives given in Appx 1 of the report (Sustainability Appraisal Objective: Impact: Comments / Mitigation) have to be seen as null & void. Yet, the reply to Ques. 8 in the Council's document 'Updated Preferred Option 7/09 Housing Distribution Consultation - Frequently Asked Questions' states with reference to the Sustainability Appraisal that it provided ' ...an objective assessment...'
How exactly the instruction to evaluators was finally achieved that the " overall impact should be considered"- given this evaluation method - is not made at all clear. Neither does it follow from the method that "the objectives have a high level of sustainability ingrained them". With this particular method a different panel of evaluators may well arrive at a quite different set of conclusions & recommendations.
Another unfortunate consequence of the method is that it may undermine the public's trust in the process if it is seen to be misleading, obfuscating and possibly partisan. An honest declaration of the true nature of the evaluation done and the inevitable difficulties, choices, dilemmas and conflicts involved in the project may lead to a greater feeling of confidence in the Council's conclusions. Any claim to objectivity here could be spurious, however. To convey an air of objectivity in such a non-transparent manner may be construed as disingenuous, adding to suspicions the public may have about whether ambiguities are being exploited to 'railroad' through an unpopular decision.
Comment 2 (Section 1.0, 1.1, 1.2)
A sustainability appraisal requires balancing of the three main sets of inter-related sustainability variables of 'Environment - Social - Economic' . There is also an ethical duty to protect resources for use by future generations. It is aimed to show that key resources are sustained and not left depleted by a proposed development, and that this includes resources in the natural environment such as wildlife and their habitat. But there is a clear imbalance in this particular study. What is not clear is why the economic objectives carry more favourable sustainability evaluations than the many important potential environmental risks and costs (risks recognised in the document), especially the need for wildlife conservation. By what criteria they have been evaluated, can be seriously questioned on the basis of this method.
Central government's checklist 1a on p3 in its document 'Creating Local Development Frameworks. A Comparison Guide to PPS 12' in 'Creating Sustainable Communities' (2004) from the Office of the Deputy Prime Minister, identifies sustainability appraisal as 'an integral part' of the process of LDF production. It stipulates the requirement for 'soundness' and comprehensive evidence underpinning documentation, and for the 'long term social, environmental, economic and resource impacts of development' to be considered.
This particular sustainability appraisal has infringed these principles and requirements and has patently failed to achieve its purpose, despite its declared aim in para 1.1 being 'to promote sustainable development by ensuring environmental, social, and economic factors are considered during plan preparation'. Para 1.1 goes on to note that the 'European Directive 2001/42/EC requires Strategic Environmental Assessment to be undertaken to assess the effects of plans and programmes specifically on the environment'. I maintain this directive has not been adequately followed in this particular case.
Comment 3 (Section 2.2, 2.4)
There are contradictions & inconsistencies in this document. Note the assertion in section 2.2 is contradicted in 2.4.
Section 2.2 The sustainability of the new policy is higher than the previous version. The distribution of housing has been altered with a greater proportion of the District's required number of dwellings to be built in the Ipswich Policy area, and a lower allocation in Felixstowe and the Trimleys. Concentrating development in the IPA is considered a more sustainable strategy for a number of reasons:
Section 2.4 The new policy is marginally less sustainable due to additions of land abutting Adastral Park being identified for development. This is greenfield land that includes current archaeological and biodiversity sites and a mineral working as identified in the site specific appraisal.)
(Also, Section Appendix 1.0. Assessment Summaries for SP20, area East of Ipswich, & SP21 Felixstowe)
Note the major issue of whether house building should best be located on a single site versus building dispersed across a number of sites (this is without a full and reasoned comparison of broad placement strategies included in the Appraisal). To be logically consistent, what is recommended for Felixstowe & the Trimleys with the spreading of costs & benefits across different sites must also apply to the area east of Ipswich (SP20), in the absence, as here, of a justifying and rational set of reasons for this clear anomaly.
Comment 4 (Section 2.2 iii, Appx 1.0)
Some important variables have been omitted in the evaluations, such as specific health variables affected by congestion and pollution, and mental health & stress factors (See UK's Health & Safety Act for mental health definition). Other environmental risks are under-estimated such as the development's potential contribution to flooding in an area close to the Deben river, especially with the increasing challenge posed by climate change to such an environment. Potential car use is grossly under-estimated and the estimates offered are far too low and over-optimistic, and are unsubstantiated. We lack robust evidence in this Appraisal, the necessary up-to-date reliable & comprehensive facts & figures, to guide us.
The potential increase in accident risks from the development to users of the complex network of narrow surrounding roads, which are regularly used by heavy, slow farm vehicles and increasingly other traffic, including cyclists and walkers is not addressed. The doubling of housing can only double many of these risks, if not all.
Comment 5 (Section 2.2, para.ii. Appx 1.0)
Other variables are over-estimated, such as the unconvincing claim to be able to generate a 'stand-alone', 'self-sustaining community', or 'sustainable settlement' on site. This unsubstantiated claim is contrary to evidence from the behavioural sciences. The necessary culture to meet the social needs of this kind of community is hard won. Yet, resilient communities are increasingly needed in a world having to come rapidly to terms with climate change, and growing fuel and food shortages.
Comment 6 (Section 1.3, 2.10, 2.11)
The 2000 house plan will also have a dramatic impact on Martlesham and surrounding villages. There is no doubt these villages will be overwhelmed by the impact, the quality of life of their residents adversely affected, and the special character of the rural area destroyed. This is not a sustainable plan as far as these people are concerned. Given this, how can it be concluded, as it is in Council's 'The Preferred Option Report Dec 2008: Housing Distribution East of Ipswich' para 5.17, as " having the least impact on other individual communities"? I fail to see it.
The Council's assertion in 6.03 of 'Core Strategy Housing Distribution Updated Preferred Option 7/09' that "The evidence suggests that the benefits do indeed outweigh the disbenefits", is breathtaking in its lack of rigour. Yet, the consequences, should it be the wrong choice, will be far-reaching and long-lasting. Historically, for example, development from economic growth has been achieved at the expense of the environment. It has also brought many social problems in its wake. Prioritising, therefore is inevitable. If the priorities are not transparent then they must be hidden, intentionally or not.
[See here sections on 'Sustainable development' (p61-65) & 'Over-development' (p65-67) in A.Giddens, 2009 The Politics of Climate Change. Polity Press, Cambridge. Lord Giddens was previously government adviser to Blair's cabinet & Director of the London School of Economics.]
Comment 7 (Appx 1.0)
Importantly, left unaddressed in this Appraisal are the clear social and economic merits & benefits for existing & alternative uses of the proposed area SP20, East of Ipswich (such as returning the land fully to heathland after mineral extraction, the development of 'eco-farming' because of growing food shortage with the growing challenge from climate change threats, etc.).
Comment 8 (Section 2.4)
The proposed 'mitigation' proposals for the inevitable damage to the natural environment are thin and unpersuasive. A dispersed housing strategy is better able to mitigate these costs and risks. The Appraisal acknowledges for example, that in the area east of Ipswich at Martlesham (SP20) traffic will increase considerably " in an area that is already congested" but it is unclear how far this problem can be adequately mitigated in the proposal. We lack the appropriate quantification and costings in the study. Overall, the (theoretical) mitigation offered for the over-whelming of local communities by this development on this scale is very weak and unconvincing, and the arguments on which it is based are uncosted and under- developed in other ways.
If you are objecting to any area of the documents, please indicate what changes you would like made (please continue on a separate sheet if necessary)
Comment on Changes :
There should be a second fully independent expert opinion sought, and another Sustainability Appraisal undertaken based on a valid and reliable methodology, with appropriate specialists included in the team who are well-versed in relevant up-to-date theory & methods.
SCDC Response: 8, 9
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Paul and Paula Atkinson [506] Submission Agent Respondent ID: 506 ID: 506 ID: SUBMISSION We, the undersigned, object to the proposed Adestral New Town for the following reasons:
1 The number of dwellings will overwhelm the existing community and is too many to be absorbed successfully.
2 The infrastructure, whilst adequate at present, will certainly not be adequate for 2,100 homes.
3 1,000 homes was overkill - to raise it to 2,100 is totally without regard to the area.
4 This is an area of outstanding natural beauty and also scientific interest, particularly the Heath and the area close to the River Deben.
SCDC Response: 16, 17, 20
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Paul Beaumont [330] Submission Agent Respondent ID: 330 ID: 330 ID: SUBMISSION Re 6.01 2). "2. Too much reliance is placed on the Port of Felixstowe for jobs"
Similarly BT at Adastral Park can no longer be considered as providing economic activity in the locality to support net new jobs.
SCDC Response: 7
HOUSING DISTRIBUTION EAST OF IPSWICH
Respondent Name: Paul Beaumont [330] Submission Agent Respondent ID: 330 ID: 330 ID: SUBMISSION Re 5.17.
Environmental sensitivity of the advocated area fails to be acknowledged and mitigation outlined.
SCDC Response: 17
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES. Respondent Name: Paul Beaumont [330] Submission Agent Respondent ID: 330 ID: 330 ID: SUBMISSION Re 5.10.
Captures key considerations. However, documents do not provide compelling evidence that have been factored into consideration and the proposal is compliant to these guiding principals.
SCDC Response: Noted
4 SO WHAT IS THIS REVISED HOUSING DISTRIBUTION STRATEGY CONSULTATION ALL ABOUT?
Respondent Name: Paul Beaumont [330] Submission Agent Respondent ID: 330 ID: 330 ID: SUBMISSION Re 4.01.
Object to constrained consultation on housing distribution given fallacious assertion on agreement [see prior objection] and see a need to critically appraise impact of proposal generally with fair opportunity for members of the impacted communities to discuss areas of concern with District Council officials. The opportunities for consultation have been wholly inadequate.
SCDC Response: 1
3 BACKGROUND
Respondent Name: Paul Beaumont [330] Submission Agent Respondent ID: 330 ID: 330 ID: SUBMISSION Re 3.02 4). "... the wider economic role that ... and BT research and development at Martlesham Heath play both nationally ..."
BT has systematically released UK employees at its Adastral Park R&D facility and has outsourced its activities offshore. This would appear to contradict the need to augment housing in locality.
SCDC Response: 7
2 THE CONSULTATION IN BRIEF
Respondent Name: Paul Beaumont [330] Submission Agent Respondent ID: 330 ID: 330 ID: SUBMISSION Re 2.05 A substantial increase in the amount of new housing within the Ipswich Policy Area2 east of the A12 at Martlesham
Centring increase on a geographic area is inequitable. It disproportionately impacts District Council citizens in an area by having an adverse impact on local environment, infrastructure and their enjoyment. Furthermore offseting measures proposed are limited or absent in being commensurate with scale.
SCDC Response: 16, 17
2 THE CONSULTATION IN BRIEF
Respondent Name: Paul Beaumont [330] Submission Agent Respondent ID: 330 ID: 330 ID: SUBMISSION Re 2.01. "achieved a measure of support" ambiguous.
District Council should have provided objective and statistically significant metrics to justify assertion.
In absence of this the District Council has failed to do all that is reasonably practicable to evidence this and thereby constraining the scope of the current consultation shall be considered fallacious.
SCDC Response: 1
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Peter Darnell [261] Submission Agent Respondent ID: 261 ID: 261 ID: SUBMISSION The community is not currently self-sustainable in terms of employment given the number of empty industrial units on the business park and the greatly reduced number of locals now employed at BT (5%). Increasing the size of Martlesham Heath by a factor of 3 will considerably increase the traffic levels, congestion, noise and pollution as people commute from the development. The effect on MH residents will be profound and ruin the semi-rural nature of the village. Peak time traffic levels to and from Ipswich will increase significantly on an already overloaded A1214.
SCDC Response: 7, 17, 19
IPSWICH POLICY AREA
Respondent Name: Peter Maddison [503] Submission Agent Respondent ID: 503 ID: 503 ID: SUBMISSION SUMMARY
I wish to object to the proposed building of 2000 houses on the BT land at Martlesham. The construction of so many houses in this one area will have a hugely detrimental effect on the nearby communities, the roads network to the east and around Ipswich, and the internationally and nationally recognised wildlife habitats, the closest of which is 1km from the proposed development.
OBJECTIONS
The nearness of the village of Waldringfield with its small sandy beach, opportunities for water borne activities and riverside walks will inevitably be a major draw for people living in the BT/SCDC Adastral Park scheme. Congestion in the single lane road to the riverside is already considerable and there is no public parking in the village. The Housing Distribution - Updated Preferred Option 7/09 shows confusion with claims that there is public parking (6.2.26) and there isn't public parking (6.2.37). For the doc. to state (6.2.37) 'Given this lack of available parking, it is possible to ascertain that the integrity of the Deben Estuary at Waldringfield will not be affected by the housing allocations at Martlesham' is an extraordinary assumption. People will use the pub car park and perhaps, perhaps not use the pub. Roadside verges are likely to be used for parking.
The River Deben is a sensitive environment. Martlesham Creek is recognised as a Ramsar Site and the River is a Special Protection Area. Extensive winter feeding grounds and high tide roosts for wading birds are found throughout the immediate hinterland of Martlesham Creek and the saltings between Martlesham Creek and Waldringfield and further south towards Hemley and Kirton. The river wall provides a public footpath around Martlesham Creek, in the Waldringfield area, and from Hemley south towards Felixstowe Ferry. Breaches in the river wall between Martlesham Creek and Waldringfield have resulted in a remote and undisturbed section of the Deben, which is an extremely valuable feeding ground and roost for water birds and other species associated with this type of environment. Further access to the Deben would be disastrous for this precious and most sensitive area. (This is recognised in Appropriate Assessment 6.2.31 6.2.32 6.2.33.)
Some walkers now ignore signs informing them of the impassable route and divert, without success, onto the saltings causing wildlife disturbance. A growing trend has been the increase in off road cyclists who illegally use the river wall and the edge of the Saltings, aiding the destruction of the wall, saltings and the associated plant communities. Unwitting disturbance from the proposed new community at Martlesham will encourage destruction of this special area.
I would strongly agree with 6.2.34 which states 'It therefore cannot be ascertained that an allocation of 2000 new dwellings at Martlesham will have no adverse affect upon the integrity of the Deben estuary SPA at Martlesham....'
However, 6.2.35 contradicts this by concluding, without evidence, 'Provided that development is greater than 1km from a Natura 2000 site and that accessibility to the greenspace provision is adequate, it is unlikely that visitor recreation activity would substantially increase on the foreshore of Deben Estuary SPA at Martlesham'. No explanation of the vague term 'greenspace' is given or how this 'will prevent adverse affect upon the Deben estuary.....' (6.2.34 above).
2000 houses will generate a considerable increase in vehicles using the surrounding roads. The higher level of use of the A12 which at times is extremely busy will encourage drivers to use the narrow back road from the Newbourne/Waldringfield cross road through to the old Martlesham village as a rat-run. This road is narrow, in part single lane and is unsuitable for through traffic.
SCDC Response: 9, 17, 18, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Prue Denton [507] Submission Agent Respondent ID: 507 ID: 507 ID: SUBMISSION Dear Sir/Madam Housing Distribution - Updated Preferred Option 7/09 I am writing to register my comments and objections in response to the consultation on the above document which closes today. (A 100 word summary is at the bottom of this letter) My grounds for objection are:- 1) The scale of the proposal is out of keeping with its location next to a rural area and very close to an AONB and protected sites 2) The implied housing density (45 per hectare) is far too high and will force a building form which is entirely out of keeping with all of its surroundings other than the BT buildings 3) Contrary to previously stated policy that new developments should not overwhelm existing settlements, this is what 2000 houses on that site will do 4) By agreeing to 2000 houses at this stage it will open the Council to pressure from BT to increase the number to 3500 as per BT's submission to the EERA call for developer proposals in their study up to 2031. 5) The Transport study is flawed. It contains no firm conclusion that the proposals it contains will work nor does it mention the impact of the planned growth on the Orwell Bridge, and does not cross refer to the LDF prepared by IBC council which calls for a northern bypass. 6) To position this as a very focussed consultation on merely a reallocation of numbers is unreasonable as doubling the allocation will have a much bigger impact on this area than the original 1050. 7) The consultation process is defective and has failed. The option of 2000 houses on the Adastral site was not one of the previous options put forward by the council. It has only arisen as result of reaction to pressure to reduce the proposed allocation for Felixstowe/Trimley. Had the figure of 2000 been quoted in the previous round then there would have been much more opposition to it, and the Council might have agreed to look at other options to meet the criticism voiced by residents in both the Felixstowe and Martlesham areas, and hence the current proposal would not have arisen. 8) The consultation process has been badly publicised and is unnecessarily complex. The arbitrary 100 word summary requirement makes it virtually impossible to produce a summarised objection which does not look like a NIMBY objection as reasoned argument cannot be put forward in the space of 4 text messages 9) It is clear that the decision making is being skewed by the site owners and the lure of short term S106 funding. The long term strategy for the whole of the Suffolk Coastal District should not be determined in this way 10) There is no study to validate that employers and other organisations will be drawn to this site as suggested by BT and apparently assumed by the Council. If it does not materialise then this would be the least sustainable option as it is furthest from other employment centres of the sites originally looked at. 11) There should be a full re-consultation based on real choice and which is not presented in a skewed fashion Yours faithfully Prue Denton
SCDC Response: 1, 7, 10, 16, 17, 18, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: R. Holroyd [297] Submission Agent Respondent ID: 297 ID: 297 ID: SUBMISSION have you really considered the problems that can arise from going ahead with this development?
ROADS: 2000 houses will put between 3000-5000 more cars onto a road system barely adequate for the present volume of traffic.
MEDICAL: Ipswich Hospital is already under pressure.
POLICE, FIRE & AMBULANCE SERVICES: These are probably already operating to their limits.
EDUCATION Playgroups, Infant and Junior Schools, Senior Schools will all need expansion.
GAS< WATER AND ELECTRICITY: There is no doubt whatsoever that sometime in the not too distant future water supplies will present a serious problem.
REFUSE COLLECTION & DISPOSAL: Only you will know of the existance of any problems here but I doubt if Foxhall will have sufficient facilities.
SEWAGE: Again as above. Are the present facilities sufficient to deal with an increase of this magnitude?
ENVIRONMENT: Farmland:- The loss of good farmland is to be deplored. Enough was lost with the Grange Farm development. To rely on the rest of the world to feed us in an emergency would be foolish and even suicidal! Car parking:- Woodbridge, for example, does not have parking facilities sufficient for its summer visitor needs. Even in the winter the Council Offices Car Park is needed on a Saturday. Therefore more land will have to be lost to car parking. Pollution:- More cars produce more atmospheric pollution with carbon monoxide emissions.
And so it goes on.
Of course the building of more houses on greenfield sites is in line with government policy. Such building will increase Council Tax Revenue and enhance the power of Suffolk Coastal D.C. So I would suggest that no matter how many objections are raised the project will still go ahead.
After all, is this not the modern concept of democracy?
SCDC Response: 15, 17, 19, 20
STEP 2 INDIVIDUAL STRATEGIES AND POLICIES PRODUCED FOR THE MAJOR CENTRES AND TOWNS, TOGETHER WITH A MORE GENERAL APPROACH TO DEVELOPMENT AT KEY AND LOCAL SERVICE CENTRES.
Respondent Name: Rachael Snelham [361] Submission Agent Respondent ID: 361 ID: 361 ID: SUBMISSION Roads here cannot support new growth of traffic. Disturbance resulting in road changes, increased noise and pollution would be unnacceptable, the Orwell bridge cannot cope with more traffic.
New housing changes the area into an urban environment neighbouring and encroaching on an area of natural beauty. Martlesham Heath's character would be destroyed.
Sewerage, water and power already has problems in the area more houses will make the system ineffectual.
Jobs at BT are still declining, with reported losses and the axing of graduate recruitment programme - no new jobs here - actually less.
I strongly object to this developement.
SCDC Response: 7, 12, 17, 18, 20
CORE STRATEGY SUSTAINABILITY APPRAISAL SEPTEMBER 2009
Respondent Name: Rebecca Patten [241] Submission Agent Respondent ID: 241 ID: 241 ID: SUBMISSION The Martlesham Heath area cannot sustain this type of development without a deteriaration in the quality of life for existing residents. Crime will increase, the strain on our local GP's will increase, traffic and pollution will increase. Initial funding sought from the developers to offset these issues will not be for an indefinite period. The houses will be built and the people of Martlesham and Waldrigfield will be left to suffer the social issues. Only the pockets of BT stand to benefit, we don't.
SCDC Response: 18, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Rev. & Mrs N.J Platten [479] Submission Agent Respondent ID: 479 ID: 479 ID: SUBMISSION My wife and I object strongly to the council's and BT's plans to build over 2000 (3400) new homes in the area, for the following reasons. 1) We live in the area with the lowest rainfall in the U.K. This proposal could make the water supply even worse in times of drought. 2) It would be criminal to allow B.T. to build on green field sites. The world food supply is deteriorating. As a nation we could be making it more difficult to feed ourselves in the future. 3) The traffic situation would become more congested. It's difficult for residents of Martlesham to get out on the A12. The A14 is frequently congested and Main Road through Kesgrave is a real problem. 4) This would entirely change the nature of the area into an urban one, instead of a lovely village. It would be disastrous.
SCDC Response: 15, 16, 17, 18, 19, 20
KEY SERVICE CENTRES
Respondent Name: Reverend John Eldridge [42] Submission Agent Respondent ID: 42 ID: 42 ID: SUBMISSION Dear Sir/Madam,
While I understand the need to place much of the additional housing in the major centres of population, I would like to see further development at Wickham Market.
There are excellent facilities, shops and school, good communication links and easy access to A12. It seems that many of the local towns have been developed over the past twenty years but Wickham Market has been left somewhat as a backwater. Many of our parishioners would like to see this reversed. I would commend Wickham Market to you for growth and expansion.
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Rolleen Barclay [199] Respondent ID: 199 Submission 199 Agent ID: ID: SUBMISSION Dear Sirs,
The development of Adastral Park by BT.
I would like to register my strongest possible objections to the proposal by OUR Council to take up the opportunity presented by BT'S planning application for 2000 house, in fact a large new town. I should be grateful if my letter could be taken into account.
Firstly, it is extraordinary that your plan exactly matches the no. of houses applied for by BT!! Except that BT has reserved the right to apply for 2,500.00 houses. Have the Council taken into account that BT's profits are badly down and to make a few million would be vastly beneficial regardless of the appalling effect this will have on this part of the country. Perhaps the Councillors are shareholders?
This must be the most ill conceived idea in the history of planning. To put this amount of house so close to the Deben River is total madness. Taking into account the proposed development near Kirton for a vast new business park/lorry park this side of the A14 this is going to create the most wicked urbanization and pollution of a precious and ecologically important peninsular.
Traffic: The weight of traffic over the Orwell Bridge has not been taken into proper account. Total gridlock has got to be a strong possibility inspite of your 7 lane traffic light proposal on the A12 adjacent to Adastral Park. The possibility of having to build a Northern Bypass will have a devastating effect on the villages north of Ipswich. (These people have no idea what is planned). The idea that you will create cycle lanes for people to bike to work is a joke. The surrounding villages will be badly affected and the reasonably peaceful area close to our beautiful river, which many come to visit and enjoy, will be saturated with cars looking for rat runs to escape the gridlock on the A12.
Pollution: Light , air and water and noise. We will not see the stars again - there will be a massive glow of light from houses and streets. This is countryside. Not a dormitory for Ipswich. Some of the buildings planned are very high so will be visible for miles.
The air has got to be polluted from the endless building and vehicle movements that will continue for years. This will have a major impact on the health of residents.
The run-off of water from the miles of concrete will pollute land and the River.
RESUME In short, I think it is incredibly irresponsible of the Council, paid for by us tax payers, to be attempting to ruin a piece of important countryside instead of protecting it which should be their priority. The council have a duty to protect this River and this fast disappearing heath land for future generations.
Any right thinking human being would have to see that it is REDICULOUS to try and squash a vast new town between the River Deben and the A12. A criminal idea that must not go ahead.
Yours sincerely,
Rolleen Barclay, Resident of Waldringfield.
SCDC Response: 12, 17
IPSWICH POLICY AREA
Respondent Name: Ronald and Sheila Payne [422] Submission Agent Respondent ID: 422 ID: 422 ID: SUBMISSION We object to this application, proposed density is unacceptable, it is seriously detrimental to locality and communities.
Our village already experiences heavy traffic, high numbers of visitors coupled with no public car parking and no toilets.
The area already experiences low water pressure being on the fringe of water/sewage services. Fire services recently had problems with lack of water.
All local services including Hospitals, Doctors, Schools and Dentists are overloaded.
It is highly probable that few BT employees will purchase properties therefore increasing the number of commuters on the A12, A14 and the Orwell Bridge. local unsuitable roads becoming overloaded and more dangerous.
There will be a serious adverse effect on the AONB as well as heathland and wildlife.
We understand that there is a necessity for more housing, but it would effect less people and be less environmentally damaging to put these in smaller development as previously supported by the electorate. Why are elected representatives ignoring this?
SCDC Response: 12, 17, 19, 20
THE OVERALL STRATEGY
Respondent Name: Rosa Waller [499] Submission Agent Respondent ID: 499 ID: 499 ID: SUBMISSION Summary
The Council fail to justify the increased number of houses in the IPA. 'A large measure of agreement' is claimed where there has been consistent and overwhelming opposition to the urbanisation of a rural area. 2000 houses neatly dovetails with the BT application and raises questions about the independence of the LDF. The dispersal strategy (deemed appropriate for Felixstowe) is never considered for the IPA but small developments across the region would be more desirable. This proposal means the destruction of a beautiful rural landscape, a huge threat to environmentally important sites and greatly increased traffic in already congested areas.
Comments
My understanding is that no decisions about individual planning applications (and certainly no large controversial ones) should be taken until the Core Strategy has been fully adopted rather than 'all but agreed' (paragraph 1.02).
The current consultation is too narrowly focused given the number of reports that are now available that throw new light on the strategy and policies adopted (paragraph 4.01).
People are definitely 'not' happy with what is proposed as had been demonstrated repeatedly by large scale objections to the choice of land South and East of Adastral park as a site for development (paragraph 3.05). Doubling the number of houses proposed in the face of the concerns raised about the adverse impact of such a development shows a complete disregard for the views of residents (paragraph 5.09).
If the policy is to concentrate 'large scale development at the main urban areas', then developing a new town to the South and East of Adastral park is inconsistent with this policy as this is a rural Greenfield site. it is also contrary to the stated preferences of the public who would prefer smaller sites as indicated by the Issues and Options consultation 2007 (paragraph 5.12).
The case has not been made for the site adjacent to Adastral park offering 'the best all-round solution'. Indeed all the reasons for choosing this area have been consistently critiscised by residents. The existence of the BT planning application has skewed and biased decision-making by the Council. Without that application on the table, it is highly unlikely that this site would have been chosen as it is a rural landscape adjacent to the AONB and European Wetland sites. The notion that 'careful planning and management' can overcome the 'identified problems' is to misunderstand the serious consequences of developing this area (paragraph 5.17).
There is no explanation as to why a dispersed strategy of 'organic and evolutionary growth' is appropriate for Felixstowe and not for the IPA. It seems that the Council simply uses arguments to justify whatever stance it wishes to take, regardless of issues of consistency in Policy. If dispersal is appropriate for Felixstowe, an already developed are, why not for the IPA where the site chosen involves the urbanisation of a rural Greenfield site (paragraph 5.19).
'The financial crisis and resulting recession' are quoted here as impacting the growth of jobs in Felixstowe and therefore as a reason to reduce the housing allocation there. The document appears not to recognise that the credit crunch is a nation wide event impacting Martlesham equally. No consideration is given at all to the possibility that the much trumpeted jobs at the planned business park may actually not materialise, particularly in view of the realities on the telecoms markets, outsourcing abroad etc. There is too much blind reliance on BT's plan for a business park without adequate enquiry into its viability. Evidence of BT's down- sizing and redundancies might be an indicator that it is in considerable decline and thus the outlook for other hig-tech companies might be unfavourable (paragraph 6.03 Felixstowe Comment 1).
Althought 'reducing the impact on the A14' by reducing the number of houses in the Felixstowe area, this is more than outweighed by the increase in traffic resulting from the increase in the number of houses South and East of Adastral Park. Increasing traffic on the A12 and A14 will pose major problems and the Orwell Bridge is already a traffic nightmare. Insufficient account has been taken of extra traffic from these proposals (paragraph 6.03 Felixstowe Comment 3).
'The integrity of local communities' is respected I Felixstowe but ignored in the IPA (paragrpagh 6.03 Felixstowe Conclusion).
If the number of houses was already felt to be too great in the IPA development it is an incomprehensible response by the Council to double that number in order to create a new town in an environmentally sensitive spot (paragraph 6.03. IPA Comment 1).
Creating a 'good sense of place in the community' is dependent on many factors over and above the bricks and mortar in an area. Many sociological studies point clearly to this. It certainly cannot be claimed as a justification for building a larger number of houses. Providing more community facilities only becomes necessary if more houses are built and would not be needed if the housing were disposed over the IPA area. no evidence is presented to support the claim that 'the benefits do indeed outweigh the disbenefits'. This conclusion would suggest that evidence to the contrary has been ignored, eg the disbenefit of urbanising an open rural landscape, the disbenefit of the impact of such a development on an environmentally important area, the AONB, Ramsar sites as well as the disbenefits of the massively increased traffic flow in an already congested area (paragraph 6.03 IPA Comment 2).
Building more houses inevitably creates a greater visual impact that cannot be 'better' mitigated by landscaping. The assertion that the 'degree of the disbenefit' from damage to the landscape...is limited' is unbelievable in the face of what will be total destruction of a landscape. This is Greenfield site where mineral extraction is only temporary. Building a town means losing potential agricultural land or the opportunity to restore the land to its previous heathland state, a habitat that has been consistently lost to development in this area (paragraph 6.03 IPA Comment 3).
Even of there are open spaces in the development this does not prevent people suing the AONB, the Estuary etc for dog walking and recreation. People are free to go where they wish. Twice the number of houses creates twice the number of cars, people, dogs, boats etc to potentially disturb the environmentally sensitive sites (paragraph 6.03 IPA Comment 4).
The real impact on roads and junctions is not being acknowledged here. Twice the number of houses means twice the number of cars etc and will create twice the amount of congestion on the roads, roundabouts etc (paragraph 6.03 IPA Comment 5).
The Council is trying to justify doubling the number of houses by pointing to the consequent provision of more public transport, a secondary school and other infrastructure which is only needed when more houses are built. Doubling the number of houses cannot reduce the impact on the surrounding areas (paragraph 6.03 IPA Conclusion).
The increase in numbers in the IPA neatly dovetails with the BT planning application. It is very hard to see the LDF as an independent exercise genuinely considering best options for future planning development and not as utterly tainted by the existing application. The Council has provided no justification for increasing the numbers apart from the circular argument about providing more infrastructure which would not be necessary without the oncreased housing. The proposed new town is described as both a 'stand alone' community and as being 'well integrated into Martlesham'. This would seem to be contradictory and an example of the Council simply using arguments to justify its actions regardless of consistency and accuracy (7.02/03).
There appears to be little logic and reasoning in the Revised Strategy. The increased numbers of houses are not justified nor is there any evidence that the broad housing strategy will be better met as a result of the changes. Claiming a 'large measure of agreement' on the Strategy as a basis for increasing the numbers is patently wrong. There has been overwhelming opposition and consistent objections made to the choice of the area South and East of Adastral park.
Sustainability Appraisal - OBJECTION
Summary
Sustainability is not defined so increased sustainability cannot be assessed. The sustainability strategy for Felixstowe, that of dispersal (dispersing the potential negative effect of major new build) is sensible and should apply to the IPA. Walking/cycling/using public transport are laudable aims but not promoted by building a new town in the countryside. Increasing the numbers of houses runs contrary to conserving and enhancing biodiversity by destroying a greater area of countryside and further opening up an environmentally sensitive area to greater impacts from greater numbers of visitors/dogs etc.
Comments
No satisfactory definition of sustainability is put forward so it is hard to see how the claim that the sustainability of the new policy is higher than the previous version is arrived at (paragraph 2.2).
The fact that the policy encourages the use of public transport/walking/cycling etc is aspirational rather than real. Developing the rural area South and East of Adastral park is more likely to result in far more people needing to commute by car into Ipswich or further afield for work. The 'houses next to jobs' pitch here is no longer a sustainable argument (Appendix 1 SP20 14).
The development at Adastral Park clearly runs contrary to this objective of conserving and enhancing biodiversity not only destroying a significant area of countryside but also opening up an environmentally sensitive area to greater impacts from greater numbers of visitors, dogs etc (Appendix 1 SP20 17).
The sustainability strategy for Felixstowe: dispersal allows 'individual communities to grow at a rate which is more readily absorbed into the existing social fabric', 'dispersing the potential negative effect of major new build'. This very sensible argument should also apply to the IPA (Appendix 1 SP21 Assessment summery).
Appropriate Assessment - OBJECTION
Summary
The Council are unable to quantify the amount of disturbance/impact that will be caused to the Estuary by the increased housing. A Dorset dog walking survey is used to conclude that disturbance will be insignificant - this is hardly an adequate basis for decision-making on such an important issue. The lack of public car park at Waldringfield does not deter visitors who park in the pub car park, on the verges, at Church Field, the Church, on the road. Provision of a new Country park as mitigation for damage will not necessarily deter visitors to the AONB and estuary.
Comments
Contrary to what is asserted here the estuary side path is extremely well used all year round where it is accessible. There may be no public car park but people simply park in the Pub car park, by the Church, on Church Field, along the road, on the verges. The lack of public car parking is not an effective deterrent. The Council cannot assert that the integrity of the Deben Estuary at Waldringfield will not be affected by the increased housing allocation South and East of Adastral Park (paragraph 6.2.37).
The Deben Estuary is acknowledged to be a 'refuge' area for SPA qualifying birds. The Council are unable to quantify the amounts of disturbance to birds or impact on other wildlife that will be cased or indicate levels of adverse effect from the increased housing. Relying on a study of dog walking in Dorset (not necessarily comparible to here), the Council predict that people will not venture more than 1km on foot and that the area will be inaccessible by car due to lack of car parking, concluding therefore that increased disturbance will be insignificant. This is not an adequate argument given what is at stake here in terms of protection of birds and wildlife in an environmentally special area (paragraph 6.2.32).
As mitigation for the unknown increase in visitor numbers, dogs, traffic etc to the Deben Estuary SPA as a result of the new town development the Council is proposing to create a new Country park. The provision of extra green space cannot compete with the draw of the Estuary which is a very beautiful and special environment (paragraph 7.2.2).
This assessment is a case of extrapolating from dodgy data. To conclude that there will be no adverse effect on the integrity of the Estuary from one dog walking survey in Dorset is frankly inbelievable. The counts of species in the Estuary simply reinforce the special nature of the area and the extent to which it is being endangered by the proposed increase in housing by SCDC (paragraph 9).
SCDC Response: 8, 9, 12, 13, 15, 16, 17, 18
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Rose Steward [168] Submission Agent Respondent ID: 168 ID: 168 ID: SUBMISSION Dear sir/madam
I am writing to express my shock and dismay on your future plans for my home village. Recently, many locals have expressed their views on the current development plans in Martlesham. I, being only a 14 year old student decided to not act upon these plans and to accept the further development plans and to focus on the present. But after examining the documents and plans I refused to let this pass me by and am now determined to terminate the planning permission. My views on the situation are strong. Not only have I thought of the effect on the locals, but also on the environment. Just stop a minute and think of the consequences of your actions. Imagine, road congestion, crime, over populated streets, rush hour, air pollution, noise levels, queues for shops, loss of the RPCA and more. The idea worries me greatly since I have always lived where I live now and my love for it is unbelievably strong. Not only is it a beautiful community, but a place to feel safe, a quiet and easy life for anyone. How can this continue with over 2000 new families? I write not to be intentionally rude but to stop everyone in their tracks and to re-think their steps and to take full responsibility for their actions. Change is not necessarily bad, but I have to consider the effect on my life and my community. Being a teenager, this effects my future greatly and the quality of my life here as I would choose to stay here rather than move away.
Thankyou for your time and I hope you will take my views in to account.
SCDC Response: 16, 17, 18
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: RSPB (Dr Philip Pearson) [580] Submission Agent Respondent ID: 580 ID: 580 ID: SUBMISSION SUFFOLK COASTAL LOCAL DEVELOPMENT FRAMEWORK CORE STRATEGY AND DEVELOPMENT MANAGEMENT POLICIES: HOUSING DISTRIBUTION - UPDATED PREFERRED OPTION 7/09. Thank you for consulting the RSPB regarding the updated preferred housing distribution for Suffolk Coastal district. We are pleased to be able to offer comments. The validity of the Appropriate Assessment - Section 7.2.12 (p.33) As identified in the Appropriate Assessment (AA) there are a large number of Natura 2000 sites designated within the district. Consequently, it is vital that any increase in the district's population must be carefully screened and monitored to ensure that there is not an increased visitor pressure to such sites. We generally accept the findings of the AA and the proposed mitigation measures that will be necessary to avoid adverse effects on Natura 2000 sites in the future. We are particularly supportive of the proposal for a new Country Park to be created to the north or north-east of Ipswich. We agree that this may in part encourage a certain amount of visitor pressure away from Natura 2000 sites, but its effectiveness would need to be carefully monitored and a management strategy prepared for the site. We would expect the site to be functioning fully prior to development taking place. We do, however, have some concerns about aspects of the AA and these are outlined below. 1. The use of visitor monitoring as mitigation The draft AA has currently concluded that there will be no adverse effects because of mitigation measures being put in place. This is largely based on the proposal to undertake further visitor surveys. The citing of monitoring cannot be considered as a mitigation measure to ensure that there will be no adverse effect of the proposed developments, as it does not avoid or reduce the risk of harm to the international sites. Base-line data should already have been gathered, and used to estimate the likely additional impacts of visitor pressure. Monitoring should be used to validate the predictions made by the AA. If baseline data indicated that no adverse effects were expected, on-going monitoring would still be needed to assess future visitor impacts, as highlighted by the AA. If an adverse impact cannot be excluded, it will be important to devise a strategy for implementing suitable site and access controls. Consideration must be given to the speed with which mitigation measures could be implemented. 2. Data underpinning the AA conclusions We have concerns over the appropriateness of applying the findings of the Dorset Heaths study to the Natura 2000 sites of Suffolk Coastal district as there are a number of differences between the areas, notably the variety of habitats the sites support and the biodiversity and recreational opportunities that attract visitors.
Similar concerns over applying the study broadly to other sites were expressed at the 'Examination In Public' of Breckland District Council's Core Strategy. Of particular concern is the use of 1km distance that people are expected to walk to Natura 2000 sites and the 8km distance that people are expected to travel to Natura 2000 sites. These distances are likely to vary, possibly even seasonally, depending on the features of the site that attract visitors. Visitor monitoring at Great Yarmouth and other sites has typically applied a 20km zone of influence (ZOI) to Natura 2000 sites in attracting visitors: a considerably greater distance than used in this AA. Clearly, if a larger ZOI is considered this is likely to increase the number of visitors and hence increase the impacts on Natura 2000 sites. We therefore recommend that if the distances in the AA are to be accepted that they should be supported by more than a single reference to show that the ZOI distances used are justified. Failing that, the ZOI of the Natura 2000 sites may need to be reassessed. 3. Recognition of limitations to the AA Whilst we approve of the approach that The Landscape Partnership have taken in preparing the AA and generally support their conclusions and recommendations, we are concerned by the inclusion of Section 9 'Limitations to the assessment.' It clearly identifies data deficiencies with regard to visitor numbers and therefore creates doubt over the assumptions made regarding visitor impacts on Natura 2000 sites, notably the Deben Estuary Special Protection Area (SPA), the Stour and Orwell Estuaries SPA, the Alde-Ore Estuary SPA, the Sandlings SPA and the Minsmere-Walberswick SPA. Our concerns over the impacts on these sites were raised in our response to the Site Specific Allocations and Policies Issues and Options Consultation dated 20th February 2009. In order for the assumptions in the AA to be accepted, we believe that a more robust evidence should be presented at the final submission stage to show that the plan can be deemed sound. Conclusions: The RSPB considers that there is a significant question mark over the plans soundness as a result of the AA's inclusion of a 'limitations' section. Whilst we accept that further work will be necessary, notably the establishment of a visitor monitoring strategy, the lack of a solid evidence base regarding visitor numbers compromises the conclusions drawn in the AA. Based on the current information underpinning the AA, we are therefore uncertain whether the updated preferred option document could be adopted as it stands. We trust that these comments are helpful. If you have any queries on the issues discussed above, please do not hesitate to contact me or my colleague Mary Norden ([email protected]) who is the RSPB Conservation Officer covering the Suffolk area.
SCDC Response: 8 Other comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Rushmere St Andrew Parish Respondent Name: Council (Mr Mel Bentley) [502] Submission Agent Respondent ID: 502 ID: 502 ID: SUBMISSION Dear Sir,
Rushmere St Andrew Parish Council have examined the 'Housing Distribution - Updated Preferred Option 7/09' consultation document and would wish to comment as follows:-
In general, Rushmere St Andrew Parish Council supports the proposed changes to the housing distribution and would agree that the reasons behind the changes are justified. Specifically we agree that within the Ipswich Policy Area, East of the A12, an allocation of 2,000 homes at Martlesham is the most suitable way to allocate the housing requirements for that Policy Area.
However, we do have major concerns regarding the traffic loading that will result from such a development on the two main feeder roads into Ipswich (A1214 and Foxhall Road). In particular, Foxhall Road currently classified as a 'C' class road, which in its current state can barely support existing traffic loads, would be overwhelmed given the addition of 2,000 additional dwellings at Martlesham. Hence major road infrastructure improvements need to be planned, not just in the immediate vicinity of Martlesham (A12 corridor) but also on those Ipswich feeder roads.
We re-iterate our earlier comments (29th January 2009) with respect to 'Rushmere St Andrew (south)' currently considered part of the East of Ipswich, Major Centre. This Council still feels that this settlement should be considered in its own right with respect to the settlement hierarchy classification. On that basis it should be moved down to a Local Service Centre, as it aligns more closely to that hierarchy level by virtue of only having convenience shopping and is unlikely to ever have a Post Office or Doctors Surgery facilities in the long term. Whilst it is close to Ipswich it does not in itself have the requisite facilities to be classified any higher than a Local Service Centre. Indeed, SP11 - Key Service Centres and Local Service Centres would appear to be the most apt envelope for this settlement.
SCDC Response: 19, 20 Other comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Sainsbury's Supermarket Ltd Respondent Name: [555] Submission Agent Respondent ID: 555 ID: 555 ID: Caroline Huett SUBMISSION SUFFOLK COASTAL HOUSING DISTRIBUTION, UPDATED PREFERRED OPTION We write on behalf of our client, Sainsbury's Supermarket Ltd, in respect of the recently published Housing Distribution, Updated Preferred Option consultation document. Indigo Planning has previously submitted representations on behalf of Sainsbury's Supermarket Ltd on both the Core Strategy Issues and Options document and the Further Issues and Options document. These representations supported the allocation of new housing within 'Area 5', situated to the North-west of the A14, as the broad area for the strategic housing growth to the east of Ipswich. The Updated Preferred Option does not include 'Area 5' as a potential location for new housing. However, we still consider that allocating housing in this area would provide a sustainable and logical solution in accommodating the identified need for housing growth as it is in a location which is well served by its proximity to existing retail and employment opportunities, infrastructure and facilities. Please keep us informed of the LDF process going forward. Should you have any questions or wish to discuss our representations further please do not hesitate in contacting me, or my colleague Leanne Croft.
SCDC Response: Noted
2 THE CONSULTATION IN BRIEF
Respondent Name: Sally Hopper [546] Submission Agent Respondent ID: 546 ID: 546 ID: SUBMISSION Ref: How many homes? 2.03 The total number of new homes... Comment: it is wrong to continue with this outdated projection which has not taken the credit crunch into account. The document does not present any evidence to justify that the population proposals are either accurate, or suitable for the infrastructure, or the local environment.
The phasing of the homes 2.04 Comment: please clarify the difference between 'specific deliverable sites' and 'specific, developable sites'. This parag is not clear, and we cannot comment on the proposed changes without very clear understanding of what your propose..
How much new housing is needed? 3.02, 4) Comment: The council needs to be very mindful that BT will not offer much in the way of additional jobs locally, it is naïve to think that UK people will be employed by BT. For many years now, BT has been preferring to employ off-shore (Indian) contract staff who fly in to Suffolk, stay a few months to become familiarized, and then fly back to India to continue working as off-shore resource. These workers are used by BT because they cost considerably less than UK-based workers with the same skills. If you are not aware of this, you should stand at the '66' bus stop at the beginning and end of the day to see the large numbers of Indian workers. Thus it is wrong to select Ipswich Policy Area2 east of the A12 at Martlesham for a large numbers of houses.
5.08 Note for all those settlements listed as "Other Villages" or "Countryside" no change is proposed in terms of the revised housing distribution. Those settlements are not proposed to have any allocations of new homes. Comment: while it is appreciated that the 'other villages' are unaffected, the council has not taken into consideration what a massive impact the housing will have on the character and way of life in Waldringfield, it is so immediately close to the Ipswich Policy Area2 east of the A12, and has no through road. The pub, sailing club and beach currently attract huge numbers of people in the summer - already causing traffic problems in the village. The additional housing, so close to the village would cause a massive increase in the numbers trying to access the eastern end of the village, bring massive traffic problems and pollution to the environment. What will the council do to prevent this? 5.10 states: "New housing should allow integration with existing communities but at the same time should respect and maintain the character of individual settlements and communities; In deciding where new development should go, it should respect the quality of the local environment; Protection should be given to wildlife and to the landscape, particularly those areas that are designated as being of national and international importance;"
Comment: What specific steps will the council take to ... 'respect and maintain the character of individual settlements', 'respect the quality of the local environment' and protect wildlife ?
Given the impacts expected on Waldringfield, I rather doubt that the council will be able to meet these worthy aims. Should you really make promises you cannot keep? Without knowing your plans in this respect, it is not possible to comment adequately on the proposals.
5.17 states: ... "It was considered that with careful planning and management the identified problems could be managed to an acceptable level" Comment: Please explain the term 'acceptable', and state who will decide what is and isn't acceptable. Without knowing your plans in this respect, it is not possible to comment adequately on the proposals. 7.03 Ipswich Policy Area - East of the A12 Where are the 'objectives' and the 'Action Plan'?
8.02 The changes are not justified, since the impact of the larger community on Waldringfield will be even more severe than the original proposal, and no proposals are offered on how the impact will be mitigated, other than saying you will provide dog walking space. Can you not be more imaginative, and consider that the new community needs to have some very major attractions of its own that will contain the community sufficiently to prevent it spilling out to overrun the neighboring communities, such as: lake with beach facility, boating on the lake, angling opportunities, allotments, a 'Go-Ape' type facility, a cinema / entertainments complex, skating track, speed cycling facility, dirt-bike riding facility, etc, etc.
Since I did not agree with the broad strategy already commented on, I cannot unfortunately agree with the changes.
If you are objecting to any area of the documents, please indicate what changes you would like made (please continue on a separate sheet if necessary)
8.02 I would like the changes to include proposals that specify what the council will do to mitigate the impact on the Waldringfield community. The new community needs to have some very major attractions of its own that will contain the community sufficiently to prevent it spilling out to overrun the neighboring communities, such as: lake with beach facility, boating on the lake, angling opportunities, allotments, a 'Go- Ape' type facility, a cinema / entertainments complex, skating track, speed cycling facility, dirt-bike riding facility, etc, etc. The infrastructure study on page 19, is not sufficient.
SCDC Response: 3, 7, 16, 17, 18, 19
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009
Respondent Name: Sally Redfern [490] Submission Agent Respondent ID: 490 ID: 490 ID: SUBMISSION Which document and sections are you commenting upon?
Updated Preferred Option 07/09: yes
Sustainability Appraisal: no
Appropriate Assessment: no
Section: 5.08, 5.17, 5.19, 6.03, 7.01, 7.02, 7.03 Paragraph:
Are your responses supporting, objecting or generally commenting? objecting
If you are commenting upon the Updated Preferred Option 07/09 document, then please indicate concisely whether you feel the changes are a) justified and b) are considered to better meet the broad strategy for development in the district. If you are commenting on the Sustainability Appraisal or Appropriate Assessment documents, please indicate concisely, the nature of your support/objection or other comments (please continue on a separate sheet if necessary). Comment 1
Summary The need to double the housing allocation is not justified on the evidence provided. The infrastructure required to support a large single-site housing development east of Ipswich could be avoided if the housing needs were dispersed over the whole region. Modest extension of existing communities and villages, which already possess a certain amount of infrastructure, and a thriving community life, would be far cheaper than starting from scratch with a large new development.
Comment a) The proposed changes are not justified Doubling the housing allocation is not justified on the evidence provided. The argument put forward in the document is confusing, incoherent, unconvincing and circular. The infrastructure required to support a large single-site housing development east of Ipswich at Martlesham would not be needed if the housing needs were dispersed over the whole region in a number of small units. Indeed, adding new small units to existing communities and villages, which already possess a certain amount of infrastructure, would be far cheaper than starting from scratch with a large new development. Villages enjoy a thriving community life that could readily absorb incoming families. I do not understand why a dispersed housing strategy is proposed for Felixstowe and the Trimleys and not for Martlesham. That decision seems to me to be logically inconsistent. b) The proposed changes do not better meet the broad strategy for development in the district The proposed changes are unjustified, as argued under a), and so cannot be said to better meet the broad strategy for development. A multi-site housing development dispersed across several sites would be a far better strategy, as is reinforced in supporting documents, and would not need the financial outlay required for a large single-site development.
If you are objecting to any area of the documents, please indicate what changes you would like made (please continue on a separate sheet if necessary)
The solution is to disperse the houses needed across existing communities rather than opt for a single-site strategy. This would enable the costs and benefits, such as welcome regeneration, to be spread equably in several communities.
Signed: Sally Redfern Dated: 18.11.09
Thank you for your comments
Please return this form by post or email to: [email protected]
Which document and sections are you commenting upon?
Updated Preferred Option 07/09: yes Sustainability Appraisal: no Appropriate Assessment: no
Section: 4.02, 5.19, 5.12, 5.17, 6.0, 7.01 Paragraph:
Are your responses supporting, objecting or generally commenting? objecting
If you are commenting upon the Updated Preferred Option 07/09 document, then please indicate concisely whether you feel the changes are a) justified and b) are considered to better meet the broad strategy for development in the district. If you are commenting on the Sustainability Appraisal or Appropriate Assessment documents, please indicate concisely, the nature of your support/objection or other comments (please continue on a separate sheet if necessary). Comment 2
Summary Doubling the housing numbers from 1050 to 2000 risks serious over-development. New up-to-date predictions are needed before decisions are made so that the carbon costs of over-development, and unacceptable traffic congestion, are avoided and to confirm current employment need.
Comment a) The proposed changes are not justified Doubling the housing numbers from 1050 to 2000 (and more are predicted in later years) risks serious over- development at a time when housing needs may be fewer than that predicted. New up-to-date predictions are needed before decisions are made so that the carbon costs of over-development, and unacceptable traffic congestion, are avoided and to confirm current employment need. b) The proposed changes do not better meet the broad strategy for development in the district A strategy based on out-of-date predictions cannot be said to better meet the development requirements of this district and, particularly, if it increases carbon costs that could have been avoided.
If you are objecting to any area of the documents, please indicate what changes you would like made (please continue on a separate sheet if necessary)
A reliable, evidence-based study is needed for housing need in the Martlesham area before decisions are made about the best strategy.
SCDC Response: 4, 15, 16, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Sally Winterbourne [131] Submission Agent Respondent ID: 131 ID: 131 ID: SUBMISSION I object in the strongest terms to the continuously changing plans for Adastral Park. There are too many houses proposed - this will result in more traffic and lower quality of life in this area. What about sewage and water requirements - straining resources in the driest county? This is a beautiful area with outstanding wildlife and quality of life for its residents - please do not diminish this by supplicating to BT's demands motivated by money alone. Do not delude yourselves that this will benefit this area - it will detract. More traffic, more crime, more people, more sewage, more rubbish, more cars, less space, less water, less freedom, and overall destruction of our beautiful countryside.
I urge you to hear us - the residents of Martlesham.
Regards Sally Winterbourne
SCDC Response: 16, 17, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Sarah Videlo [527] Submission Agent Respondent ID: 527 ID: 527 ID: SUBMISSION Housing Distribution - Updated Preferred Option 7/09 response
Summary
I strongly object to the numbers proposed in the new LDF, which will make all the disastrous impacts of the proposed new town at Adastral Park even worse. This totally inappropriate development will urbanise a beautiful rural area and have an overwhelming impact on local communities, the road system and the environment. It is in close proximity to the Deben Estuary which is an internationally recognised and PROTECTED environmental site having SPA, SSI and Ramsar status and is within the Suffolk Coasts and Heaths AONB.
Response I strongly object to the housing allocation of 2,000 homes on the Adastral Park site on the grounds of the negative impact on the internationally recognised environmental site that is the Deben Estuary. The original allocation was totally unacceptable and this revision simply doubles the issues; the housing will be denser, no space for areas of heathland to regenerate and the new residents will be even more likely to look for recreation in the surrounding area. Moreover the runoff from the site will naturally drain through streams and creeks to the Deben Estuary with resulting effects on the chemistry of this highly sensitive ecosystem. The questionable premise that people walk, on average, 1km. from their homes (App. Ass. 6.2.35) brings Martlesham Creek within easy range at one side of the development. The premise is also undermined when, at a distance of only 2km. on footpaths, there is a beautiful riverside with a sandy beach and a pub to provide rest and refreshment, a circular walk along the river wall and a different route back mostly on footpaths. Furthermore, just over 1km. away on footpaths is the SSSI Newbourne Springs nature reserve, again with a pub a short distance away to act as a draw. Also in Appendix 6, the Suffolk Coasts and Heaths respondent states that even a 1% increase in visitor numbers would increase the harm done to the Deben SPA and the AONB. The "low to moderate level of terrestrial recreational activity at present" (App. Ass 6. 2. 26) already results in considerable disturbance to feeding birds. Increased human activity would result in even more disturbance, destroying one factor that gives the Deben Estuary its Ramsar status. Further disturbance on the banks of Martlesham Creek will result from the new sewage treatment works that will be required whether 1,000 or 2,000 houses are built. In sum, trampling and chemical contamination will adversely affect what is supposed to be a RAMSAR and a highly protected area. Other disturbance will be caused by light and noise pollution from the site itself.
The extra traffic generated by this development will cause major congestion to the road network causing even more problems on the Orwell Bridge and the Seven Hills roundabout especially during peak times and periods of bad weather. When accidents occur on these major roads the whole of Ipswich becomes gridlocked. The A12 struggles to cope now with current traffic levels and the replacement of roundabouts with traffic lights will exacerbate the situation and cause more congestion on other local routes with traffic trying to avoid them. Residents of Martlesham Heath will be subjected to the same problems as those at Grange Farm endured for many years.
Waldringfield already suffers from influxes of visitors in the summer months. There is officially no public car parks but people already park illegally and cause access problems. There are also no public toilets here and problems with human waste being deposited on the beach and around beach huts, already happens in hot weather. This is the nearest beach for the new town. This will not get any better with addition of 2000 houses.
I would urge SCDC to look again at the plans for houses at Adastral Park and not to pass this scheme that will have such a damaging effect on the surrounding communities and an internationally important wildlife site.
SCDC Response: 12, 17, 18, 19
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS Save Felixstowe Countryside Respondent Name: (Mr John johnston) [505] Submission Agent Respondent ID: 505 ID: 505 ID: SUBMISSION Save Felixstowe Countryside Submission To LDF Consultation
Save Felixstowe Countryside is a group comprising approx. 100 members and has been responsible for much of the awareness of Felixstowe residents through various means including doorstep publicity funded by members own pockets.
Firstly, Save Felixstowe Countryside would like to highlight that there is clearly NOT a broad agreement on the Core Strategy. The overwhelming response to past public consultations is evidence that the core strategy is overwhelmingly rejected with the points raised being summarily dismissed. The public rejected the housing allocations for Felixstowe in past consultations and most recently through their elected body, Felixstowe Town Council. Save Felixstowe Countryside thought the objective of the public consultation process was to develop an LDF supported by the community, not one in spite of it.
The LDF must be re-written with a significantly lower housing allocation for Felixstowe else it will destroy the town.
There has been insufficient publicity for the LDF consultation excercises past & present, and the publicity that there has been has been biased by misleading facts or cherry picked evidence to support a "preferred option" whilst contra-evidence is silently ignored. There has not been an open unfettered consultation process but a carefully orchestrated process in which public consultation is largely ignored.
False facts are used to defend the LDF. For example; a) commuting figures used to show a nett inflow of commuters to Felixstowe include misleading data. Commute figures TO Felixstowe include significant numbers from the Trimley villages. These villages themselves are potential locations for houses to reduce commuting from themselves! Also included are locations for which house prices are significantly more expensive that Felixstowe. Clearly, if an individual is prepared to pay a premium to live in another area, no matter how many houses are built in Felixstowe, this commute will not be prevented. Similarly commuting from distant locations such as Colchester & Thurrock were included. Clearly these are not due to affordability or availability of homes in Felixstowe. Commuter statistics for those who commute from significant distances, from areas whose house prices are more than Felixstowe and areas which are close to Felixstowe should be excluded to make the analysis valid. b) houses are needed because of shrinking household sizes and ageing populations. Household size in Felixstowe is only 2.2, so a decrease in household size to 2.1 means a maximum requirement of 450 houses. Due to the ageing population, it is forecast that there will be more house dissolutions than formations so even all of these 450 houses may not be needed. Thus, this should be possible to restrict to brownfield sites.
Felixstowe is NOT a major urban area within the context of that described in the RSS, nor is it identified as one in the RSS. Unlike major urban areas, Felixstowe has just one significant employer, the port. Felixstowe has already been identified as having an overdependence on port or port related employment in the David Lock study for Felixstowe. Given the current financial crisis the port has suffered a decline. The port has enjoyed significant throughput in the form of high imports in the past which has contributed to a massive national debt. Consequently, the current modest levels are likely to continue for some time. Setting asside the port or port related activity, there are little prospects for employment.
Felixstowe is the last stop on the A14. Any businesses sited at the end of the Peninsula have to travel up and down a busy A14 competing with port traffic. Whilst it is appreciated that what amounts to a large siding is being proposed - a significant amount of freight will still need to travel by road. Consequently, it is highly unlikely for significant sized businesses to relocate to the end of a Peninsula, they will locate in an area with good road & rail communications.
The A14 study looks at specific junctions. It does not look at the capacity of the Orwell Bridge. According to a study in the LDF base the bridge is predicted to be at 98% capacity by 2015. This before any consideration of the expansion of Ipswich, Martlesham, Felixstowe or the rest of the District. This fact seems has been overlooked in the transport study looking at the ability of the A14 to handle the councils preferred option for Felixstowe.
According to the Highways Agency traffic model which has been validated against measured figures, nett traffic flows show that there is a nett OUTFLOW of trafic in the morning and nett INFLOW in the evening. Should the additional housing be provided at Felixstowe, it is likely that there will be increased outward commuting as those that move in to occupy the houses have to commute for employment.
The Governments stated objective is to make houses more affordable, to that end it ought to be distributed in accordance with market forces & with regard to local need. A recent house price survey reveals that Felixstowe is one of the cheapest locations in the District, thus housing should have a greater focus towards the most expensive towns as well as some in villages, in accordance with their wishes, in order that their amenities and schools remain viable and their communities vibrant. We are also aware that some areas of the District have high numbers of holiday homes (e.g. Aldeburgh 27%, Walberswick 34%) so these ought to be the focus of provisions to keep communities vibrant during the week & schools viable. Details follow for the average house prices sold over the past 3 years;
TOWN AVGE PRICE SALES FELIXSTOWE £184,585 1,428 WOODBRIDGE £259,748 1,811 ALDEBURGH £341,657 255 SOUTHWOLD £331,644 323 STOWMARKET £190,162 2,046 SAXMUNDHAM £241,924 569 DISS £216,330 1,385
We understand from presentations at Felixstowe Town Council that the policy of 1 in 3 affordable homes in Felixstowe will be reduced to a position of "there may be some affordable homes." If this is true, then this is a very significant change to the LDF and calls into question the validity and credibility of this consultation excercise. A full consultation on the revised document as a whole should be subject to public consultation. How many other changes have been quietly made to the LDF yet not consulted on?
Whilst not specifically in this consultation, we understand there are thoughts to build warehouses or container storage facilities on high quality agricultural land on the approach to Felixstowe. This is a grave mistake as it would mean the loss of much needed quality farmland, increase lorry movements on the A14, lower the already poor air quality, cause undue congestion and further increase the dependency on the port. Such a facilty should be located close to rail links, major roads and off the peninsula. When the UK consumes less than 29% of that it grows, only the poorest grade agricultural land should be used.
Section 7.01 - Object to the link road being an objective. This policy automatically means the loss of greenfield land. It must be removed. States greenfield land will be used after brownfield but policies in this actually require green field land to be taken first. This policy creates coalecence between communities. Something that Save Felixstowe Countryside believed this was against planning policy. Woodbridge has a policy to protect the town using the A12 as a firm edge to the town to retain quality & character. Felixstowe has exactly the same issue and so the A14 combined with Candlet Road & Links Avenue should be used as a firm boundary for Felixstowe, however, unlike Woodbridge, the boundary isn't breached by a significant retail facility & small housing estate. Failure to implement would demonstrate inconsistant planning policy.
A new housing survey is due as at 1 April 1010, and this could alter the need for 1000 houses in Felixstowe.
It is likely that there will be a change of government very soon. This could mean a complete change in policy.
The whole consultation is fatally flawed because it is too narrow and far too many new evidence base documents have only just been published. Given this plus the disturbing anomalies found there is a need for a full ranging consultation in the new year.
SCDC Response: 1, 3, 5, 10, 12, 22, 24, 26, 27
2 THE CONSULTATION IN BRIEF Save our Country Spaces (MRS Respondent Name: Barbara Robinson) [364] Submission Agent Respondent ID: 364 ID: 364 ID: SUBMISSION Save our Country Spaces (MRS Barbara Robinson) [364 I wish to make the following representations on the Development Plan Document (DPD) Core Strategy and Policies . * These proposals are "unsound" due to SCDC having used an out of date and incomplete evidence base. * That the evidence base was not complete when the decisions were made. Therefore the proposals are not robust; are unjustifiable and unsustainable without guaranteed funding available for hospitals, schools, other services. * We need realistic transport policies which take global warming and climate change into account. * Both the "Greater Ip[Ipswich "Area and Suffolk Coastal are impacted by having used an out of date and incomplete evidence base. The order of events should be: evidence productionpublic consultationpolicy finalisation The order of events of this plan has been; public consultationpolicy finalisationevidence production. This policy document is UNSOUND due to flawed procedure. No convincing evidence has been provided by the Regional Assembly to justify this current growth agenda for the region. I attended the recent public event held by the RA in Ipswich and found their methodology and evidence base wanting. I contest; (a) That the proposal to increase the population is either needed or desirable (b) Insufficient employment opportunities exist for our indigenous population (c) The Government recently admitted that they had been Maladroit regarding population increase from migation.; that projections for population, from migration increase were wrong and that measures would be taken to reduce this growth. This was confirmed by data from the Office of National Statistics and Cross Party Select Committees (d) If , how and when the necessary hospital, health and social care services would be available, what the funding for these provisions would be and how it would be provided, (following listening to the recent SCDC LD Task Force) on who will pay for necessary infrastructure (e) How and when the present road structure in the town would be up to a standard (if it were feasible) to cope with the increase in population and traffic (f) Ipswich's Definitive Map of Right of Way is still at a very early stage, therefore the layout of future development cannot be properly assessed by either IBC or by Suffolk Coastal District Council (g) Northern By Pass. The public is unable to come to a firm opinion as to whether this would be advantageous to Ipswich and Suffolk Coastal District as; * no evidence available of expected traffic volume on this by pass * source and destination of this traffic has not been established * what impact this might have on town traffic has not been establish * if it was expected that the land between the current developed edge of town and the new by pass would mainly be used for housing development, what impact this would this have on town centre I wish the Council to resist the politically driven Growth Agenda. TO SAVE THE region FROM WHOLESALE DEVELOPMENT PROTECT OUR FARM LAND AND GREEN SPACES PROTECT OUR QUALITY OF LIFE- this growth agenda will damage local environments ( I agree with Natural England) and adversly impact on our quality of life WE DO AGREE WITH THE NEED FOR A COUNTRY PARK IN THE NORTH area of Ipswich and environs We need modest sustainable growth of existing village and small town communities. WE NEED THE GOVERNMENT & COUNCILS TO TAKE A MORE REALISTIC APPROACH AND ENCOURAGE BUILDING WHERE INFRASTRUCTURE CURRENTLY EXISTS I support the following comments; We note in 7.2.8 that a new country park is proposed for north or north-east Ipswich, possibly in the Martlesham area. Whilst this will provide a facility for people in this area, it will not address the needs of housing growth in the Felixstowe/Walton and Trimley Area. We note in 7.2.5 that improvements need to be made to accessibility of greenspace provision. This does not match with what is being said in 6.2.43 which uses the phrase 'adequate greenspace provision' (rather than access to it). Mitigation therefore needs to include new greenspace provision for the 1000 new homes in this area as well as improvements in access. SP2 Housing numbers- negative impact noted by Natural England SP5 SP17 SP20 Need for an Appropriate Assessment
SCDC Response: 3, 7, 9, 19, 20, 25
2 THE CONSULTATION IN BRIEF Saxmundham Town Council Respondent Name: (Maddie Gallop) [436] Respondent ID: 436 Submission 436 Agent ID: ID: SUBMISSION
Saxmundham Town Council have no further comments to make.
SCDC Response: Noted
3 BACKGROUND Sibton Parish Council (Sally Respondent Name: Lear) [429] Submission Agent Respondent ID: 429 ID: 429 ID: SUBMISSION We understand the need to increase the existing housing stock and accept that the majority of additional housing would: 1. Benefit from being built where the infrastructure exists to support it or where it can be suitably upgraded to meet the needs of any new development. 2. Benefit the regeneration of areas where this is advantageous for long term benefits such as accessibility and employment.
Sibton Parish Council is keen that the impact on the landscape by any future developments be thoroughly considered and every effort made to minimise the adverse effect that such developments would have on the quality of life for existing neighbouring residents, in particular, sites that are known to be at risk of flooding should not be considered for development; other, more suitable sites should be selected.
SCDC Response: Noted
1 INTRODUCTION
Respondent Name: STAG (Mr Ian Cowan) [312] Submission Agent Respondent ID: 312 ID: 312 ID: SUBMISSION Consultation Response By Save Trimley Against Growth - STAG - November 2009
Consultation Confusion It is our belief that the online consultation system is potentially confusing, and could discourage stakeholders from submitting responses. STAG want to comment on the consultation as a whole, but there appears to be no facility to do so. We have therefore submitted our response in the "introduction" sexction, but our comments refer to the whole process.
Introduction STAG's response to the previous LDF consultation was censored on the spurious grounds that some of our comments were "extraneous". We have reason to believe that other stakeholder responses were also censored, but (a) Philip Ridley ignored our Freedom Of Information request to provide further details, (b) on appeal, Jeremy Schofield refused to provide these details, and (c) despite several reminders Council Chairman Stephen Burroughes has declined to comment on this censorship.
We would like it to be known that we consider none of the following consultation comments to be in any way extraneous and want them to be made available for consideration in full by Cabinet members, plus other Councillors and all other stakeholders and other interested parties.
At previous consultations STAG occasionally requested further information from Stephen Brown in order for us to complete our responses. This information was always supplied promptly and in full. As part of the current consultation we have made similar requests for information to Hilary Hanslip. Despite SCDC's claimed policy of openness and transparency, these requests have all been dealt with in terms of the Environmental Information Regulations 2004 and, almost invariably, the full 20 working day period has been taken to reply. These time delays have hindered our ability to carry out further research and have also discouraged us from seeking further information on certain matters of concern to us.
Limited Scope Of This Consultation The stated intention of the LDF Task Group is that the current consultation should be narrowly focused on only the housing numbers and nothing else. However, a large volume of supporting evidence has only just been published concerning some very important matters, including infrastructure, road traffic and retail facilities. It is the belief of STAG, shared by many others, that the integrity of this consultation is fatally flawed (a) because it is so narrow in scope, and (b) because the accompanying documentation is so voluminous and varied in the matters covered that no reasonable individual stakeholder or group of stakeholders could possibly digest and consider everything in the time available.
We have discovered several major flaws and anomalies - as noted below - based on only a limited reading of the recently published documentation. What we - or others - may find given more time can only be speculated at. These anomalies cast doubt on the integrity of the LDF documentation taken as a whole.
At the last LDF Meeting - on 15 October 2009 - a number of District Councillors complained about the limited scope and time scale of the current consultation. These concerns were dismissed by Philip Ridley, who stated that "there was nothing new in the content or detail" of the current consultation documentation, and that "stakeholders have got adequate time to consider everything." We believe that these comments by Philip Ridley were misleading because in subsequent correspondence with STAG he claimed that his remarks referred to the whole consultation process and not just the current element.
STAG challenged Ray Herring to survey a sample of stakeholders to assess whether or not they shared the concerns expressed by District Councillors. He refused to do so. It therefore remains to be seen how many stakeholders agree with STAG and the above mentioned District Councillors, and how many agree with Ray Herring And Philip Ridley.
On 6 October Waldringfield Parish Council complained in writing to Philip Ridley about the scope of the current consultation. He only replied after being reminded to do so at the last LDF-TG meeting. In his reply, dated 23 October, he stated: "If your Council is of the opinion that these recent evidence based documents have a direct impact on other district wide policies, then I would advise you to include these comments in your response." This advice, which broadens the scope of the current consultation, has not been widely publicised. The integrity of the current consultation process has therefore been compromised to the extent that stakeholders will respond only on housing numbers without knowing that they can broaden the scope of their responses.
Possible Misrepresentation By Councillor Andy Smith At the last LDF-TG Meeting, in response to a question from Councillor Barry Slater, who suggested that projected housing figures for Key Service Centres could reasonably be increased over the 15 year period, Councillor Smith, in his capacity as Chairman of the LDF-TG, replied: "This is as far as we dare go or the document [submitted to the planning inspector] will be judged to be unsound. I would dearly love to allocate more houses to villages. Current government policy is regrettable, especially for smaller centres."
With this statement he clearly gave the impression to members of the LDF-TG that 210 and 870 were the maximum number of houses which could be allocated "according to government policy".
STAG subsequently wrote to Hilary Hanslip asking her, among other things, to "refer to the actual government policy that limits housebuilding in Key and Local Service Centres to only 210 units? In addition, can you confirm whether or not the number of houses allocated to Market Towns - 870 - has also been limited by government policy"
According to her reply - EIR Request No 239 : "Government policy does not specify the number of houses to be allocated to a particular type of settlement. ... It sets out an approach which Local Planning Authorities are required to follow. ... The Regional Spatial Strategy ... requires 3200 and 7000 houses to be provided. ... How these houses are then distributed across the district is then a matter for this Council following consultation with the general public and other consultees, to determine. It is a matter of judgement set within that national and regional framework and which has regard to the views submitted in respect of these individual settlements."
It will therefore be clear to any reasonable person - including an Independent Planning Inspector - that Councillor Smith's views on this matter are at extreme odds with SCDC's Principal Planning Officer - Policy. It could also be said by a reasonable person that his position as Chairman of the LDF-TG combined with being Deputy Leader of SCDC means that his views were inevitably persuasive of his colleagues in determining LDF-TG recommendations.
Councillor Smith has replied at length and has refuted our allegations. We stand by them and will be happy for a Planning Inspector to make the final decision.
We would add that at the LDF Meeting in question Hilary Hanslip pointed out to Councillor Smith that there was some flexibility but this was waved aside and her comment does not appear in the Minutes. Not surprisingly, there is also no mention in those Minutes of Councillor Slater's statement that the five parishes he represents would all welcome new housing and aren't getting any.
Furthermore, at a Cabinet Meeting held in Kesgrave on 28 October 2008 Councillor Colin Hart asked Stephen Brown if houses could be dispersed around the villages where they were needed, in a "pepper-pot" affect. Stephen Brown replied that the local planners could put these houses anywhere they liked. They didn't have to go in one place.
The Credibility Of Housing Numbers In the Spring 2007 consultation it was claimed that there was a requirement for 2700 houses to be build on greenfield land around Felixstowe and the Trimley Villages up to the year 2021 in order to satisfy local needs. This number was substantiated by numerous facts and figures - in Minutes, consultation documents, drop-in displays and speeches and Powerpoint presentations at public meetings. Shortly thereafter, this was changed to a requirement for 1700 houses which was again substantiated by very similar facts and figures, including "arithmetical proof" via Councillor Smith's claim that headcounts per home was decreasing from 2.34 to 2.1 people. This figure is now 1000 houses. Therefore, using basically the same facts and figures, the supposed "need" for houses to be built around Felixstowe and The Trimley Villages has been reduced by a staggering 63% over a period of less than 3 years.
However, even this figure of 1000 houses appears to be substantially wrong. As part of the brief presented to various consultants, SCDC gave estimates of population growth, and buried deep within one such document (*1) is a prediction that the Felixstowe population will increase over the period of the LDF by 1269 people. At an average density of 2.1 people per household this gives an actual need of only 604 houses. At a density of 2.3 this is only 552 houses. Therefore, almost all of the houses that are really required, based on estimated population growth, can be satisfied from currently outstanding planning permissions and already identified urban potential (large brownfield) sites without the need to encroach on any greenfield land.
So far as the Ipswich Policy Area is concerned, the population increase is predicted to be 2376 people, which gives a need for 1131 houses (or 1033), and not 2000 as claimed.
(*1) "Appropriate Assessment for Suffolk Coastal District Council Core Strategy and Development Management Policies - 21 September 2009" prepared by The Landscape Partnership - Page 13
The Accuracy Of The Housing Need Figures In late 2006 and early 2007 the claim was made by the LDF-TG that 2700 houses needed to be built on greenfield land up to the year 2021. At that time STAG pointed out, in a meeting with Messrs Smith, Ridley and Brown and then in our detailed consultation submission, that the evidence base for house completions, outstanding planning permissions and brownfield land availability was based on actual historical numbers as at 1 April 2004 and the claimed need to build 2700 houses was seriously overstated to the extent that historical figures had changed since 1 April 2004. Our warnings were ignored, even though a Freedom Of Information request substantially proved our point. The evidence base was updated as at 1 April 2007, right in the middle of the consultation and STAG were proved to have been correct in our warnings. When the figure of 2700 houses claimed to be needed up to 2021 was adjusted by the houses built from 1 April 2004 to 1 April 2007, plus the latest figure for outstanding planning permissions, plus a more up to date survey of brownfield land availability the real need up to 2021 was shown to be zero! The figure of 1700 houses which the LDF-TG then claimed were needed to be build was only obtained by extending the LDF period from 2021 to 2025.
The same situation applies today because actual houses built since 1 April 2007, currently outstanding planning permissions and brownfield land availability are all scheduled to be reassessed as at 1 April 2010. Therefore it is entirely probable that the supposed need for 1000 and 2000 houses (or 604/552 and 1131/1033) could be substantially reduced by houses built since 1 April 2007, currently outstanding planning permissions and the latest figures for brownfield land availability.
Erosion Of Stated SCDC Policy On Affordable Homes The need for affordable homes has always been one of the major - and most persuasive - justifications for building large numbers of new houses all across the District. Indeed, at a public meeting in Trimley St Martin on 14 March 2007 Philip Ridley stated: "The council adopted a policy in April last year where we lowered the threshold for affordable housing, which is something the council should take great credit for. One third of all new dwellings across the district will be affordable on schemes of over 3 in size in villages and 6 in towns. The national policy is 15 and 25. We brought these thresholds down so we can deliver more affordable housing for the needs of this district as a whole and that policy is proving to be very successful for the last year."
However, at the last LDF-TG Meeting Councillor Snell stated - without any denial from council officials - that it would be uneconomic for developers to provide such large numbers of affordable homes
Councillor Snell's statement was categorically contradicted at a drop-in session held in Felixstowe Town Hall on 3 November 2009 when Philip Ridley and Hilary Hanslip both confirmed - without caveat or qualification - that the figure for affordable homes was still 33%.
A report in the Evening Star also seems to contradict the comments made on 15 October by Councillor Snell: "A Suffolk Coastal spokesman said the council had been approached by developers asking to renegotiate legal agreements. 'Their requests reflects the problems affecting builders across the country caused by the ongoing recession and it is an issue that the council will be considering, but this will have no impact on the current affordable housing policies as laid out in the Local Development Framework consultation document,' he said."
Once again, however, stakeholders have to look at documents which "they" don't want us to consider, and which have not been publicised, in order to get at the real truth - there is now absolutely no fixed policy with regard to the provision of affordable homes.
The actual policy is as follows (*2):
(a) Felixstowe :"Sustainable mix of housing types may include some affordable housing." (b) Ipswich and Woodbridge are just the same: "Sustainable mix of housing types may include some affordable housing." (c) Aldeburgh and Framlingham have no affordable homes policy - so they probably won't get any. (d) There are only two places in the whole of the District where affordable homes will definitely be built - Leiston and Saxmundham - where it says "Affordable housing provision prioritised" But no actual housing numbers have been specified.
This complete reversal in affordable homes policy has - shamefully - received absolutely no publicity and is not mentioned in any of the LDF Consultation Summary Documents.
(*2) September 2009 Consultation Document "Sustainability Appraisal Of Core Strategy And Development Management Policies" page 5 onwards - Objective Number 4 "To Reduce Poverty And Social Exclusion"
Brownfield Land As part of the housing survey which is due to take place as at 1 April 2010 an assessment of brownfield land will be made. It is now known that both the Deben and Orwell High schools will close, thus releasing brownfield land for possible housebuilding purposes. According to the David Lock Study, depending on housing densities these sites could accommodate between 118 and 179 (Deben) and 336 and 510 houses (Orwell).
Additionally, there is an increasing recognition of the need to preserve land for food growing purposes and for this reason we believe that sites identified by David Lock, but subsequently rejected because of supposed flood risk, should be seriously reconsidered, for example - Peewit/Felixstowe Beach Caravan Parks (313 - 476 houses) and Suffolk Sands (204 - 310 houses).
Traffic Issues SCDC have commissioned a study from AECOM, entitled "Proposed Strategy Transport Appraisal" dated September 2009. Paragraph 8.4 states, with reference to Felixstowe and the Trimleys: "Expected vehicle trip generation and distribution has shown that the number of additional trips on the trunk road network will be modest in comparison to the existing levels of traffic, and would be unlikely to have a material impact on the operation of any trunk road junctions."
We cannot believe that the cumulative traffic impact of 1000 new houses around Felixstowe, plus 2000 extra houses at Martlesham, plus 6000 houses east of Ipswich, plus doubling of the number of Port-related lorries, plus 8000 new jobs, plus regeneration of Felixstowe as a leisure resort, plus SnOasis, plus Sizewell "will be modest in comparison to existing levels of traffic."
(It should also be borne in mind that a possible Tesco Superstore in Walton could also now be legitimately brought into the equation.)
In addition, the Frequently Asked Questions Document issued as part of the current LDF consultation states at Paragraph 8: "What impact will all of these houses have on local infrastructure, roads, education, health, etc? None of these studies show that the scales of development proposed and the distribution suggested cannot be accommodated."
This statement is highly misleading because it does not make clear the serious limitations of the AECOM study with regard to its scope and the sources of traffic considered. For example, AECOM largely looks at A14 junctions, but has not studied all of them. In addition, and even more seriously AECOM have not considered the impact of extra traffic on the Orwell Bridge or traffic flows along the A14 itself.
The Felixstowe Port Logistics Study Final Report For Suffolk Coastal District Council, dated September 2008, by GHK In Association With Royal Haskoning states at Annex D5: "The Highways Agency ... estimated the Orwell Bridge to be operating at 83% capacity in 2004 with demand forecast to increase to 90% in 2009 and 98% in 2014."
This 98% capacity leaves no room for error and does not take account of the substantial extra traffic which will be generated from the items noted above.
Annex D5 also stated: "Problems of congestion affecting the Orwell Bridge are thought to effect over 100000 people and, significantly, 12000 goods vehicles per day, including virtually all traffic to and from the Port Of Felixstowe."
At a Planning Appeal heard in May 2007 by Planning Inspector Michael Ellison, SCDC tried to close down the Orwell Crossing Lorry Park on the grounds that it was a venue in its own right, and that the A14 could not cope with traffic travelling specifically to this establishment as a destination. Paragraph 24 states: "Evidence was accepted at the Felixstowe Port Inquiry that the section of the A14 between the Port and the Copdock Interchange with the A12, some 10 km to the west of the appeal site [Orwell Crossing], was already operating at capacity."
Paragraph 42 stated: "The maximum sustainable hourly throughput for the A14 eastbound is 1500 vehicles per lane per hour. That level of traffic is currently exceeded in the weekday morning peak between 0800 and 0900. It is almost reached in the weekday evening peak between 1800 and 1900."
Paragraph 38 stated: "The Highways agency stated that by becoming a destination in its own right, people travelling to the site [Orwell Crossing] who would not otherwise be on the network would place extra pressure on the network, create undesirable traffic movements, and increase the very real probability for accidents to occur."
It must be concluded that if the small numbers of extra vehicles generated by the Orwell Crossing Lorry Park will cause such stress on the A14, then the extra stress caused by traffic generated from 1000 plus 2000 plus 6000 extra houses, plus from 8000 extra jobs, plus double the number of port-related lorries, will surely create stress that is intolerable and unacceptable.
It is disturbing that AECOM have not been asked to consider these matters and that SCDC have not publicised them. This, therefore, surely destroys the credibility of the AECOM study and SCDC's conclusions that: "None of these studies show that the scales of development proposed and the distribution suggested cannot be accommodated."
Ian Cowan - STAG Trimley St Martin 17 November 2009
SCDC Response: 1, 3, 4, 10, 11, 12, 22, 25 See also Policies DM1 and DM2
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Sue Hooper [530] Respondent ID: 530 Submission 530 Agent ID: ID: SUBMISSION Objections to the proposed increase in number of houses to be built at Martlesham Heath.
1) I fully support Martlesham Parish Council previous objections to the proposed development at Martlesham Heath. These objections also apply to the new proposal for increase of housing. 2) I understand Suffolk Coastal Area earns a lot of income from the tourist trade, so must be careful not to lose some of its attractive areas around the lovely rivers. 3) I note in the EATD newspaper today that Felixstowe Town Council have thrown out the plans for 1000 plus houses in their area. 4) Suffolk Coastal District Council should look again at their options for future development and go for smaller developments as required using brownfield sites and not good crop growing fields. 5) I note from the ONS new estimates of population for local authorities (Aug 09) that Suffolk Coastal has the largest population and continues to grow at a faster rate than Ipswich Borough.
SCDC Response: 4, 16 Other comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Suffolk Agricultural Association Respondent Name: [544] Submission Agent Respondent ID: 544 ID: 544 ID: Mr Glyn Davies SUBMISSION Dear Sir
Consultation on Core Strategy Housing Distribution - Updated Preferred Option 7/09 Bidwells represents the Suffolk Agricultural Association, owner of Trinity Park (the Suffolk Showground). On behalf of our client, we wish to make the following submission in respect of the Core Strategy Housing Distribution - Updated Preferred Option 7/09.
In general we support the continued identification of the Ipswich Fringe as one of two Major Centres that will be the recipients of a large proportion of the District's overall housing requirements to 2025. We also agree with the approach concerning the use of brownfield sites and making the best use of known "brownfield" development opportunities" before looking to identify new greenfield sites. However, we wish to object to the revised strategy of directing virtually all of the 2,000 new homes within the Ipswich Policy Area to greenfield allocations to the east of the A12 (i.e. land adjacent to Adastral Park) with virtually no allowance elsewhere for alternative types or locations of development.
We do not agree with the findings of the Sustainability Appraisal that this is the most sustainable pattern for future growth in the Ipswich Policy Area and feel that the Council's approach of placing "all its eggs in one basket" is not the hallmark of a sound Development Plan Document, particularly given the uncertainty surrounding the ability of this location to deliver housing during the early part of the plan period.
Guidance produced by the Planning Inspectorate states that a Local Planning Authority should rigorously assess a Development Plan Document before it is published under Regulation 27 to ensure that it is a plan which it considers to be "sound". In order to be found sound the Core Strategy will need to be "effective", which means it must be deliverable, flexible and able to be monitored. Therefore in order for the Core Strategy to pass the soundness test, the Council will need to be sure that housing sites can be confidently delivered in the locations identified in the Updated Preferred Option Housing Distribution.
As the Housing Distribution stands we are unconvinced that the necessary housing sites can be delivered to meet the District's housing growth targets and in particular there would appear to be a lack of robust evidence to counter the real concern that delivery of housing growth on land adjacent to Adastral Park is fettered by planned mineral extraction and requirements for substantial infrastructure improvements, raising doubts over its viability and delivery.
Much of the land proposed for the increased level of housing growth in the Ipswich Policy Area (i.e. 2,000 homes on land adjacent to Adastral Park) has been or is scheduled for mineral extraction. This raises a serious question mark over the ability of land to the East of the A12 to deliver new housing growth particularly during the first 5 year phase of the Core Strategy period, and would not appear to support the proposed increased levels of growth at land to the east of Ipswich as advocated by the Updated Preferred Option.
We consider that in order to ensure a sound Development Plan that is capable of delivering the District's housing growth targets during the early plan period, and ensuring the provision of a 5 year housing supply as required in PPS3, there is a need to identify sites elsewhere within the Ipswich Fringe that are not constrained by infrastructure requirements or planned mineral extraction. However, we do not consider that there is any benefit in locating these additional sites, other than at Martlesham Heath, elsewhere on land to the east of the A12, which would merely exacerbate existing traffic and infrastructure problems in the area that will not be relieved until at least major housing development is underway at Martlesham Heath, which could be at least 10 years away. Development of alternative sites at Martlesham in the short term to overcome the land supply shortage would inevitably in our opinion also require the use of Greenfield land. We would suggest therefore that consideration should also be given to sites that could deliver housing during the early years of the plan period and on their ability to contribute towards the objectives of sustainable development including the use of available "brownfield" development land.
We have already provided the Council with substantive information that part of Trinity Park, which is classified as a "brownfield" site, could be developed to deliver housing growth within the Ipswich Fringe during the early years of the plan period, without the need for significant infrastructure improvements (please refer to letter to Stephen Brown dated 18th July 2008 containing detailed planning, landscape and transportation information; further copy attached). The proposed site is on the edge of the existing settlement, close to local facilities and employment opportunities, and readily available for redevelopment given the Association's plans for the enhancement of the Showground at Trinity Park to develop the County Show and its other charitable activities at this location. We are very surprised and disappointed therefore to learn from the updated preferred option consultation, that this information has not been taken on board and that the level of potential brownfield housing listed in Table 1 of Appendix 4 is substantially less for the whole of the Ipswich Policy Area than the area being suggested for redevelopment at the western edge of Trinity Park (i.e. 220 houses compared to the potential site for 300 plus houses at Trinity Park).
Paragraph 5.10 of the Updated Preferred Option document provides a summary of the responses that have been received in relation to the individual strategies and policies that have been produced for the Major Centres and Towns and describes how these have informed the housing distribution strategy that is now proposed. In summarising these comments the consultation document states inter alia that:
"We should look first to re-developing old "brownfield" sites before identifying new greenfield sites".
This approach is endorsed again at paragraph 5.12 where the document states that one of the underlying objectives for the distribution of housing is to make the best use of known "brownfield" development opportunities.
It therefore follows that the Council should be seeking to identify previously developed sites within the Ipswich Fringe such as at Trinity Park in the first instance rather than allocating new greenfield allocations. However, this does not appear to be the approach that the revised housing distribution is following, which appears to be to develop East of the A12 irrespective of whether there is developable brownfield land available elsewhere in the Ipswich Policy Area. We therefore object to this approach.
In summary, we do not support the "all eggs in one basket" approach of directing all housing growth in the Ipswich Fringe to land east of the A12, particularly given the acknowledged lack of an available 5 year supply of housing land at the present time. We consider that the Council should identify sites elsewhere within the Ipswich Fringe to ensure a range of sites are available that can help to deliver housing growth; and should give consideration to the western part of Trinity Park, as an appropriate brownfield location to meet the housing requirements of the Ipswich Policy Area, particularly during the early years of the plan period.
We respectfully request that the above comments are given due consideration in your formulation of the "Submission" version of the Core Strategy document and would be grateful if you would keep us informed of future stages in the LDF preparation process.
SCDC Response: 4, 6, 15, 16, 21
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES Suffolk County Council (Michael Respondent Name: Wilks) [382] Submission Agent Respondent ID: 382 ID: 382 ID: SUBMISSION Due to the contrasting approach to development in the Felixstowe peninsula, one of "organic and evolutionary growth", SCC's specific requirements will need to be resolved in response to individual development proposals. However it is important to note that irrespective of the Building Schools for the Future project in Felixstowe, contributions will be sought from new development for secondary school places. Although BSF will consider future pupil yields, the potential capacity in the new school will not be realised until development comes forward and that development will need to fund these future places.
A clear strategy for securing developer contributions will be required to ensure that the policy of incremental and dispersed development does not jeopardise the delivery of the necessary infrastructure (physical and community). Contributions will need to be secured from development over a range of scales and at a level that is sufficient to fund the said infrastructure, but without jeopardising the overall delivery of housing and with it affordable housing.
SCC notes in para 7.04, SCDC's objective of delivering a link road between Candlet Road and the High Road. This is not currently an objective of SCC, as highways authority. The case for any access to/egress from Candlet Road would need to be evaluated on grounds of acceptability/sustainablity, safety and capacity.
Pending further assessment, there is currently considerable concern as to whether acceptable access from/egress to Candlet Road can be achieved. Furthermore, there is a significant risk of any through road acting as a "rat-run" for the significant number of dwellings immediately west of the A14 and indeed for those immediately adjacent to the east of the site. If a satisfactory solution cannot be realised with regard to access from/egress to Candlet Road, it is likely the capacity of the site will need to be reduced so that there is not an unacceptable impact on High Street and High Road. The development strategy for Felixstowe should not assume a given level of development in this location in advance of a full transport assessment endorsed by SCC.
SCDC Response: 22, 25, 26
IPSWICH POLICY AREA Suffolk County Council (Michael Respondent Name: Wilks) [382] Submission Agent Respondent ID: 382 ID: 382 ID: SUBMISSION SCC notes that the strategic allocation in the Ipswich Policy Area - East of the A12 is now specified as "to south and east of Adastral Park" (p13). This is SCC's preferred location for a new secondary school, thus any development here would need to be planned with this ambition in mind.
A significant priority for development in this location should be for strong links to be forged with the existing residential area, local communities and the adjacent employment sites. In order for development of 2,000 homes in this location to be acceptable, SCC, as Mineral and Waste Planning Authority, Local Transport Authority and Service Provider has the following requirements:
1. Minerals
Development should be compatible with the planned minerals extraction in this area. Two sites in SCC's Minerals Site Specific Allocations Local Development Document lie within the boundary of this strategic allocation. Each of the two sites is estimated to contain a mineral reserve of 1 million tonnes, part of an overall plan allocation of just over 10 million tonnes for the period up to 2021. Any development here could therefore affect planned mineral reserves of strategic significance. Ideally, any development should be phased in such a way as to ensure that any sterilisation of mineral resources would be kept to a minimum, and to allow for the full reserve to be extracted if possible.
2. Transport
Any development here would raise significant transport issues, including the challenge of providing sustainable transport infrastructure and services and managing the impact of additional traffic generation on the local road network. Significant expenditure on highway works would be required, including signalisation and conversion to crossroads of the three roundabouts on the A12 in the vicinity of Adastral Park and also signalisation of the A12/A14 Seven Hills junction. The proposed junction improvements would need to function in an acceptable way, reflecting the strategic importance of this route linking Lowestoft and East Suffolk to the strategic road network. Furthermore any internal roads in subsequent development should not encourage "rat running" through the site in order to bypass any congestion on the A12. A significant modal shift would be required in commuting patterns. In addition to the following improvements to sustainable transport infrastructure, a Travel Plan would need to be prepared. Bus priority measures would be required at the Foxhall Road/A12/Newbourne Road junction as well as at Barrack Road. Measures to support public transport operations in the A1214 and Foxhall Road corridors would also be necessary Funding contributions towards the improvement of the local public rights of way network, which may include additional crossings of the A12 to better connect existing and new housing with services, education and employment will be needed.
3. Service Provision a. Education 2,000 homes "south and east of Adastral Park" would be expected to generate a demand for 105 pre-school, 490 primary school and 420 secondary school places. SCC would expect that all education needs arising from any development would be met through provision of services on an appropriate site within this location. SCC would expect provision of land and building at no cost to SCC for at least one primary school and contributions towards pre-school education. As there is neither sufficient places nor scope for expansion at the nearby secondary schools to accommodate the anticipated number of pupils of this age, SCC needs to secure a secondary school site in the east of Ipswich to cater for future demand for secondary school places, including that which arises as a result of any development in this strategic allocation. Independent consultants have concluded that (an extended) Adastral Park is the most suitable location, due to the potential to create an education campus as part of a community hub and to create the optimum catchment area. SCC believes there would be increased educational value, through the sharing of teaching expertise and co-operation over transfer of pupils from primary to secondary school. Many facilities could also be shared by both schools, such as playing fields, ICT spaces and halls, potentially reducing land requirements by 20%. There would also be increased cost effectiveness in the construction of both schools together. SCC recognises that demand for secondary school places arising from development solely at this location is unlikely to require the provision of a full secondary school immediately. However SCC does not wish the opportunity for provision to be prejudiced in the longer term, thus the layout of any development in this location should allow for future delivery. This will require thoughtful siting of the primary education site and proposed open space and will need to have regard to the phasing of mineral extraction. SCC would require provision of land and contribution of build costs for a full secondary school, commensurate with the level of development forthcoming. b. Waste Standard developer contribution towards waste disposal facilities would be sought, and additional capacity may need to be provided at Foxhall Household Waste Recycling Centre, or any subsequent site serving this location. SCC would require that recycling facilities should be provided within any development at the expense of the developer(s). c. Libraries Development of this scale could be expected to increase te local population by around 4,800, which would justify the provision of a new library of some 150 - 250 sq metres, centrally located within any development and ideally integrated with school, health or retail facilities. d. Very Sheltered Housing While SCC's policy is to support people within their own homes as long as possible, there will be a need for provision of supported housing as part of major development where there is inadequate provision in the locality. A proportion of the affordable housing requirement, as determined by local need, should be provided for as Very Sheltered Housing. e. Fire Service New Fire Service provision could be required in due course. Further risk assessments are being made and appropriate contributions towards any such provision would be sought from future developers under the terms of a s106 agreement.
4. Other matters Any development in this location will contribute to the deficit of green infrastructure in the locality. It is therefore likely a significant contribution will be required to cater for the needs of the future inhabitants of this development in order to mitigate impact on the nearby European designated sites due to increased recreational pressure. Extensive strategic landscaping will also be needed given the proximity of the Suffolk Coast and Heaths Area of Outstanding Natural Beauty. There are a number of features of archaeological interest in this location including two barrows which are Scheduled Ancient Monuments. Provision for in-situ preservation of archaeological remains should be made where appropriate. In consideration of the adjacent employment uses and the proposed scale of development in this location, there is a clear opportunity for a renewable and/or decentralised energy network. The development should aim to be very low carbon.
SCDC Response: 18, 19, 29 Other comments noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Suffolk County Council (Mrs Respondent Name: Patricia O'Brien) [103] Submission Agent Respondent ID: 103 ID: 103 ID: SUBMISSION Once again as County Councillor for Martlesham Division and District Councillor for Nacton Ward, I respond to proposals to site housing at Adastral Park. My previous letters of 15th March '07, October 24th '08 and May 1st '09 object, in the strongest terms, to development at Martlesham. I reiterate the sentiments previously expressed, and in addition, comment on the revised LDF proposals to site 1000 houses in Felixstowe ( instead of the original 1600) and 2000 at Martelsham ( instead of the original 1050) to which I most strongly object.
I must confess to total bemusement at SCDC's reasons for reducing the numbers of houses in Felixstowe and increasing those at Martlesham.
The Updated Preferred Option document is being put forward to address concerns raised by the Preferred Optiion document of 12/08 and "to recognise other changes in circumstances". What are these "other changes in circumstances"? These "other changes" are not listed and could be pertinent to this revised consultation. (Updated Preferred Option para 2.02. p1)
SCDC states that studies and evidence have been accumulated to ensure "any decision in relation to new development is soundly made". The evidence includes an independent study of Felixstowe by David Long & Associates. (Updated Preferred Option para3.04. p3) There is no independent study of Martlesham, yet Martlesham is the preferred option for the largest housing development in Suffolk Coastal for at least a decade!
One of SCDC's justifications for reducing the numbers of houses in Felixstowe is by citing the financial crisis, recession and the slow down of the rate of expansion of the Port of Felixstowe;that this will have a negative effect on jobs, thus reducing the need for greater numbers of houses. (Udated Preferred Option para1 p9) However, SCDC fails to acknowledge that the economic slow down is also affecting Martlesham's major employer, BT. BT has axed 10,000 jobs and has asked its staff to take a 75% pay cut in return for long-term holidays, to help the company to ride out the recession. These are not the actions of a beacon of growth.
Much emphasis is placed on employment at Martlesham as a reason for increasing housing numbers. I would argue that the employment capabilities of a major employer are not a sound basis on which to risk any future large development. In these uncertain times there is no guarantee that the major employer will not constrict his operation or re-locate.
I would like to focus on three main concerns, traffic, education and the impact on villages in my Ward. SCDC states that with the improvements at the Dock Spur Roundabout and the Copdock Interchange the A14 "will be able to cope" ( Updated Preferred Option - Council's response p3 para 3)with the increased volume of HGVs and that the reduced numbers of homes in Felixstowe will reduce the impact on the A14 !! I find it bizarre that SCDC is prepared to accept improvements that "will cope" with the extra 1ml. containers.
The Sustainability Appraisal admits that development at Martlesham will "increase traffic considerably in an area that is already congested" and the Assessment Summary states at Adastral Park was "the worst site for congestion"( Policy Sp 20 p6/7).Having acknowledged that Adastral Park is heavily congested, what measures are proposed to reduce congestion? The answer, junctions are to be improved and traffic lights at the roundabouts on the A12 between Martlesham and Seven Hill Roundabout. I fear this will only add to the long queues, already existing at peak times, and to the frustration of motorists.
There is no mention of the Orwell Bridge and the Seven Hill roundabout. Any solutions to the management of traffic must take into consideration the problems that already exist, not only on A14/A12 but also Seven Hills and the Orwell Bridge. Improving the Dock Spur Roundabout and the Copdock Interchange are welcomed but serious improvements are needed to the Orwell Crossing, now! The Atkins report of 2004, into the capacity of A14 at Seven Hills, Nacton Interchange and the Orwell Bridge, showed near capacity at peak times, together with queuing problems. Five years on the problems are markedly worse and nothing has been done. Factor in 2000 homes at Martlesham and the scenario for the inhabitants of my division is bleak. The solution, another bridge or tunnel, which should have been envisaged a decade ago, would be too late, even if there was the will. The Sustainability Appraisal seriously believes that the traffic problems can all be solved by more footpaths, cycle routes and the use of Park & Ride. I have no such faith.
The provision of secondary /6th form education is a considerable problem for Martlesham. The evidence states "the capacity of Kesgrave High School is expected to be exceeded in Phase 1". (Updated Preferred Options App 1 p16) Kesgrave High School is already up to capacity. This year 9 pupils from my Ward failed to gain places at Kesgrave High School.
2000 homes would generate only 350 pupils; this would be totally insufficient to provide for a new high school. The numbers of pupils needed to create a new high school, and make it viable, is between 900-1200 pupils. Provision of education is not the simple exercise as envisaged in the evidence. Account needs to be taken of the transformational changes taking place in education in Suffolk. Projects such as: Building Schools for the future, £600m of government money to rebuild or refurbish secondary schools; School Organisation Review, raising attainment, ambitions for Suffolk pupils and moving from a mixed system of two and three tier education to two tier, in line with the rest of the country; providing new facilities within 'hub' schools for children with Special Needs; - the 14-19 agenda whereby each pupil will have access to 17 diploma courses by 2013. A huge programme of developments and one in which any proposal for a new secondary school would have to be linked to. Further, the County Council's policy on new 6th forms is for a minimum of 200 pupils; 2000 homes would generate 70 pupils aged 16-19.
The building of 2000 houses at Martlesham would have a huge impact on the villages in my division. SCDC turned down an application for 184 log cabins, opposite the proposed Adastral Park site, because of the impact of visitors upon the nearby village of Waldringfield. Yet SCDC offers little in the way of mitigation in relation to vastly increased numbers of visitors. It believes that the numbers of people, such a development would bring, will "actually create the opportunity to provide for a more self contained development".( Updated Preferred Option - Council's response to increased numbers p11 para 3). SCDC states that "larger development has the opportunity to provide for a more meaningful (!) set of mitigation measures which can limit the impact of development on the nearby AONB" (Updated Preferred Option - Council's response p12,conclusion). Does SCDC believe that the future residents of the new development would be so self- contained that they would have no desire to explore the delights of villages such as Waldringfield, Levington, Nacton, that all their needs would be met on site? I think it unlikely.
No amount of landscaping, tree planting and the creation of open space for dog walkers ( open space that by 2025 could be used for 1,000 more homes) will mitigate against the spoliation of the countryside, the loss of character and ambience of a charming corner of Suffolk.
SCDC Response: 7, 11, 12, 15, 16, 17, 18, 19, 20
1 INTRODUCTION Suffolk Primary Care NHS Trust Respondent Name: [122] Submission Agent Respondent ID: 122 ID: 122 ID: Mrs Aarti O'Leary SUBMISSION The proposed housing strategy needs to be supported by a policy context that requires suitable health care infrastructure to be provided & phased accordingly. In the absence of such a policy basis, the Trust objects to the Core Strategy on the grounds that the plan may not be the most appropriate strategy & would therefore be 'unsound' See attached letter for additional details.
SCDC Response: 20
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009 Suffolk Wildlife Trust (Dr Respondent Name: Simone Bullion) [178] Submission Agent Respondent ID: 178 ID: 178 ID: SUBMISSION We note in 7.2.8 that a new country park is proposed for north or north-east Ipswich, possibly in the Martlesham area. Whilst this will provide a facility for people in this area, it will not address the needs of housing growth in the Felixstowe/Walton and Trimley Area. We note in 7.2.5 that improvements need to be made to accessibility of greenspace provision. This does not match with what is being said in 6.2.43 which uses the phrase 'adequate greenspace provision' (rather than access to it). Mitigation therefore needs to include new greenspace provision for the 1000 new homes in this area as well as improvements in access.
SCDC Response: 23 Other comments noted
THE OVERALL STRATEGY Suffolk Wildlife Trust (Dr Respondent Name: Simone Bullion) [178] Submission Agent Respondent ID: 178 ID: 178 ID: SUBMISSION Re 'Proposed housing numbers at Felixstowe/Walton and the Trimley villages to be managed, the scale and pace of development only increasing in order to achieve social and economic objectives for the town' - This should also reflect environmental objectives in accordance with the principles of sustainable development
SCDC Response: Noted
FELIXSTOWE/WALTON AND THE TRIMLEY VILLAGES Suffolk Wildlife Trust (Dr Respondent Name: Simone Bullion) [178] Submission Agent Respondent ID: 178 ID: 178 ID: SUBMISSION There is no mention of the requirement for green infrastructure. The Appropriate Assessment indicates that impacts upon the Stour & Orwell SPA would be limited if 'accessibility to greenspace provision is adequate'. This principle should therefore be embedded within the Housing Distribution - Updated Preferred Option.
SCDC Response: Noted
IPSWICH POLICY AREA Suffolk Wildlife Trust (Dr Respondent Name: Simone Bullion) [178] Submission Agent Respondent ID: 178 ID: 178 ID: SUBMISSION There is no mention of the requirement for green infrastructure to support this level of housing growth. The Appropriate Assessment indicates that accessibility to greenspace provision is a key element in limiting impacts upon the Deben SPA. This principle should therefore be embedded within the Housing Distribution Preferred Options document.
SCDC Response: Noted
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009 Suffolk Wildlife Trust (Dr Respondent Name: Simone Bullion) [178] Submission Agent Respondent ID: 178 ID: 178 ID: SUBMISSION With reference to 6.2.26, regarding the Deben estuary-side path in poor repair, the impacts of access to this area will need to be reviewed in view of the contents of the Marine and Coastal Access Bill 2009, soon to be an Act of Parliament.
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Susan Pike [517] Submission Agent Respondent ID: 517 ID: 517 ID: SUBMISSION Dear Sir
I would like to VERY strongly object to your proposals to build a new town to the rear of the current site owned by BT at Adastral Park.
As a resident of the original village of Martlesham, we choose to live here due to the relatively rural location. We did not want to live in a town nor do we want a new town built on our doorstep which will bring with it many problems. I fully realise that there is a need to build additional housing in Suffolk but why spoil the lovely countryside which we currently are able to enjoy right on our doorstep? Surely there are other areas which would benefit from regeneration such as Leiston for example. This is a thoroughly miserable and run down location which would benefit from investment. Have you even considered this location? I am sure that the local people would likely welcome this.
I appreciate that you propose to improve the infrastructure with regards to the current road system but this will bring with it many other problems such a noise and light pollution. Our roads are already very congested and it is already extremely difficult to access and exit the village of Martlesham Heath at off peak times let alone during the rush hour.
I hope that I am not a voice crying in the wilderness. I am aware that there are many like-minded people with this same plea.
PLEASE WILL YOU THINK AGAIN AND TURN DOWN THIS PLANNING APPLICATION.
SCDC Response: 4, 11, 17, 19
HOUSING DISTRIBUTION EAST OF IPSWICH Sutton Parish Council (Mrs Jane Respondent Name: King) [113] Submission Agent Respondent ID: 113 ID: 113 ID: SUBMISSION Dear Sir
I am writing on behalf of Sutton Parish Council who would like to register their strong objection to the proposed additional housing at Martlesham, Suffolk.
Our reasons for doing this are as follows: The area around Martlesham is already extremely congested at peak times and further development would only add to this problem. We also feel that there would be an increase in tourist traffic from this development travelling through Sutton to get to the coastal village of Bawdsey particularly during the summer months and we feel that any further increase in the volume of traffic would have a detrimental effect on this village. There is a lack of employment currently in this area and we understand that this housing was originally planned to be nearer to Felixstowe where the job opportunities are greater and we feel that this should still be the case. We should be grateful if these views could be taken into consideration when determining these proposals.
SCDC Response: 7, 19 Noted
8 YOUR COMMENTS Swilland & Witnesham PC (Mr Respondent Name: John Lightfoot) [252] Submission Agent Respondent ID: 252 ID: 252 ID: SUBMISSION Swilland Witnesham Parish Council note the changes in the LDF (23rd Sept.2009) Consultation document. It seems that: 1) the housing targets are unchanged 2) the distribution changes are essentially about building fewer houses at Felixtowe and 3) the numbers proposed for Martlesham are correspondingly increased 4) there are some very minor changes to the allocation of some settlements as Key/Local service Centres
Thus, we can not identify anything of direct concern for this Parish Council.
John Lightfoot Chairman
SCDC Response: Noted
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: T. Wright [296] Submission Agent Respondent ID: 296 ID: 296 ID: SUBMISSION I wish to register my strong opposition to the SCDC and BT plan to build a new housing estate adjacent to Martlesham Heath. The impact on this area would be devastating with increased traffic volume on already congested roads. Try getting across the A12 from Eagle Way in the rush hour.
Should this proposal go ahead this area will become a faceless, characterless, gigantic bland housing estate. Just look at Grange Farm and the rambling faceless Kesgrave Estates to see what I mean.
I moved to Suffolk 11 years ago to get away from the overcrowded, motorway riven area of South East Kent - I am beginning to think I should have stayed put.
SCDC Response: 16, 17, 18, 19
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS
Respondent Name: Terry Duffell [286] Submission Agent Respondent ID: 286 ID: 286 ID: SUBMISSION I wish to register my profound concern regarding the proposal to increase the number of dwellings on Adastral Park, for I am convinced that such an initiative will make a substantial impact on the area and lead to extensive negative effects for the locality.
In short, my concerns are as follows:
The new development will not be self-contained in the sense that a substantial proportion of the population will need to travel to work or school, overloading an already stretched public transport system and adding significantly to the congestion already experienced; The proposal to upgrade the road system will be insufficient to cope with the increased traffic; That such a system will alter fundamentally the character of the area, and, to my estimation, involve the use of land that is currently controlled by the population of Martlesham Heath; That an area that is recognised for its beauty and rural character will be devastated by such a development, altering fundamentally the nature of the Waldringfield locality; I regard the current position of initiating a huge development in one area, rather than spread the houses around the Suffolk Coastal area is not conducive to economic development and is regarded as an easy option.
I trust these concerns will be taken into consideration when the submission is scrutinised,
SCDC Response: 11, 16, 17, 18, 19, 20
IPSWICH POLICY AREA - EAST OF A12 - PROPOSAL TO INCREASE THE NUMBERS Tessa & William Catchpole Respondent Name: [469] Submission Agent Respondent ID: 469 ID: 469 ID: SUBMISSION Where will the employment come from for so many? There are numerous flats in Ipswich which have not been sold. The consequences of increased traffic in the villages of Waldringfield, Hemley and Newbourne will be a real threat to nature and wildlife. With numerous brownfield sites surrounding/within Ipswich offering better infrastructure these should be looked at first.
SCDC Response: 7, 15, 17, 19
8 YOUR COMMENTS The Coal Authority (Miss Respondent Name: Rachael Bust) [51] Submission Agent Respondent ID: 51 ID: 51 ID: SUBMISSION Thank you for consulting The Coal Authority on the above.
Having reviewed your document, I confirm that we have no specific comments to make on this document at this stage.
We look forward to receiving your emerging planning policy related documents; preferably in an electronic format. For your information, we can receive documents via our generic email address [email protected], on a CD/DVD, or a simple hyperlink which is emailed to our generic email address and links to the document on your website.
Alternatively, please mark all paper consultation documents and correspondence for the attention of the Planning and Local Authority Liaison Department.
Should you require any assistance please contact a member of Planning and Local Authority Liaison at The Coal Authority on our departmental direct line.
SCDC Response: Noted
THE OVERALL STRATEGY The Environment Agency (Mr Respondent Name: Andrew Hunter) [543] Submission Agent Respondent ID: 543 ID: 543 ID: SUBMISSION Suffolk Coastal Local Development Framework Core Strategy & Development Management Policies Housing Distribution - Updated Preferred Option 7/09 Sustainability Appraisal Appropriate Assessment
We refer to your letter dated 23rd September 2009 which enclosed copies of the above consultation documents. We apologise for the delay in responding, due to an oversight of the writer's part, and trust that our comments will still be taken into account. We have perused the documents and have the following comments.
Housing Distribution - Updated Preferred Options
We have no objection in principle to the proposed housing distribution across the Council's area. We concur with the proposed concentration of development at the larger settlements where most people already live and work and where facilities and services are located. This appears to be a rational approach and fits in with the principle of sustainability. Some of the comments made under the infrastructure section in appendix 1 to the housing distribution document give, allegedly, a rather simplistic and, to a lesser degree, a misleading impression of water supply and waste water treatment capacity issues. Therefore, the thrust of our comments concern matters of supporting infrastructure, particularly the timing of infrastructure and how such timing fits in with the phasing of residential development under the proposed housing distribution.
Notwithstanding the intention to phase house building between 2009 to 2025, as mentioned in paragraph 4.04, there will be a need to ensure water supply and sewage infrastructure, i.e. sewage treatment works and sewer networks, is upgraded so that there is adequate capacity to cope with proposed housing development, particularly in relation to the substantial proposals for the Ipswich Policy Area, Felixstowe and east of the A12 at Martlesham. On these matters, we note that the baseline evidence for the Housing Distribution consultation document appears to be based on the Haven Gateway Water Cycle Study Stage 1 Report, which was published in 2008 and which took a broad brush approach. However, more detailed assessment work of both water supply areas and individual sewage treatment works has since been carried out and the findings presented in the Stage 2 Report. A draft Stage 2 Report was published in June 2009 and following comments on this report by the Environment Agency and Anglian Water, further work was carried out and a final version of the Stage 2 Report published in mid September 2009. It is expected that a 'caveat' will be added to the Stage 2 Report final version which incorporates additional comments on this report by the Environment Agency and Anglian Water Services (AWS). The Stage 2 Report final version should be available shortly.
The findings of the more detailed assessment work of the Stage 2 Report final version indicate that the water supply and wastewater infrastructure capacity issues discussed below will need to be addressed in order that the issues concerned do not act as barriers to the development proposals in the housing distribution document.
Water supply
Contrary to the comments made in relation to water supply in the infrastructure section in appendix 1, it is too simplistic to state that all growth options almost certainly have sufficient capacity to supply the required potable water supply. The Water Cycle Study (WCS) provides a timeline - see Table 8.1 - of preferred water resources activities for the Ipswich and Woodbridge planning [water] zones. In other words, the provision of adequate water supply for future development is dependent on options detailed in the AWS Water plans being carried out. These options are scheduled to take place in the AMP5 and AMP6 periods. Any slippages in the work programme or refusal of investment by Ofwat could affect the timing of developments, particularly those of a large scale. The Council should liaise with AWS to ensure that the options will be carried out in accordance with the expected programme. As the water supply network was not the subject of any review work, we would also recommend that the Council should discuss this aspect with AWS so as to ensure it is confident that there are no issues or problems that would present a barrier to development.
Waste water infrastructure
The findings presented in the Stage 2 Report demonstrate that there are capacity issues in terms of combined residential and employment development for the sewage treatment works that serve Cliff Quay, Felixstowe and Martlesham as well as capacity issues for the sewer networks in the Ipswich Policy Area, Felixstowe and the Trimleys, and Woodbridge and Martlesham development areas. Comments on the sewage treatment capacity issues which draw on the WCS are given below.
Cliff Quay STW The WCS shows Cliff Quay with a lack of headroom to cope with the projected growth of both housing and employment over the study period and therefore it is categorised as 'red'. On the basis of the planned development Cliff Quay will exceed its consent in 2014/15, reaching a maximum of almost 29% exceedance by 2020/21. However, the position improves when employment development is removed from the equation and it then falls to be categorised as 'amber'. The WCS states that AWS have identified the main problems and restrictions in the system as being related to the volume of surface water discharge entering their combined sewer systems, resulting in flooding and the underperformance of a Sludge Treatment Centre which impacts heavily on the STW. AWS consider the Sludge Treatment Centre to be the main limiting factor to the STW and therefore propose to replace it within AMP5 which they claim will enable the STW to continue within the existing flow and sanitary consent parameters until 2021 and beyond. AWS go on to state that a long term potential strategy for the STW catchment announced by it is a potential diversion of flows to the neighbouring Sproughton STW. However, as identified in the WCS, this STW is under pressure from the proposed development indicating that without expansion or improvement it is unlikely to be to accept an increase in flows. In the light of the previous comments on Cliff Quay and the sewer network, any proposals to transfer wastewater from STWs else to Cliff Quay will require further investigation and discussions with AWS.
Felixstowe and Trimley STW According to modelling work reported in the WCS, the current consent will be exceeded by 2010/11 and this will continue to increase in the future. Therefore, in order to accommodate planned growth, an increase in consented discharge may be necessary. Further detailed future assessment in relation to the Water Framework Directive classifications could enable the derivation of indicative consent (concentration) limits which would be required to achieve these standards and will further inform decisions as to whether technological solutions will be sufficient to accommodate growth in the Felixstowe area. On the basis of combined residential and employment growth, an increase in the consented discharge volume is required.
The WCS concludes that this STW has the capacity to accommodate all the proposed residential development. However, the projections which incorporate employment development show the capacity of the discharge consent being exceeded as early as 2010/11. The majority of the employment development within this catchment relates to the redevelopment of the port (expansion of dock area?) and should have a smaller impact on the STW than reported in the WCS. Further investigation and analysis should ideally be carried out before development takes place. Any new business park arising out of the port expansion could however increase the level of impact. The capacity problems highlighted by the WCS can be overcome through the investment in, and implementation of, BATNEEC technologies throughout the planning period. Further discussion with AWS is essential.
The WCS states that further analysis will also be required to assess the capacity of the sewer network and whether upgrade, and therefore investment, is required for the development to proceed.
Woodbridge and Martlesham STW This STW serves a large population, encompassing the major settlements of Woodbridge and Martlesham and the villages of Newbourne and Waldringfield. Although this STW currently operates with headroom of greater than 50%, it is predicted to exceed its consent in 2010/11 when both the employment and residential development projections are taken into account. The headroom is exceeded by over 167% by the time 2020/21 is reached. However, according to the WCS, if the employment is removed from the equation, the STW retains of headroom greater than 20% throughout the planning period, reaching a minimum of 50.3% in 2020/21.
The findings of the WCS indicate that the Woodbridge and Martlesham STW has capacity to accept the additional flows from the proposed residential development but not from the employment development. If the proposed growth takes place, this will need to be accompanied by additional investment, upgrade and consent increases. The WCS has also identified capacity issues in the sewer network and again additional investment will be needed in order to upgrade and extend the network.
Other locations for development
We recommend that the Council consults the WCS for comments on STW that serve other potential development areas elsewhere within Suffolk Coastal. Particular regard should be made to:
Benhall STW which serves Saxmundham; Melton STW which serves Melton; Leiston STW which serves Leiston and Sizewell (increases in capacity required for workforce associated with potential nuclear new build at Sizewell C?); Aldeburgh sewer network has been identified as having capacity issues.
Conclusions This brief commentary on the findings of the WCS has concentrated on capacity issues for both STWs and, to a lesser degree, the sewer network. We have not gone into any detail on the environmental considerations. The WCS sets out potential impacts on conservation sites that are within areas that receive treated effluent from the STWs discussed in this consultation response. For ease of reference, the names of the STWs, the receiving water and the conservation sites concerned are listed in Table 1.
The comments made in the WCS on the impact of development under the heading 'Environmental considerations' should be discussed further with Natural England in order to establish their position on whether or not assessment under the Habitats Regulations is required. The Area Environment Planning team in the Environment Agency provides the local lead contact on water quality aspects of River Basin
Table 1 Name of STW Receiving water Conservation site designation Cliff Quay STW Orwell Estuary Stour and Orwell Estuaries Ramsar, SPA and SAC Felixstowe & Trimley STW Orwell Estuary Stour and Orwell Estuaries Ramsar, SPA and SAC Woodbridge & Martlesham STW Martlesham Creek Deben Estuary Ramsar & SPA
Management Plans under the Water Framework Directive and in this connection Natural England may wish to seek input from this team on the bearing that increases in consented discharge volumes and technological upgrades to limit pollutant load may have as factors that could lead to positive or negative impacts on the above European sites.
Regional and National Policy Position and Infrastructure Planning
Policy WAT2 of The East of England Plan requires a co-ordinated approach to water supply and waste water treatment to ensure that there is appropriate additional infrastructure for water supply and waste water treatment to cater for the levels of development through this plan. This is so that water resources are not over utilised and that water quality does not deteriorate as a result of the cumulative impacts of development in growth areas. Paragraph 10.9 of The East of England Plan states that in parts of the region, existing waste water treatment infrastructure (sewage treatment works and the associated pipe network) operate at the limits of their current discharge consents. Where capacity limits have been identified and additional infrastructure is required, development may need to be phased to ensure it does not exceed the capacity and/or environmental limits of the infrastructure. We consider that Policy WAT2 needs to be borne in mind when looking the timing of development proposals across Suffolk Coastal as a whole and more specifically for those locations where substantial housing growth is planned.
Planning Policy Statement 23 confirms that the possible adverse effects on water quality, the provision of sewerage and sewage treatment and availability of existing sewage infrastructure are material considerations for planning applications. PPS23 also directs that the precautionary principle applies and here we would consider that where there is reasonable doubt as to the application's proposals to mitigate the risk to water quality, this should warrant further investigation. The onus is on the applicant to do further work.
We would refer you to paragraphs 4.8 to 4.10 in Planning Policy Statement 12 (PPS12) which emphasis, inter alia, the need for infrastructure to support housing growth, the importance of good infrastructure planning, the timescales for infrastructure delivery and that the outcome of the infrastructure planning process should inform the core strategy and should be part of a robust evidence base. Consideration should be given to Paragraph 4.11 of PPS12 which states that infrastructure planning for the core strategy should also include the specific infrastructure requirements of any strategic sites which allocated in it.
Paragraph 4.45 of PPS12 states that core strategies should make it clear how infrastructure which is needed to support the strategy will be provided and that evidence must be strong enough to stand up to independent scrutiny. Furthermore, according to the first bullet point under section 4.45, the core strategy should be based on sound infrastructure delivery planning.
The adequacy of existing infrastructure may well influence the timing of development. Provision of completely new infrastructure in some cases might take several years from identification of need to commissioning; therefore the Council should discuss the possible phasing of development during their discussions with the water company.
Sustainability Appraisal (SA)
With regard to the appraisal of the housing distribution Policies SP1, SP2, SP20, SP21, SP22, SP23, SP24, SP25 and SP26, against SA objective 10 'To maintain and where possible improve water quality', we note that no impact scores have been recorded. It is not clear to us why this is the case as no explanation has been given in the SA document. It would appear that the SA has not been informed by the Haven Gateway Water Cycle Study, particularly with regard to capacity issues at the sewage treatment works and sewer networks that serve the settlements where development growth is proposed. In the light of the information provided within the Haven Gateway Water Cycle Study, we would recommend that the Research & Intelligence Group, who we understand carried out the SA, should re-consider the impact of housing provision on water quality.
Appropriate Assessment (AA)
It would appear that this AA is concerned solely with the impacts of disturbance at European sites from visitors from an increased human population. We were recommend that the consultants, The Landscape Partnership, who carried out the AA should make reference to the Haven Gateway Water Cycle Study for comments on potential impacts on the environment from increased loading at sewage treatment works and sewer networks from additional housing growth over the plan period. This Water Cycle Study recommends, in relation to certain locations, that advice is sought from Natural England on whether assessment is required under the Habitat Regulations.
SCDC Response: Noted
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS The Felixstowe Society (Mr Respondent Name: Philip Johns) [53] Submission Agent Respondent ID: 53 ID: 53 ID: SUBMISSION Dear Sir
The Society welcomes the proposed reduction of new dwellings in Felixstowe and Trimleys from 1600 to1000. However, we still consider this number is too high for local needs and we are against Felixstowe being targetted for major growth. Such growth must be equitably distributed across the whole of Suffolk Coastal District (as allowed under 4.14 in the EERA East of England Plan >2031).
Before any new dwellings are approved, we require assurance on the following points:-
* Full infrastructure will be in place, including utilities, particularly water and sewage. (4.31 in East of England Plan 2031 and 4.61 in Haven Gateway sub-area profile)
* Brownfield sites always take priority over greenfield sites
* That the 5 year pause to review future housing needs remain in place
Felixstowe is on a peninsula linked by a single main road which is already considerably overloaded. The number of new vehicle movements arising from an additional 1000 dwellings will result in unacceptable gridlock. The fact that Felixstowe has a major port should not automatically mean that it is a Designated Growth Point. Storage and support industries to the Port would be better sited at central UK locations because of the improved distribution outlets and also to create new growth opportunities in more deprived areas. Such decisions would alleviate water shortage, safeguard vital agricultural land and reduce the gridlock on the Felixstowe Peninsula. The projections for new jobs in the area are unrealistic. Consideration should be given to what the area can sustain.
All 450 members of this Society have been circulated with details of the LDF proposals and fully support our responses to date.
Yours faithfully
Philip Johns Chairman
SCDC Response: 22, 24, 25, 26
IPSWICH POLICY AREA The National Trust (mrs sian Respondent Name: derbyshire) [204] Submission Agent Respondent ID: 204 ID: 204 ID: SUBMISSION A key element of any action plan/proposal for development in this sensitive location should be recognise the importance of integrating the development into the landscape with reference to its historic significance, visual and other impacts. It should also consider how biodiversity could be enhanced through the appropriate provision of Green Infrastructure. These elements should be recognised as equally important as the "community building" aspects of the proposed development.
SCDC Response: 17 Other comments noted
6 THE COUNCIL'S RESPONSE & REASONS FOR PROPOSED CHANGES TO HOUSING DISTRIBUTION The National Trust (mrs sian Respondent Name: derbyshire) [204] Submission Agent Respondent ID: 204 ID: 204 ID: SUBMISSION The National Trust welcomes the suggestion that the Martlesham proposal will include informal open space sufficient to meet the immediate needs of the development. However it would be desirable to have more specific information about this to be able to assess the potential impact of the development on the recreational resource at Kyson Hill and on the estuary/Sutton Hoo. Also a key element of any proposed development should be to consider the visual impact on the AONB & the estuary and more specifically the unique historic landscape character and sense of place at Sutton Hoo. The proposal should take account of English Heritage & the HCA's Historic Landscape Characterisation Programme.
SCDC Response: Noted
HOUSING DISTRIBUTION EAST OF IPSWICH The National Trust (mrs sian Respondent Name: derbyshire) [204] Submission Agent Respondent ID: 204 ID: 204 ID: SUBMISSION The National Trust wishes to be consulted on any future Action Plan for the proposed Martlesham development. It is clear from recent research that the Suttom Hoo site was carefully chosen for its particular place in the landscape . This is all to do with what can be seen from the mounds and where the mounds can be seen from. In other words this was a landscape of great cultural significance to the Anglo-Saxons. Clearly there are many modern structures and settlements within the 'views' but the landscape is still largely one the Anglo-Saxons would have recognised. This needs to be very carefully considered as a part of a brief/AAP. Consideration needs to be given to what links (transport/education/other)could be established between the development and Sutton Hoo. Also any provision of informal open space should look to extending the areas of BAP target habitat within the area - particularly heathland.A provision for allotments and even small scale market gardens could make a real contribution to a sustainable local food supply.
SCDC Response: Noted
THE MARKET TOWNS Theberton & Eastbridge Parish Respondent Name: Council (Mrs Joan Harvey) [476] Submission Agent Respondent ID: 476 ID: 476 ID: SUBMISSION The Parish Council would like to see the provision for more housing in Leiston before 2020 - 2025 as Sizewell 'C' could be up and running by 2018. If more houses are not registered in Leiston before new build at Sizewell this will result in an increase of traffic passing through Theberton village.
SCDC Response: 4
APPENDIX 1 - LIST OF LDF EVIDENCE BASE STUDIES Trevor Sparkes Consulting Limited (Mr Trevor Sparkes) Respondent Name: [548] Submission Agent Respondent ID: 548 ID: 548 ID: SUBMISSION Suffolk Coastal Local Development Framework Core Strategy & Development Management Policies
Housing Distribution - Updated Preferred Option 7/09
CONSULTATION RESPONSE FROM THE KESGRAVE COVENANT LTD
Our comments, as set out below, on the Updated Preferred Option 7/09, relate to Area 1 to the East of Ipswich.
In our opinion the Updated Preferred Option 7/09 and supporting evidence do not demonstrate adequately that the proposed changes result in the best option for the Area to the East of Ipswich.
We are concerned that:-
* insufficient explanation and justification is given of the change from 1050 to 2000 homes in Area 4 at Martlesham to the east of the A12 and also
* some of the evidence relied upon in reaching the updated preferred option is inaccurate and incomplete, and has failed to take into account previous consultation responses we have submitted, and as a consequence the assessment of Area 1 and its comparison to the other East of Ipswich sites has failed to identify properly all of its relative advantages.
The reasons for our concerns, and hence our comments, are as follows:-
Insufficient explanation/justification
The reason given for the increase in the number of homes in Area 4 at Martlesham east of the A12 from 1050 to 2000 is a consultation comment that 1000 is insufficient to provide a stand-alone community (item 2 on page 12). The only other explanation given is that a larger allocation provides the basis for a significantly improved range of community facilities leading to a 'good sense of place' in the community created. No other details or background to the proposed change is given and nor is the source of the comment quoted.
In the previous Preferred Options 12/08, 1050 homes were proposed in Area 4 at Martlesham, ie 1050 homes were considered appropriate seven months before the current proposals were formulated, but no explanation is given as to why 1050 was acceptable such a short time ago but 2000 are now considered necessary.
With regard to the statement that a larger allocation provides the basis for a significantly improved range of community facilities leading to a 'good sense of place' in the community created, this applies to any development anywhere, and implies that only large developments of the order of 2000 homes or more are acceptable, which is contrary to the rest of the Preferred Options 7/09 proposals.
In the 2001 census Martlesham ward had a population of 4,926 and therefore it is already a significant community and, in our view, it would be preferable for any new development to be integrated with the existing community, rather that a stand-alone community with a different identity separated from existing housing and facilities.
It seems to us that the increased allocation of homes at Martlesham is a direct result of the decision to reduce the number of homes at Felixstowe and the need to accommodate the consequent shortfall in numbers somewhere, the somewhere being Martlesham. We do not believe this is a sound or appropriate process for allocating development.
Employment
Also, we believe that in order to maximise the overall sustainability of any new development at Martlesham, and in particular transport sustainability, it is essential for the Preferred Option allocation to have a clearly expressed requirement for the provision of housing at Martlesham to be linked to the provision of employment floorspace at the same (or adjoining) location. We do not believe your Updated Preferred Option 7/09 contains such a requirement and we believe it should be amended to explicitly include it such that the provision of housing cannot proceed in advance of employment facilities.
Inaccurate and incomplete evidence
Public Transport
Paragraph 3.04 on page 3 states that 'the Council has commissioned a number of additional studies. These studies provide the detailed evidence to ensure that any decision taken in relation to new development is soundly made'.
One of the additional studies is the Proposed Strategy Transport Appraisal September 2009, prepared by Aecom. We object to some of the evidence contained in this report because it is inaccurate and incomplete.
With regard to Area 1 to the East of Ipswich, the report does not refer to bus services 5 and 11, or service 31.
Services 5 and 11 serve the central part of Area 1 with a 15 minute service in each direction on a gyratory route between Ipswich Town Centre and Ipswich Hospital. The journey time to the town centre is 18 minutes and from the town centre it is 12 minutes, and the to Ipswich hospital the journey time is 7 minutes and from the hospital it is 4 minutes.
These are short journey times and compare very favourably with other Ipswich bus journey times. For instance, the bus journey time during the day from Grange Farm, Kesgrave to the town centre varies from 27 to 32 minutes, and from Ravenswood it is 19 to 22 minutes. The Park & Ride journey times are Martlesham 24 minutes, London Road 12 minutes and Norwich Roiad 9 minutes.
Service 31 provides a one hour frequency service between Ipswich Town Centre and Ipswich Hospital. The journey time from the central part of Area 1 is 11 minutes.
Therefore we are of the opinion that as an evidence base the report is inaccurate and incomplete and we believe it does not present a correct account of the accessibility and sustainable transport benefits of Area 1 of the Ipswich Policy Area when compared to other locations in the East of Ipswich.
We have drawn attention to this omission previously as follows:-
* Our letter of 20 October 2008 responding to SCDC Report LPTG 10/08 - Core Strategy - Proposed Location of Strategic Housing Growth in the Area East of Ipswich.
* Our letter dated 21 November in response to IBC & SCDC SHLAA Consultation.
* Our letter of 22 January 2009 responding to SCDC LDF Core Strategy Preferred Options Consultation.
Copies of the above letters are attached for ease of reference.
Our previous representations referred to above were acknowledged in your Report LDF 01/09 LDF Task Group 16/06/09 Core Strategy - Housing and Settlement Policy, Appendix 2 SCDC LDF Core Strategy Response to Preferred Options Consultation para 24 on page 5 which states:-
Some valid points have been made about the alternative locations for housing growth. It is accepted that Option 1 to the north of Ipswich does have good public transport links to the town centre,.....
Unfortunately the points we made have been overlooked by Aecom in their Report.
Locations in their Report where reference to bus services 5, 11 and 31 is omitted and should, in our opinion, be included in order to give an accurate account of the bus services available to Area 1 are as follows :-
Page 24 - section 4.2.1 - Existing Bus Services
Page 25 - section 4.2.1 - Public Transport Accessibility of Sites - Site 1
Page 28 - section 4.2.3 - Sustainable Transport Links to Key Employment Sites - Ipswich Town Centre
Page 39 - section 4.5.1 - Mitigation Requirements & Estimated Scale of Associated Cost - Scenario 2
Page 73 - section 8.3 - East of Ipswich
Also we believe there is an incorrect assumption in the evidence in the Aecom Report concerning the number of dwellings needed to justify provision of a new commercial bus service. On pages 25 and 26 of the Report it suggests that 2000 new households could justify a new commercial bus service, but 950 dwellings would not. We believe this may not be accurate and by way of example we quote the Ravenswood development in Ipswich which was developed with a new bus services to serve in the order of 1000 new homes. In our opinion this assumption should be reconsidered and evidence of other new bus services elsewhere in the country should be introduced to clarify this matter, and to enable a more accurate comparison of the potential development areas in the east of Ipswich to made
Walking and Cycling
In our view in comparing Area 1 to the other four areas in the Eats of Ipswich insufficient weight has been given to the advantages Area 1 has by virtue of its accessibility to Ipswich Town Centre, which is the largest employment centre and attractor of trips to work in the region, and to Ipswich hospital. There are existing pedestrian and cycle routes to Ipswich town centre and Ipswich hospital, and to other parts of the town.
Employment Areas - Ipswich Town Centre
In our opinion the Aecom Report does not give sufficient weight to the importance of Ipswich Town Centre as the largest employment area in the region and the largest attractor of employment trips. It is mentioned on page 13 of their Report and in Table 3.5 on page 20, but we believe it should receive greater emphasis in the overall consideration of the transport aspects of the Preferred Option proposals.
According to the Aecom Report the 2001 Census data states that 54% of work trips from Area 1 were to Ipswich Town Centre. From Area 4 in Martlesham (east of the A12) 32% of work trips were to Ipswich Town Centre and 29% were to Adastral Park. Thus even from Martlesham there were more work trips to Ipswich Town Centre that to Adastral Park.
Therefore it is our view that in the comparison of the five areas in the East of Ipswich the benefits which Area 1 has in terms of sustainable transport, ie the potential for over 50% of work trips to be made to Ipswich Town Centre with an excellent existing bus service, have been understated and not given sufficient consideration and emphasis.
Infrastructure
The Roger Tym Report, and also the Haven Gateway Water Cycle Study, indicate that there is insufficient sewerage and waste water treatment capacity to accommodate the proposed housing numbers in the Ipswich Policy Area. We understand that no capital works to address these shortfalls in capacity are included in Anglian Water's AMP5 submission and so there is no prospect of a solution to the problems in their programme up to 2016, and there is no guarantee that solutions will be included in subsequent AMPs. Your Report refers to the need for developer funding to achieve these infrastructure upgrades, without which the proposed housing numbers are not deliverable, but the costs will be significant and developers may not be able or willing to make major contributions in the current economic climate. We believe the potential delays to deliverability of the proposes housing numbers may have been underestimated in your Report and we are of the opinion that this should be revisited prior to submission of your Core Strategy.
SCDC Response: 7, 10, 11, 16, 18, 20
IPSWICH POLICY AREA Trevor Sparkes Consulting Limited (Mr Trevor Sparkes) Respondent Name: [548] Submission Agent Respondent ID: 548 ID: 548 ID: SUBMISSION Suffolk Coastal Local Development Framework Core Strategy & Development Management Policies
Housing Distribution - Updated Preferred Option 7/09
CONSULTATION RESPONSE FROM THE KESGRAVE COVENANT LTD
Our comments, as set out below, on the Updated Preferred Option 7/09, relate to Area 1 to the East of Ipswich.
In our opinion the Updated Preferred Option 7/09 and supporting evidence do not demonstrate adequately that the proposed changes result in the best option for the Area to the East of Ipswich.
We are concerned that:-
* insufficient explanation and justification is given of the change from 1050 to 2000 homes in Area 4 at Martlesham to the east of the A12 and also
* some of the evidence relied upon in reaching the updated preferred option is inaccurate and incomplete, and has failed to take into account previous consultation responses we have submitted, and as a consequence the assessment of Area 1 and its comparison to the other East of Ipswich sites has failed to identify properly all of its relative advantages.
The reasons for our concerns, and hence our comments, are as follows:-
Insufficient explanation/justification
The reason given for the increase in the number of homes in Area 4 at Martlesham east of the A12 from 1050 to 2000 is a consultation comment that 1000 is insufficient to provide a stand-alone community (item 2 on page 12). The only other explanation given is that a larger allocation provides the basis for a significantly improved range of community facilities leading to a 'good sense of place' in the community created. No other details or background to the proposed change is given and nor is the source of the comment quoted.
In the previous Preferred Options 12/08, 1050 homes were proposed in Area 4 at Martlesham, ie 1050 homes were considered appropriate seven months before the current proposals were formulated, but no explanation is given as to why 1050 was acceptable such a short time ago but 2000 are now considered necessary.
With regard to the statement that a larger allocation provides the basis for a significantly improved range of community facilities leading to a 'good sense of place' in the community created, this applies to any development anywhere, and implies that only large developments of the order of 2000 homes or more are acceptable, which is contrary to the rest of the Preferred Options 7/09 proposals.
In the 2001 census Martlesham ward had a population of 4,926 and therefore it is already a significant community and, in our view, it would be preferable for any new development to be integrated with the existing community, rather that a stand-alone community with a different identity separated from existing housing and facilities.
It seems to us that the increased allocation of homes at Martlesham is a direct result of the decision to reduce the number of homes at Felixstowe and the need to accommodate the consequent shortfall in numbers somewhere, the somewhere being Martlesham. We do not believe this is a sound or appropriate process for allocating development.
Employment
Also, we believe that in order to maximise the overall sustainability of any new development at Martlesham, and in particular transport sustainability, it is essential for the Preferred Option allocation to have a clearly expressed requirement for the provision of housing at Martlesham to be linked to the provision of employment floorspace at the same (or adjoining) location. We do not believe your Updated Preferred Option 7/09 contains such a requirement and we believe it should be amended to explicitly include it such that the provision of housing cannot proceed in advance of employment facilities.
Inaccurate and incomplete evidence
Public Transport
Paragraph 3.04 on page 3 states that 'the Council has commissioned a number of additional studies. These studies provide the detailed evidence to ensure that any decision taken in relation to new development is soundly made'.
One of the additional studies is the Proposed Strategy Transport Appraisal September 2009, prepared by Aecom. We object to some of the evidence contained in this report because it is inaccurate and incomplete.
With regard to Area 1 to the East of Ipswich, the report does not refer to bus services 5 and 11, or service 31.
Services 5 and 11 serve the central part of Area 1 with a 15 minute service in each direction on a gyratory route between Ipswich Town Centre and Ipswich Hospital. The journey time to the town centre is 18 minutes and from the town centre it is 12 minutes, and the to Ipswich hospital the journey time is 7 minutes and from the hospital it is 4 minutes.
These are short journey times and compare very favourably with other Ipswich bus journey times. For instance, the bus journey time during the day from Grange Farm, Kesgrave to the town centre varies from 27 to 32 minutes, and from Ravenswood it is 19 to 22 minutes. The Park & Ride journey times are Martlesham 24 minutes, London Road 12 minutes and Norwich Roiad 9 minutes.
Service 31 provides a one hour frequency service between Ipswich Town Centre and Ipswich Hospital. The journey time from the central part of Area 1 is 11 minutes.
Therefore we are of the opinion that as an evidence base the report is inaccurate and incomplete and we believe it does not present a correct account of the accessibility and sustainable transport benefits of Area 1 of the Ipswich Policy Area when compared to other locations in the East of Ipswich.
We have drawn attention to this omission previously as follows:-
* Our letter of 20 October 2008 responding to SCDC Report LPTG 10/08 - Core Strategy - Proposed Location of Strategic Housing Growth in the Area East of Ipswich.
* Our letter dated 21 November in response to IBC & SCDC SHLAA Consultation.
* Our letter of 22 January 2009 responding to SCDC LDF Core Strategy Preferred Options Consultation.
Copies of the above letters are attached for ease of reference.
Our previous representations referred to above were acknowledged in your Report LDF 01/09 LDF Task Group 16/06/09 Core Strategy - Housing and Settlement Policy, Appendix 2 SCDC LDF Core Strategy Response to Preferred Options Consultation para 24 on page 5 which states:-
Some valid points have been made about the alternative locations for housing growth. It is accepted that Option 1 to the north of Ipswich does have good public transport links to the town centre,.....
Unfortunately the points we made have been overlooked by Aecom in their Report.
Locations in their Report where reference to bus services 5, 11 and 31 is omitted and should, in our opinion, be included in order to give an accurate account of the bus services available to Area 1 are as follows :-
Page 24 - section 4.2.1 - Existing Bus Services
Page 25 - section 4.2.1 - Public Transport Accessibility of Sites - Site 1
Page 28 - section 4.2.3 - Sustainable Transport Links to Key Employment Sites - Ipswich Town Centre
Page 39 - section 4.5.1 - Mitigation Requirements & Estimated Scale of Associated Cost - Scenario 2
Page 73 - section 8.3 - East of Ipswich
Also we believe there is an incorrect assumption in the evidence in the Aecom Report concerning the number of dwellings needed to justify provision of a new commercial bus service. On pages 25 and 26 of the Report it suggests that 2000 new households could justify a new commercial bus service, but 950 dwellings would not. We believe this may not be accurate and by way of example we quote the Ravenswood development in Ipswich which was developed with a new bus services to serve in the order of 1000 new homes. In our opinion this assumption should be reconsidered and evidence of other new bus services elsewhere in the country should be introduced to clarify this matter, and to enable a more accurate comparison of the potential development areas in the east of Ipswich to made
Walking and Cycling
In our view in comparing Area 1 to the other four areas in the Eats of Ipswich insufficient weight has been given to the advantages Area 1 has by virtue of its accessibility to Ipswich Town Centre, which is the largest employment centre and attractor of trips to work in the region, and to Ipswich hospital. There are existing pedestrian and cycle routes to Ipswich town centre and Ipswich hospital, and to other parts of the town.
Employment Areas - Ipswich Town Centre
In our opinion the Aecom Report does not give sufficient weight to the importance of Ipswich Town Centre as the largest employment area in the region and the largest attractor of employment trips. It is mentioned on page 13 of their Report and in Table 3.5 on page 20, but we believe it should receive greater emphasis in the overall consideration of the transport aspects of the Preferred Option proposals.
According to the Aecom Report the 2001 Census data states that 54% of work trips from Area 1 were to Ipswich Town Centre. From Area 4 in Martlesham (east of the A12) 32% of work trips were to Ipswich Town Centre and 29% were to Adastral Park. Thus even from Martlesham there were more work trips to Ipswich Town Centre that to Adastral Park.
Therefore it is our view that in the comparison of the five areas in the East of Ipswich the benefits which Area 1 has in terms of sustainable transport, ie the potential for over 50% of work trips to be made to Ipswich Town Centre with an excellent existing bus service, have been understated and not given sufficient consideration and emphasis.
Infrastructure
The Roger Tym Report, and also the Haven Gateway Water Cycle Study, indicate that there is insufficient sewerage and waste water treatment capacity to accommodate the proposed housing numbers in the Ipswich Policy Area. We understand that no capital works to address these shortfalls in capacity are included in Anglian Water's AMP5 submission and so there is no prospect of a solution to the problems in their programme up to 2016, and there is no guarantee that solutions will be included in subsequent AMPs. Your Report refers to the need for developer funding to achieve these infrastructure upgrades, without which the proposed housing numbers are not deliverable, but the costs will be significant and developers may not be able or willing to make major contributions in the current economic climate. We believe the potential delays to deliverability of the proposes housing numbers may have been underestimated in your Report and we are of the opinion that this should be revisited prior to submission of your Core Strategy.
SCDC Response: 7, 10, 11, 16, 18, 20
8 YOUR COMMENTS Trimley St Martin Parish Council Respondent Name: (Mrs Tracey Hunter) [291] Submission Agent Respondent ID: 291 ID: 291 ID: SUBMISSION LDF Consultation Response - November 2009
As part of the continuing Local Development Framework (LDF) process, we are now being asked to respond to the latest documents out for consultation but this is proving to be an almost impossible task due to the volume of documentation recently published and the restrictive time scale in which to reply. The covering letter accompanying the documents issued by the Planning Policy Team stresses that this round of consultation is solely related to a revised strategy of housing distribution with no other issues being considered. However, this parish council feels that consultees are being discouraged from looking at important recently published documentation on transport and infrastructure, which we consider are two of the main factors which should be taken into account when discussing housing distribution.
The latest LDF document shows a change in housing distribution but the overall perceived number of houses remains the same. No account has been made of the likely change in housing requirements since the last housing review in 2007. Since the next review is due in April 2010 it would therefore seem appropriate to wait until these figures are confirmed before deciding on the total numbers of new homes required around the district.
Whilst, as representatives of the residents of Trimley St Martin, we feel that it is a positive step in the right direction that the housing numbers have been reduced for the Felixstowe, Walton and Trimleys area, we remain steadfastly convinced that the revised figure is still excessive for this area. Development should not be delivered by large scale housing schemes but should be organic small growth in line with local housing needs. According to the Landscape Partnership document, "Appropriate Assessment for Suffolk Coastal District Council Core Strategy and Development Management Policies 21 September 2009" (page 13), Felixstowe population growth is projected at 1269 people which based on your own formula of 2.1 people per household, would only equate to 604 houses and not the 1410 total new houses required as per your revised housing distribution table.
There appears to be no mention, within the Housing Distribution Updated Preferred Option document of adherence to the criteria for affordable housing being paramount to any development (apart from under point 7.06 Key Service Centres) and we feel that this must be one of the key features under all settlement types. In the Potential Directions for Strategic House Growth (East of Ipswich and Felixstowe/Walton & Trimley Villages) Feb 08 under Housing Needs, (3.30), it states that there is a need to allocate land for 3190 dwellings, approximately one third of which will be affordable. This is further re-affirmed in the Core Strategy and Development Control Policies Preferred Options December 08 document under Development Control Policy DC2 although this is at odds with the section under Affordable Housing (4.27 iv) whereby the SCDC commissioned Local Housing Assessment completed in July 06, states that a requirement for affordable housing of just 24% is necessary and this is now your preferred option. We are further concerned that in the Sustainability Appraisal of Core Strategy and Development Management Policies September 09, the policy SP21 recommends a sustainable mix of housing types which MAY include some affordable housing without specifying any fixed percentage. It is our view that there should be a non- negotiable policy for affordable housing at the scale of 1 in 3, to adequately provide the type of housing required by potential home owners.
We would also like to re-iterate our views contained in previous responses that both Trimley Villages should remain as Key Service Centres, but WITHOUT the asterisk which notes that they are considered capable of accommodating more strategic levels of growth. As stated previously, due to the lack of employment/retail and recreational services, we cannot sustain large scale development and object to becoming a 'dormitory' for the neighbouring town of Felixstowe.
More consideration needs to be given to utility infrastructure needs when apportioning housing growth. There is an expectation that all costs will be borne by developers, however it is likely that any upgrades to current infrastructure are likely to be charged to existing utility customers. This is particularly evident in the case of Anglian Water where their Asset Management Programme is funded by the revenue collected from existing customers. Furthermore, the current Anglian Water Asset Management Programme does not contain any projects to support the growth options identified by the LDF.
We have always expressed concerns about the ability of the local road network to cope with the extra traffic generated from new houses on the peninsula; at Martlesham and east of Ipswich, from extra lorries arising from the Port expansion, from extra employment generally and specifically at Leiston and Adastral Business Park and from Felixstowe tourism regeneration. While the September 2009 AECOM study addresses some of these items, worryingly it fails to take account of others.
We also feel that the availability of brown field land needs further investigation before any assessment of housing numbers to be built on greenfield land is made. For example, with the closure of Deben and Orwell High Schools there is the possibility of releasing extra brownfield land for housebuilding purposes. In addition, with the need to preserve Greenfield/farmland, we believe that brown field land previously identified by David Lock should be reconsidered eg: Peewit/Felixstowe Beach Caravan Parks. We are also very concerned that the number of windfall houses has been drastically cut from the already heavily discounted 1320 units to only 540 homes without proper justification or alignment with evidence from housing review data used elsewhere in the LDF. In summary, we are still of the opinion that too much emphasis is being placed on mis-leading housing numbers and that the requirements are excessive compared to the actual needs of each individual town and village within the district. There is still a real danger that Trimley St Martin could have a large housing estate built under the proposed LDF strategy; we expect the paper to safeguard our rural community from large scale development. Greater consideration must be given to the current economic climate particularly in respect of employment opportunities - too much importance is still being placed on expected Port growth. More consideration should be given to prioritising brown field sites and most importantly of all, housing growth should be divided amongst the District, based on where it is needed rather than providing unwanted and unnecessary large scale development.
SCDC Response: 1, 5, 22, 23, 24, 25
8 YOUR COMMENTS Trimley St Mary Parish Council Respondent Name: (Mrs Debra Cooper) [238] Submission Agent Respondent ID: 238 ID: 238 ID: SUBMISSION Trimley St Mary Parish Council believes that 30% of all developments should be affordable housing, this must be guaranteed. There must be protection for the residents of Trimley High Rd from pollution, congestion and noise. Therefore this Parish Council opposes any larger housing development having access onto the High Rd. The infrastructure required must be in place with the assurance of provision of maintainance. Quality farmland must be protected with Greenfield sites only considered at the last phase of the process if proved to be required for development. Councillors ask that all previous comments and concerns are taken into account.
SCDC Response: 22, 26
FELIXSTOWE/WALTON AND TRIMLEY VILLAGES - PROPOSAL TO REDUCE THE NUMBERS
Respondent Name: Trinity College Cambridge [348] Submission Agent Respondent ID: 348 ID: 348 ID: Mr Rob Snowling SUBMISSION Dear Sir
Consultation on Core Strategy Housing Distribution - Updated Preferred Option 7/09 Bidwells represents Trinity College Cambridge, owner of the Trimley Estate at Felixstowe. On behalf of our client, we wish to make the following comments in respect of the Core Strategy Housing Distribution - Updated Preferred Option 7/09.
Our comments primarily refer to the Updated Preferred Option 7/09, however we have also commented on the updated Sustainability Appraisal where this relates to the revised Housing Distribution at Felixstowe and the Trimleys.
In general we support the continued identification of Felixstowe with Walton and Trimley St Martin and Trimley St Mary as one of two Major Centres that will be the recipients of a large proportion of the District's overall housing requirements to 2025. However, we wish to object to the reduction in proposed housing growth at Felixstowe and the Trimleys from 1,660 dwellings to 1,000 dwellings. We do not agree with the findings of the Sustainability Appraisal (i.e. that the sustainability of the revised Housing Distribution is more sustainable than the previous version) and do not support this change in direction.
Guidance produced by the Planning Inspectorate states that a Local Planning Authority should rigorously assess a Development Plan Document before it is published under Regulation 27 to ensure that it is a plan which they consider to be "sound". In order to be found sound the Core Strategy will need to be "effective", which means it must be deliverable, flexible and able to be monitored. Therefore in order for the Core Strategy to pass the soundness test, the Council will need to be sure that housing sites can be confidently delivered in the locations identified in the Updated Preferred Option Housing Distribution.
As the Housing Distribution stands we are unconvinced that the necessary housing sites can be delivered to meet the District's housing growth targets and in particular there would appear to be a lack of robust evidence to counter the real concern that delivery of housing growth on land adjacent to Adastral Park is fettered by planned mineral extraction and requirements for substantial infrastructure improvements, raising doubts over its viability and delivery.
We consider that the organic growth that would be provided through the comprehensive planning of smaller scale, yet interconnected locations of growth at Felixstowe and the Trimleys, offers more certainty of viable, well integrated planned growth, where it can respond to local needs best. Furthermore, we consider that this would add to the sustainability of the Core Strategy and also provide housing growth in locations where there are no overriding constraints and a single landowner, such as the land owned by Trinity College at Walton and Trimley St Martin.
Paragraphs 5.09 and 5.10 of the Updated Preferred Option document provide a summary of the individual strategies and policies that have been produced for the Major Centres and Towns and describes how these have informed the overall housing distribution. The document states inter alia that the Housing Distribution has been amended to take into account concerns raised in respect of the proposed settlement hierarchy and refers to the need for housing and jobs to be provided in tandem. However, there is already an abundance of employment opportunities associated with the Port activity at Felixstowe and it therefore appears logical to locate new housing in locations where employment opportunities already exist.
Paragraph 5.12 of the Updated Preferred Option document states that one of the reasons why new homes are being shared out in the proposed way is to provide new housing where it will support new employment provision and has the optimum opportunity for providing new and improved infrastructure to support it. However, an increase in the provision of housing at Felixstowe and the Trimleys would provide the opportunity for those people currently commuting into the area to work to live closer to their jobs, helping to meet the objectives referred to above. This approach (i.e. reduced provision of housing growth at Felixstowe and the Trimleys) does not on the face of it appear to be consistent with the Council's Updated Preferred Option 7/09, which is proposing a lesser amount of housing growth at Felixstowe and the Trimleys.
There would also appear to be a conflict with the revised Housing Distribution and the Sustainability Appraisal, which refers to the increased sustainability of the Updated Preferred Option, with the A14 noted as a constraint northwards of Felixstowe and the Trimleys. However, the growth of jobs in Felixstowe, driven by expansion of the Port, means that employment is now out of balance with the availability of housing with more new jobs being taken up by people who are not able to find a home in Felixstowe and the Trimleys. The provision of additional housing at Felixstowe and the Trimleys would help to reduce inward commuting therefore we consider that the Housing Distribution set out in the Council's Preferred Option 12/08 (i.e. more growth at Felixstowe and the Trimleys) represents a better approach to growth in the District.
Whilst the Council has commented that the financial crisis and resulting recession have significantly slowed the rate of expansion of the Port, and appear to have used this partly as the basis for decreased housing provision at Felixstowe and the Trimleys, the Core Strategy, once adopted will provide the spatial strategy for the District up until 2025. It would therefore appear to be wholly inappropriate to base the future settlement hierarchy and plans for growth in the District on circumstances that are unlikely to prevail for the duration of the plan period, particularly when delivery of the Felixstowe South Terminal expansion (circa £90 m investment) will come on stream in 2010 - placing Felixstowe well ahead of the competition in terms of capacity to deliver substantial growth in the economic upturn. This would appear to be one of the key drivers behind the Updated Preferred Option and we do not consider this to be the hallmark of a sound plan.
Appendix 3 of the Updated Preferred Option document sets out a summarised version of the "Housing Distribution Consultation Timeline", indicating that the currently proposed strategy for a 1,000 new dwellings at Felixstowe and the Trimleys was put forward in February 2009. However, this indicates that the updated housing distribution has not been based upon the technical reports, published more recently (that will form part of the evidence base for the Core Strategy). If this is the case, it would indicate that the revised housing strategy has not taken into account the full evidence base, including the Roger Tym and Partners Infrastructure Study (Final Report, September 2009) and the Suffolk Haven Gateway Employment Land Review and Strategic Sites Study (Interim Draft Report, September 2009).
In addition to the points raised above there would appear to be outstanding delivery/viability issues associated with the proposed allocation of 2,000 dwellings to the land East of the A12 that require further investigation and viability testing before the Housing Distribution is finalised. The Ipswich Eastern Fringe Infrastructure Study (September 2009) identifies "significant needs which may be difficult to deliver" in respect of secondary education provision, identifying that a new secondary school will be required in respect of growth to the East of the A12. Appendix 1 of the Updated Preferred Option document identifies that funding will need to be delivered through developer contributions, however the Infrastructure Study states that 60% of the costs would need to come from other sources, which are yet to be identified.
In contrast the proposed replacement of the existing two schools in Felixstowe by a single new secondary school is being funded through the BSF programme and is expected to provide sufficient capacity to cater for the proposed growth. Consequently the Infrastructure Study for Felixstowe (September 2009) finds that there are "no significant needs that cannot be delivered" in respect of secondary education. We consider that infrastructure costs and the wider issue of viability are likely to be a key factor in the delivery of the District's growth targets and should therefore be given further consideration in determining the overall Housing Distribution.
Similarly, the Ipswich Eastern Fringe Infrastructure Study identifies delivery issues associated with requirements for a new wastewater treatment works (WwTW) to serve the proposed 2,000 new dwellings in the Eastern Fringe. The Study states that the necessary expansion works are not included in Anglian Water's Asset Management Plan (AMP), meaning that the necessary works could only be delivered through AMP funding by 2016 at the earliest. Again this raises issues over the deliverability of the land to the East of the A12 to deliver the necessary levels of growth during the first 5 year phase of the Core Strategy period, raising a further question mark over the revised Housing Distribution.
One of the arguments for increasing dwelling numbers on land East of the A12 is to make the infrastructure burden viable. However, the need to increase growth in this location by an additional 1,000 dwellings reveals that it is a growth location that has been identified without the necessary evidence base to justify its inclusion, and it is likely to attract future requests for infrastructure subsidy through the allocation of even more housing. Delivery of sustainable development is at the heart of soundness and we do not consider that draft allocations should be manipulated in this fashion, particularly when it will prevent the delivery of housing in locations where infrastructure is already available and housing sites are deliverable. If the Council establish a location for 2,000 homes on land adjacent to Adastral Park then the result will be a forced scenario which is likely to see the continuous expansion of an outlying dormitory settlement that has a poor physical relationship with existing communities. We consider that the Council should revert to looking at locations where the availability of infrastructure is apparent and where new housing can be planned at a scale and in a manner which most suits community needs. We consider that reverting back to the provision of 1,660 dwellings at Felixstowe and the Trimleys would achieve this, and ultimately result in a more sustainable Housing Distribution.
Another issue that is likely to impact on the ability of the revised Housing Distribution to deliver the proposed levels of growth on land to the East of the A12 is the planned mineral extraction in this area. Much of the land proposed for the increased level of housing growth in the Ipswich Policy Area (i.e. 2,000 homes on land adjacent to Adastral Park) has been or is scheduled for mineral extraction. This raises a serious question mark over the ability of land to the East of the A12 to deliver new housing growth during the first 5 year phase of the Core Strategy period and would not appear to support the proposed increased levels of growth at land to the East of Ipswich as advocated by the Updated Preferred Option. Instead, we believe that the Council should consider a higher proportion of growth at Felixstowe and the Trimleys rather than the reduced allocation that it is now proposed.
As stated above, the organic growth that could be provided through the comprehensive planning of smaller scale, yet interconnected locations of growth at Felixstowe and the Trimleys, offers much more certainty of delivering viable, well integrated planned growth, where it can respond to local needs best.
In summary, we do not consider that the Updated Preferred Option 7/09 will ensure that the Council's vision and objectives will be better met as a result of the proposed changes to the proposed levels of growth at Felixstowe and the Trimleys, and we request that the above comments are given due consideration in your formulation of the "Submission" version of the Core Strategy document.
SCDC Response: 4, 16, 20, 21, 22, 25, 26
KEY SERVICE CENTRES Ufford Parish Council (Mrs Respondent Name: Heather Heelis) [494] Submission Agent Respondent ID: 494 ID: 494 ID: SUBMISSION LOCAL DEVELOPMENT FRAMEWORK - Consultation Response
Ufford Parish Council would like to reiterate their support for the downgrading of Ufford to a Local Service Centre.
In the Ufford Parish Plan there was significant demand for allotments in the parish. There is currently no allotment provision in the parish and this is something the Parish Council will be addressing in 2010. The Parish Council would support inclusion in the LDF for the provision of allotments in villages, including Ufford.
Thank you for taking these comments into consideration.
SCDC Response: Noted
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009 Waldringfield Church Field Trust Respondent Name: (Christine Fisher Kay) [420] Submission Agent Respondent ID: 420 ID: 420 ID: SUBMISSION As trustees of Waldringfield Church Field Trust we are writing to object to this proposal. The Trust manages one of two public open spaces in the village.
Updated preferred option - OBJECT
Both the 2000 houses now proposed and the 1050 in the previous document would be an urban intrusion into a rural area, close to the Suffolk Coast and Heaths AONB. The population of Waldringfield is about 400 and would be completely dominated by the new development in terms of traffic, use of facilities, and damage to the environment especially the fragile environment of the Deben Estuary. The proposal fails to satisfy most of the criteria listed in its own introduction: The road, rail and other public transport networks should be capable of accommodating the traffic and journey requirements that new housing inevitably brings with it; New housing should allow integration with existing communities but at the same time should respect and maintain the character of individual settlements and communities; In deciding where new development should go, it should respect the quality of the local environment; Protection should be given to wildlife and to the landscape, particularly those areas that are designated as being of national and international importance.
On all these counts the proposal fails.
We consider the car park at Church Field although meant for users of the field may be used as a starting point for increased use of footpaths along the Deben Estuary leading to significant disturbance of the flocks of birds feeding and roosting there. We already have problems with dogs not on leads (in spite of notices) and owners not using the dog waste bins. These problems are likely to be much worse in Waldringfield becomes part of the urban fringe. This document predicts the population of the 2000 houses to be less than one person per house and assumes 300 houses will be empty! However the planning application for the site predicts an occupancy of 4800 - 12 times the population of Waldringfield. The Appropriate Assessment appears to be based on flawed data.
The document says 'At the present state of knowledge it is not possible to be certain that the increase if visitors would not result in an increase of disturbance or trampling damage to qualifying features on esturine/coastal sites.'
In contradiction of the above, the same document later states that there will be no significant increase in visitors to the Deben estuary because people will not walk more than 1 km and they will not drive to Waldringfield because there is no car park. The Church Field is about 5 minutes by car or 10 minutes by bike or 30 minutes on foor from the proposed site along public footpaths. In any case the information leading to this assertion, based on a single study in Dorset in 2004, is by no means comparable to the situation here.
Waldringfield has a network of footpaths and minor roads linking the proposed site with the Deben estuary. At Church Field there is a small car park and two footpaths lead to the river a distance of 0.5km. The car park is meant for users of Church Field but this does not deter people from already using it as a base for walks. Church Field is under an entry level stewardship scheme and is developed for recreation by the village and for wildlife. We already have problems with dogs not on leads (in spite of notices) and owners not using the dog waste bins. these problems are likely to be much worse if Waldringfield becomes part of the urban fringe. In addition our car park might be used as a starting point for increased use of the Deben Estuary and disturbance of the internationally important RAMSAR site there, where, as the Appropriate Assessment states, up to 22,000 birds are to be found through the year. The proposed mitigation of increased wardening would not be feasible as wardening of public footpaths is not a practcal solution. Other green spaces which might be provided will not be able to compete with the attraction of the river.
We consider that the alternative of smaller developments throughout the region in response to local demand and including affordable housing, integrated into existing communities, would be the more logical and desirable solution.
Signed on behalf of the seven current Trustees of Waldringfield Church Field of which three are elected from the Oarish, two are nominated by the Parish Council, one is nominated by Waldringfield CP Primary School and one by the Waldringfield Tennis Club.
SCDC Response: 4, 9, 11, 16, 17, 18, 19
IPSWICH POLICY AREA Waldringfield Sailing Club (Mr T Respondent Name: Carter) [489] Submission Agent Respondent ID: 489 ID: 489 ID: SUBMISSION OBJECTION _ TO PROPOSED CHANGE TO HOUSING DISTRIBUTION TO INCREASE HOUSING NUMBERS IN THE IPSWICH POLICY AREA EAST OF A12 AT MARTLESHAM HEATH
The Waldringfield Sailing Club wishes to respond and voice its considerable concern over the proposed increase to housing numbers for Martlesham and to highlight what it considers to be the flawed reasoning to justify the proposed changes.
Section 6 of the consultation document sets out the Council's response to the Preferred Options 12/8 consultation and reasons for the updated housing distribution. This consultation response comments on those references in the consultation to the impact of the proposed changes on the neighbouring village of Waldringfield and the River Deben. The comments set out in this response reflect the position of the club in objecting to the application for outline planning permission by BT for the development at Adastral park.
Summary of Response
The consultation document seriously underestimates the impact of the increased housing numbers on the village and attractive river front area at Waldringfield. The development would engulf the village. It is suggested in the consultation that the recreation and open space provisions in the new development (such as for dog walking) would mitigate any ill effects. Respectfully this is simply unrealistic and a nonsense. The River Deben and attractive beach front area, already under severe visitor pressure, will be irresistible to the new and overwhelming numbers of new residents. The increased pressure will spoil and damage the beauty and attractiveness of the area, designated for the highest level of landscape protection as an AONB, with an estuary designated as a Special Protection Area.
Findings of a Planning Inspector considering the impact of additional accommodation at Martlesham/Waldringfield.
It is instructive to consider the decision and remarks of Alan Boyland, a Planning Inspector, appointed to determine the appeal against refusal of permission for a static caravan park (log cabins) at Foxburrow Farm, land immediately opposite the proposed Adastral park Development in June 2008. Having sat for 9 days to hear evidence which covered inter alia the impact on living conditions in Waldringfield, he refused permission for 180 log cabins on grounds which included the impact on the village. We submit that the problems the inspector quite rightly identified about the pressure on the village and waterfront, for just 180 log cabins, can only be very much worse when the increased proposed pressure is from the additional new residents of at least 2000 new homes.
His Appeal Decision commented as follows:
"Issue (ii): living conditions The sites are about 2.5km from Waldringfield, which is already popular with visitors especially on summer weekends and bank holidays. Although the village itself has its attractions, most people go through it to the Rivr Deben as this is one of the few places in the area where there is fairly easy access by car to the water. The river here offers opportunities for boating, including a sailing club, boatyard and slipway, river trips and walking, a small beach though this largely disappears at high tide, and fine views of the water and of the AONB."
He then sets out the problems of congestion, and parking and then observes
To reach the river or the Maybush it is necessary to pass right through the village to a dead end at the river. The only permitted through route via School Road and Cliff Road, is in parts barely wide enough for two cars to pass and is mostly without footways...A major problem is the lack of a public car park in the village...The narrowness of the roads means that on-street parking is very limited and likely to cause obstructions. There is also very limited scope for vehicles to turn at the end of the road. This poses particular difficulties for those towing trailers. These factors are compounded by the number of boat trailers passing to and from the slipway and the sailing club.
"The above are existing situations, and would presumably continue irrespective of my decisions on these appeals, but it is necessary to consider the increased effects of the proposed developments..."
The decision was made in light of retained Policy LP112.
Overview of the sailing club.
Waldringfield Sailing Club is situated on the bank of the River Deben at Waldringfield. It was established in 1921, and currently has a membership of over 750 people. The club is an active racing club with a number of established classes including the Squib Keelboat, Wayfarer, Laser, Cadet and lark Class dinghies. Our fleets are among the most successful and prestigious classes in the country when measured by size of fleet and by participation and Rankings in Regional, National and World Championship Competitions. The club also hosts a fleet of traditional clinker hull dinghies known as "Dragonflies" were built for the club in the late 1940s and are still moored and raced at Waldringfield.
Sailing has a long and proud history on the Deben. The river provides a unique and arguably unrivalled sailing experience. The river is largely unspoilt by development, and does not host a commercial port. There are few marinas. Most of the boats on the river are moored, and dinghies are either parked within the club premises or brought to and from the river by trailer. Waldringfield has sufficient water to allow racing to take place at any state of the tide.
Impact of the Proposed Proposed Changes.
It is noted the Council considers that the impact of the proposed increase in housing on surrounding villages can be "properly managed" by the proposed development. This fails to evaluate what the club feels will be the inevitable and significant extra pressure from residents seeking recreation on the limited River bank area. given the short distance from the proposed development to the river, and given the obvious attraction of the picturesque waterfront of Waldringfield, many more people will be competing to enjoy the very limited river bank beach area. The river is accessed by Cliff Road, which terminates at a dead end, beside a very popular public house (The Maybush Inn) where there is no public car park. This area is already a "honey pot" and in sunny summer days the waterfront area becomes choked with cars and problems of congestion, overcrowding and inconsiderate parking emerge. The sandy beach is only a few hundred yards and is too short to accommodate more visitors.
The traffic congestion is a serious issue for ailing club members many of whom bring the boats to and from the club by trailer each time they sail. Others may remove and return dinghies to the club periodically to participate in regional or national championships. Negotiating a congested Cliff Road with a dinghy on a trailer is already a problem. Any further traffic pressure will exacerbate this. Furthermore from the club's "Cliff Top" dinghy park, access to the water is gained by taking boats by trolley through the access road, on to Cliff Road and then on to the slip way or beach area. Such use is incompatible with competing vehicular traffic and parking in this area.
The Council's considers that recreation and open space provisions within the proposed development would be adequate to protect the river area. This is seriously to disregard the significant impact that the residents of this area will have beyond the development boundary, when they will inevitably be drawn to the riverside area. By adding to the honey pot effect the likely effect will be to make sailing less attractive and less accessible at this location. This is likely to take the very essence of the features that are sought after for sailing and recreation and would diminish the club.
The development skirts the periphery of the AONB along the Newbourne Road. The applicant makes light of the visual impact of the development on the AONB. The club believes that the loss of this Greenfield and agricultural buffer will detract from the sense of open countryside enjoyed in Waldringfield. Furthermore the club reiterates its comments above in respect of additional visitor pressures which are entirely inconsistent with the protection of the AONB, the highest designation of landscape protection that can be granted. The estuary is designated Special Protection Area. It would be afforded little protection if the proposal were to be granted in such close proximity.
Conclusion
For the above reasons, Waldringfield Sailing Club urges the Council to recognise that increasing housing numbers at Martlesham would lead to a very much worse forward planning strategy because of the significant, and irreversible impacts on the AONB and features of Waldringfield including the vibrant sailing club and its shore area. the inevitable over congestion of the water front area that the proposed changes would bring would make the normal operation of the club impossible. The reasoning behind the proposed changes fails to give any proper, or adequate weight to the impact of the new development on the neighbouring village of Waldringfield and its sailing club. The Council is urged to refrain from adding increased housing allocation to the East of the A12.
SCDC Response: 9, 16, 17, 18, 19
CORE STRATEGY APPROPRIATE ASSESSMENT SEPTEMBER 2009 Waldringfield Wildlife Group Respondent Name: (Mrs Sally Redfern) [496] Submission Agent Respondent ID: 496 ID: 496 ID: SUBMISSION Summary Waldringfield Wildlife Group strongly opposes the increase in housing allocation on the Adastral Park site because of its close proximity to the Deben Estuary which is an internationally recognised and PROTECTED environmental site having SPA, SSI and Ramsar status and is within the Suffolk Coasts and Heaths AONB. Pressure from increasing visitor numbers will increase wildlife disturbance and trampling. Run-off from roofs, tarmac and concrete will contaminate the water table and thus the streams that are tributaries of the river. Ramsar status means that even governments are obliged to maintain favourable conservation status. No to 2000, preferably no to 1000.
Response On behalf of the 39 members of the Waldringfield Wildlife Group, we strongly object to the increase in housing allocation to 2,000 homes on the Adastral Park site on the grounds of the negative impact on the internationally recognised environmental site that is the Deben Estuary. The original allocation was unacceptable to us and this revision simply doubles the issues; the housing will be denser, no space for areas of heathland to regenerate and the new residents will be even more likely to look for recreation in the close environment. Moreover the runoff from the site will naturally drain through streams and creeks to the Deben Estuary with resulting effects on the chemistry of this highly sensitive ecosystem.
The questionable premise that people walk, on average, 1km. from their homes (App. Ass. 6.2.35) brings Martlesham Creek within easy range at one side of the development. The premise is also undermined when, at a distance of only 2km. on footpaths, there is a beautiful riverside with a sandy beach and a pub to provide rest and refreshment, a circular walk along the river wall and a different route back mostly on footpaths. Furthermore, just over 1km. away on footpaths is the SSSI Newbourne Springs nature reserve, again with a pub a short distance away to act as a draw. The warden of Newbourne Springs already comments on the disturbance caused by some of the current visitors (App. Ass Appendix 6). Also in Appendix 6, the Suffolk Coasts and Heaths respondent states that even a 1% increase in visitor numbers would increase the harm done to the Deben SPA and the AONB.
The "low to moderate level of terrestrial recreational activity at present" (App. Ass 6. 2. 26) already results in considerable disturbance to feeding birds. Particularly noticeable is the frequent, noisy rising of Dark- bellied Brent Geese on winter weekends caused by walkers along the river wall. Increased human activity would result in even more disturbance for this creature, which is one factor that gives the Deben Estuary its Ramsar status. There are 7 other bird species which currently occur in the Deben Estuary at levels of national importance so contributing to the SPA status (R.I.S. 22 a survey dated 1996 - Black-tailed Godwit, (Common) Greenshank, Bean Goose, (Common) Shelduck, (Pied) Avocet, Spotted Redshank and Common Redshank). More recent surveys (Suffolk Birds and the Wetland Bird Survey) show a much wider range of species occurring at significant population levels, including Golden Plover, Grey Plover, Pintail and Little Grebe.
The Deben Estuary saltmarsh and inter-tidal mudflats display the most complete range of saltmarsh community types in Britain (The Annotated Ramsar List: UK dated 5/9/09). Nationally and internationally important flora and fauna are to be found in the creeks, streams and estuary. There are 7 species of nationally scarce flora (R.I.S. 21 dated 1996 - Althea officianalis, Bupleurum tenuissimum, Lepidium latifolium, Puccinellia fasciculata, Sarcocornia perennis, Suaeda vera and Zostera angustifolia), which are vulnerable to trampling by increased visitor numbers and also to changes in the chemistry of this subtly balanced ecosystem.
Ramsar status for the Deben Estuary is also due to the presence of Vertigo angustior found in Martlesham Creek. This small snail is on the EU Habitats and Species Directive at the highest grade and international governments are obliged to maintain favourable conservation status or fines will ensue. The Adastral site is on the 25m contour line and drainage will naturally occur into Martlesham Creek, Newbourne Springs, and through the Moon and Sixpence stream to the decoy on the edge of the Deben. The run-off from 2000 houses, and the tarmac and concrete associated with them, will gradually get through to the Deben and the delicate balance of chemicals required for the continued survival of the community which supports Vertigo angustior will be compromised.
Further disturbance on the banks of Martlesham Creek will result from the new sewage treatment works that will be required whether 1,000 or 2,000 houses are built. In sum, trampling and chemical contamination will adversely affect what is supposed to be a highly protected area.
Without doubt this proposal is environmentally unsustainable with respect to the need for wildlife protection and preservation of the Deben Estuary's saltmarsh and mudflats. We urge SCDC to look again at the plans for houses at Adastral Park and not to pass this scheme that will have such a damaging effect on an internationally important wildlife site.
If you are objecting to any area of the documents, please indicate what changes you would like made (please continue on a separate sheet if necessary)
The Waldringfield Wildlife Group urges SCDC to look again at the plans for houses at Adastral Park and not to pass this scheme that will have such a damaging effect on an internationally important wildlife site.
SCDC Response: 9, 16, 17
KEY SERVICE CENTRES Westleton Parish Council (Mr Respondent Name: Colin Fisher) [219] Submission Agent Respondent ID: 219 ID: 219 ID: SUBMISSION Westleton is a thriving KSC that sits on the B1125. The Parish Council objects to the suggested "Housing Distribution" of just 9 additional dwellings,over the next 15 years. The WPC would therefore support a responsible and considerate approach to a minimum of 18 dwellings over the next 15 years providing due diligence was applied to its conseravtion area and a limited expansion to its current building envelope.
SCDC Response: 27
THE MARKET TOWNS Woodbridge Town Council (Mrs Respondent Name: Chris Walker) [98] Submission Agent Respondent ID: 98 ID: 98 ID: SUBMISSION We have had sight of document LDF 03/09 and feel 200 homes for Woodbridge Town only (not including parts of Melton and Martlesham) may be too many on allocated greenfield sites. We suggest this figure be phased alomnst ALL the market towns. Furthermore we wish to have consultation of phase 2 at your earliest convenience.
SCDC Response: Noted
THE OVERALL STRATEGY Woodbridge Town Council (Mrs Respondent Name: Chris Walker) [98] Submission Agent Respondent ID: 98 ID: 98 ID: SUBMISSION We wish to have sight of the exact no. of brownfield sites for the town of Woodbridge (not including paets of Melton and Martlesham) and we wish to know your plans for the possible number of dwelling per each brownfield site?
SCDC Response: Noted
KEY SERVICE CENTRES Yoxford Parish Council (Mrs Respondent Name: Rosemary Draper) [378] Submission Agent Respondent ID: 378 ID: 378 ID: SUBMISSION Yoxford Parish Council puts the following views on the Updated Preferred Options Housing Distribution consultation.
Having studied and discussed the above Yoxford Parish Council believes that the housing allocation for key centres is inadequate - it basically comes down to 10 new homes per key centre in 15 years, which essentially allows no growth. Yoxford Parish Council recommends an allocation of a minimum of 2 new houses per year in Yoxford.
SCDC Response: 27
Respondent Name: Mr. Frank Bright Submission Agent Respondent ID: 68 ID: 68 ID: SUBMISSION For the avoidance of any doubt I hereby declare that I oppose and reject the proposal to build 2000 dwellings on British Telecom's Adastral Park site.
The paragraphs cited in the comments below are those used in the document:
"Suffolk Coastal Local Development Framework, Core strategy & Development Management Policies Housing Distribution - Preferred Option 7/09 Consultation (Regulation 25) Sept. 2009"
When referring to other documents then that will be clearly indicated.
2.01 : "For many aspects other than housing distribution the Core strategy document has now achieved a measure of support".
There is no proof of that and all the evidence points very much to the contrary. Had there been such evidence then, surely, the Council would have published it in support of its contention as it is a fundamental issue in favour of its proposal. It has not done so. I am therefore encouraged in my belief that there is no such measure of support at all. It is a false and misleading statement. If one starts with a wrong and false proposition then one arrives inevitably at a wrong and false conclusion. The Greeks called that "logic". Considering the objections to all aspects of the original proposal to have 1000 (or 1050, figures are out of date anyway) then it is most unlikely, to the point of being impossible, that there should be any agreement on the doubling of that number. I shall have to judge any other of the Council's statements in the light of that made in para. 2.01.
2.05 : I object to the key change "A substantial increase in the amount of new housing within the Ipswich Policy Area east of the A12 at Martlesham".
Starting at 09:30pm on 9 June 2009 I attended the meeting of the chairman and members of the planning committee held at Trinity Park. We, the onlookers, had spent our quite valuable time commenting on the various aspects of having 1000 houses build on a variety of areas identified on O.S. maps by numbers, including "644" where area "644" was "Land at Adastral Park, A12,Martlesham (625 180, 245 052)" Our comments were based on a limit of 1000 or 10050 houses only. We were aware that BT had submitted a planning application (Application No. C/08/1725) for the construction of 2000 dwellings on its land, an increase of 100% on what had been on the table. I had commented on "Area 644" but still on the basis of only 1000 houses and the planning department had not told me that it had changed its mind and that the very basis on which comments had been made had changed, or that the goal posts had been moved. It therefore came as a surprise or rather confusion, that the head of your Planning Department dismissed everything that had gone before and extolled only the virtues of accepting BT's proposal of 2000 houses (now more likely to be 2500 houses) on their site. That was not what we had spent our time on commenting and commenting adversely, there was no "broad agreement whatever". What was even more disconcerting was that the chairman of the Planning Committee approved that suggestion without further ado. We had been led to believe in apples, it was pears which were approved. It was a foregone conclusion. No debate on this sudden and substantial change (100%) was permitted r even envisaged. It gave the impression that he chairman was a stranger to procedure.
In your publication "Coastline" of Winter 2008, on page 8, under "The Core Strategy", "What do we want your views on" and finally under "Where will the new homes be located" it was stated quite clearly in para. 2 "Of this, land for just over 1000 new homes needs to be found to the East of Ipswich. After thorough(!) investigation Suffolk Coastal has identified its preferred general location as being to the east if the A12 at Martlesham and Martlesham Heath. This is considered to have considerable advantages over other locations because of its proximity to an expanding employment base, good public transport links and generally poor land quality".
Forgetting for a moment, but only for a moment, the assertion about an "expanding employment base" which was visibly shrinking, or at least visibly to those who took an intelligent interest in such weighty matters and "good public transport links" which just do not exist at Adastral Park since the nearest bus stop for Woodbridge and Felixstowe is at Tesco, a 11/2 miles walk from the proposed housing estate. The nearest bus stop serving only and only the 66 route and that only towards Ipswich is some 250m from BT's main gate and therefore quite a distance from the proposed housing. I cannot even use that misleadingly called "superoute" to get me to Tesco from Eagle Way on Martlesham Heath. So much for "good transport links". Anyway, the goal had been 1050 houses up to the end of 2008. Six months later the thorough investigation had apparently been wrong all along in substance and that casts a shadow over everything else local planning and the consultants for both parties have to say on these and other matters.
There is no justification for a 100% increase. The planning application by BT is neither a good nor a sufficient reason, particularly since the original, never mind the present proposal, does anything to alleviate the real traffic problems in the area, most of them caused by BT now, never mind the construction of a large and densely packed housing estate next door. None of the palliatives suggested, the change from roundabouts to traffic signal controlled square junctions will do anything to cope but will certainly run counter to government policy to which you will have to adhere to, namely to produce a low-carbon infrastructure which means free-flow. Queuing at lights and for cars to start from standing and heavy goods vehicles to go through all of their many gears to overcome inertia only to repeat the process at the next set of lights has the exactly opposite effect and what is happening now is bad enough.
2.07 : "Comments are sought solely in respect of these limited aspects...."
My comment to that gagging statement is that I object to that wording and to the thought behind it as a matter of principle. Planning, if it is to be at all of use must be comprehensive and not just narrowly focused on one small aspect as to whether a large or an even larger number of houses can be squeezed into a small area and dismissing such aspects as employment, the effect on the existing road network and the limits on any improvement, unless one thinks big and that has not been the case with sustainability and carbon footprint. I will remind the Council that before it gave Tesco planning permission to open a large store in the wrong place we here on Martlesham Heath had a shopping centre which we thought was sustainable and which served the community very well and did away with the need to use a car for everyday shopping. It was "unsustained" and collapsed on the day Tesco opened causing innumerable shopping trips across the A12 by car which had not existed and for which there had been no need before their fatal decision. Presumably the focus then too was so narrow that trip generation, delays at the A12/Eagle Way/Anson Rd. roundabout and a huge carbon footprint was beyond it. I would have thought that everybody already knew by then that supermarkets have a devastating effect on existing shops and shopping centres and are an extremely large traffic generator which, after all, is the in the nature of their business. I am therefore pleased to have been informed that comments are now accepted on other documents which were issued since the last consultation. That paragraph should have never found its way onto the document.
3.02 : page 3, top, should probably read "10,200 new homes between 2001 and 2021"
3.02, 2) : I express my doubt as to whether young people leave home earlier, whatever their intention. Reports suggest that they leave home later simply because they can't afford a home of their own and there are far too few so-called "affordable homes". Likewise "people moving here for both work and retirement" of which I am a prime example. There is far less work now, there may not be any in the future and those who retired here will eventually die and create a vacant house.
3.02, 4) : "In relation to Suffolk Coastal it acknowledges the wider economic role that.....and BT research and development at Martlesham Heath play..."
That is a snare and an illusion as well as wishful thinking and bears no relation to reality. The rather more gloomy but nevertheless realistic and true facts are:
By the end of June, or a mere 3 months after the meeting at Trinity park, BT's net liabilities exceeded its net assets by a substantial £3.2bn, which is quite remarkable.
BT's dividend was slashed by 41% only 10 weeks earlier from 15.8p to 6.5p.
The deficit before tax in its pension fund had doubled from £4bn to £8bn in just 3 months. Under legislation that is an unavoidable debt.
The regulator is not happy and BT agreed in May 2009, or just a few weeks before the meeting at Trinity park, that it would put £525m each year into the scheme for the next 3 years, or half of all the cash generated by the business.
From 31.07.2000 to 29.07.2009 the price of BT shares slumped from 613.99 to 112.70. At that rate it could soon be worthless in the eyes of the market which has a better understanding of the state of BT and what BT can afford in all the contributions it is expected to make than, apparently, the SCDC.
BT offered its staff holidays in return for pay cuts,
BT posted losses of £1.3bn for the first three months of the year
BT will cut about 15,000jobs, mostly in the UK, after losing a similar number of posts last ear.
University College London, which had oft-quoted facilities on the BT site, has left.
BT axed its graduate recruitment programme and has no plans to re-open the scheme.
In short, it is rather short of the ready, offers no job prospects, has given up on training graduates and thus on its future. It does not play any, never mind a significant role, not at M.H., not anywhere, in job creation, only in job reduction.
BT, as part of its proposal, will change conventional, tested and tried roundabout into traffic lights controlled square junctions and also provide three sets of traffic lights at the Anson Road / Barrack Square "Tee" junction. The jury is still out on whether traffic lights are better that roundabouts for overloaded junctions. There is no proof of that. BT is also expected to pay for, or in some cases contribute, to the following:
Nursery education, (private funding), Libraries, Waste treatment, Health, Allotments, Community Hall and meeting places, Green infrastructure, Sports facilities, Public transport (depends on operator who has just reduced frequency of buses).
It appears to me that with their legal liabilities, which have first call on any funds, and its poor financial condition, BT is not likely, may not be able, to make all or any of the assumed contributions without which, or without the extras or what I would prefer to think of as bare necessities, the place is more likely to turn out to be just one treeless waste.
It could also be borne in mind that underneath the gravel is crag, also found on the former gravel pit at the Household Waste site off Foxhall Road across the A12. It is the worst of all possible soils as it is hard when dry but turns to liquid when wet and trenches just collapse, i.e. it is worse than London Clay and that is saying something. Foundations, properly designed to prevent cracks in walls will be an unwelcome extra cost. Not every site is suitable for conventional housing, never mind multi-storey buildings unless special precautions are taken. Precautions must also be taken to prevent flooding, for the same reason.
BT has not replaced the old aluminium cables in its immediate vicinity on the Heath with either copper or, even better, with optical fibre. The quality of broadband width, reception and connectivity depends on the distance from the nearest telephone exchange and the cabling. Our telephone exchange is in Dr.Watson's Lane off the A1214 in Kesgrave, miles away. My connectivity and speed are therefore poor. In my estimation BT's performance is therefore poor. I simply judge their future by their past and I invite everybody else to do the same.
3.05 : "Inevitably, for a plan such as this, not everybody will be happy with what is proposed".
The aim should be the greatest happiness for the greatest number. Looking at "Details of Planning Application - C/09/0555" I note that of the 120 comments received 116 were against and only 4 were in favour. If I assume, on reasonable grounds, that those in favour were from BT's consultants who don't live here (and neither do members of the planning committee) then 100% of the locals, who will be directly affected, were against, i.e. it is not a matter of "not everybody will be happy" but a matter of "nobody will be happy" and that is statistically and by common consent very significant.
4.01 : I do not think that the reason behind the changes are justified. The reasoning is based on false assumptions.
I do not think that the necessary broad housing strategy for the District will be better served as a result of these changes. It will cause the same disaster as far as traffic pollution is concerned as the planning permission for Tesco does, day and night, seven days a week, more so on Sundays and before the Bank Holidays. I do not want to be subjected to a social experiment which will fail. There cannot be integration between a new large and densely populated area without facilities for many years to come due mainly to insistence on continued gravel extraction, and an established large village with a reasonable housing density with room to grow trees in abundance, something Adastral Park will lack, one has only to look at Grange Farm, even though we have now been deprived of our central and once thriving shopping centre, thanks to planning. There is a trunk road bisecting the two. During my working life I was engineer (roads and sewers) to three New Towns: Hemel Hempstead, Redditch and East Kilbride. I can assure you that a trunk road did not pass through the middle of any of them.
4.04 : May be : ".....it will be phased between 2008 and 2025" should read "it will be phased between 2011 and 2028" if a 17-year time span is adhered to. 2008 is now in the past and, according to Appendix 2, the first year when building can possibly commence is 2011 though I hope that it will never happen. The calculation then proceeds and arrives at 155 homes p.a. Actually, if the first house is started in April 2011 and the last hose is started in April 2028 that makes for 155 x 17 = 2,635 dwellings which is ominous, but then BT has reserved the right to apply for another 500 to be built which, if my calculation is right, will amount to 2,500 and not the 2,000 presently being put forward as the only option. In fact, 2000 dwellings cannot be divided by 155 if one wants to arrive at a whole number of years.
There is however another aspect. 17 years is a long time to live on a building site and for much of the time gravel extraction and possibly a ready-mixed concrete plant for the footings will only add to noise, dust and very large and heavy lorries coming and going testing some of the old roads beyond their carrying capacity. BT doesn't want to wait that long. They had suggested, on page 23 of their "Adastral Park Transport Assessment, September 2008", Table 6, a time span of only 7 years, 2011 to 2018 with 250 dwellings a year (8 x 250 = 2000 ) but no primary school until 2018, or that is what it looks like. They also indicate 500 jobs in the first year but whether these are new jobs or jobs filled by former and experienced BT employees who had recently been made redundant, is not made clear.
5.10 : "New housing should not be provided in isolation but should be built where facilities already exist or could be upgraded or provided".
Therefore new housing should not be provided on Adastral Park because it would be in isolation, miles from anywhere.
Martlesham Heath is a completely enclosed development, and can have nothing to do with Adastral Park, Adastral Park would overwhelm it if it could, that is why I am very much against another foot and cycle bridge. Large developments have that effect on smaller ones, it is easy to show mathematically the attraction they exert, Newton knew all about it. Adastral Park with its unfinished gravel extraction with its large holes in the ground on which social facilities cannot be built until that industrial enterprise as levelled the site and has gone for good, will use our facilities and ruin them including our precious wood. Thank you.
Adastral Park is not a brownfield site. It was very much a greenfield site and can be restored to become once again a greenfield site which is exactly what will happen if houses are not built there. As to soil quality, during my walks along the back of BT along the C348 I can see rape seed, sugar beet, corn, and cabbages doing extremely well.
I don't want the integration of Martlesham Heath with Adastral Park nor the integration of Adastral Park with Martlesham Heath as the two are like chalk and cheese, they could hardly be more different in concept and I want to keep this place as it is. On the other hand I wouldn't mind having a viable shopping centre back.
5.12 : The idea of 2000 houses on Adastral Park did not occur as a result of public consultation. It was thrust upon us suddenly and without warning at a meeting on Trinity Par on Tuesday, 9 June 2009. The comments I made then, I shall point out, were no published though they should have been for everybody to see and inwardly digest
5.17 : The site now known as the "Preferred Option 2009" does indeed raise problems to the main and to the local road network. It does nothing to alleviate problems encountered now, e.g. the junction Barrack Square / Gloster Road with traffic at a standstill in the afternoon, the junction Gloster Road / Anson Road, likewise, the queues forming along Anson Road due to he right-of-way enjoyed by shoppers pouring nose to tail out of Tesco, the queue forming at the A12 / Eagle Way / Anson Road roundabout due to traffic on the A12 moving in a southerly direction, the queue forming by traffic travelling in a northerly direction on the A12 at the A12 / Eagle Way /Anson Road roundabout because that commercial traffic to which can be assigned economic value has to give way to shoppers pouring out of Tesco, the queues formed by traffic on the A12 travelling in a southerly direction being held by BT personnel arriving from Foxhall Road or the A14 at the BT roundabout who have right of way as they approach from the right, thereby holding up commercial vehicles.
The proposed development can only make matters worse and I oppose it for those traffic and environmental reasons. Heavy diesel-engine powered vehicles, going through all of their many gears inching forward contribute substantially to noise and pollution. Then there is also natural growth. To say that such scenario as "having the least impact" leaves the writer open to the charge of being economical with the truth.
I take particular exception to the photograph of the BT junction taken from the footbridge and shown on BT/David Lock Associates' drawing BTP012 / 092 dated April 2009 "Indicative Views of Junction Improvements", "A12 Junction to Adastral Park / Martlesham Heath". It shows just three cars on the A12 and none on the roundabout. It is a busy trunk road and the photographer must have been waiting for a considerable time to take a picture with so few cars. Why try to give such a false impression, whom are they tried to kid? If it was always that empty, most unlikely for a trunk road anyway, then there would be no need for a traffic signalled junction, which is what the same firm advocates. I shall attach a photo, taken within seconds of arriving on that bridge, which shows rather more vehicles. And yes, to make it even more unrealistic, from the proposed view on the same drawing, with its seven lanes, or an additional three to the present four, for which I doubt is room without retaining walls which echo noise, the traffic lights are omitted. David Lock Associares did exactly the same on previous occasions showing empty junctions with Foxhall Road and the A1214 when we know only too well that large queues form on them simply because they join roads which are at saturation point. After that I cannot take anything else they have to say seriously.
And to say that "It was considered that with careful planning and management the identified problems could be managed to an acceptable level" really takes the biscuit. Why were the only too obvious problems not addressed at Tesco and why were they then not managed, or are being managed, to an acceptable level? After all, every shopper arrives by car and there are lots and lots of them. So many of them at times that they have to queue outside all the way to the A12 roundabout before they can get in and that only slowly because when the parking area is filling up incoming cars have to cruise before they spot a vacant parking space and that, in turn, slows down the rate of entry. There certainly isn't room for more or rather, more would only make the problem worse. So far it has not been suggested to put traffic lights up and turn the Beardmore / Anson Road / Tesco roundabout into a square junction as well. If it is supposed to work everywhere else then why not there?
David Lock Associates had at least one good idea. On page 33 of their booklet "Martlesham" published Summer 2007, there is key map of the proposed layout which shows quite clearly a connecting road (in green) from the Foxhall roundabout to a proposed roundabout (in green) at the main BT gate. That would have syphoned off all of the nuisance BT traffic from both Foxhall Road and the A14. They explain in the text:
" For traffic, the site is really dependent on one junction with the A12 - the Martlesham Heath roundabout (i.e. the BT roundabout). But modest changes can ensure that the whole area is served by three junctions - the "Tesco" roundabout in the north, Martlesham roundabout in the centre and Foxhall roundabout in the south spreading the peak time traffic loads across the network to the most appropriate junction for each journey. This should simplify traffic movements that currently conflict and add to congestion".
Splendid. So what has happened since? The short connecting link from the still existing Old Felixstowe Road which passes BT's main gate and the Barrack Square only to peter out beyond it and which should be extended, as it probably had been in the past, has been omitted from more recent plans. Why? I think we should be told. It is contrary to good traffic planning. And AECOM did not even realise the nuisance value to the flow on the A12 of the A12 / Barrack Sq. / Eagle Way roundabout and omitted it from its plan and calculations altogether. I don't think that they can be taken seriously either.
Comments on Report by AECOM "Suffolk Coastal District Council Local Development Framework Housing Allocation" Proposed Strategy Transport Appraisal Suffolk County Council September 2009
1.3 Study Restrictions
Without a new survey, without transport network modelling, without a consultation, specifically on Area 4, and without latest traffic data, anything and everything that follows is suspect and unreliable, particularly if the "BT roundabout", the traffic associated with and generated by Tesco on an enormous scale and the Barrack Square/Gloster Road T-junction are not even mentioned. If one starts with out-of-date fiures and assumptions and ignores what the locals know from their everyday experience by not asking them then one is bound to get the wrong answer. Which is exactly what happened. You only get what you pay for. It was obviously a matter of saving money but it was saving money at our expense.
A week may be a long time in politics but 8 years is also a long time in assessing traffic volumes. 2001 was a long time ago. For instance Grange Farm, which offers no employment whatsoever, whatever the planners had in mind and hoped for originally (same applies to Adastral Park), now generates a lot of traffic by its inhabitants going to work somewhere else, mothers taking children to school, etc. The school, Cedarwood, is oversubscribed, has a long waiting list and shows how wrong planners (the County in this case) can be with their predictions. The long road leading to it is also full of parked cars which does not make for safety.
The only way in and out of Grange Farm is onto the A1214 which is not coping and has no proper, if any, drainage. The additional traffic from any development at Adastral Park, whose inhabitants too will have to seek work elsewhere, will make a bad situation worse, not only in pure numbers but also in pollution.
1.3, page 4
"....and indicate no critical concern"
I do not share such cavalier attitude. Presumably the SCDC felt no need for a "critical concern" when permitting Tesco to create one of their extreme traffic generating shops here.
"Given the high level context ...... proposed allocation"
One cannot understand, or propose, counsel or consider likely traffic mitigation measures required to be identified when the most important junction which causes the most nuisance now (all caused by BT) is omitted from plan and calculation, i.e. is ignored.
2.1
The study considers the existing and proposed strategic employment areas....."
Adastral Business Park:
I have heard that many times before at every meeting sponsored by BT which I attended. It was put forward by David Lock Associates, consultant for BT.
The evidence points in the opposite direction:
BT has been reducing staff levels drastically, 30,000 in the last 2 years, BT has ceased to take on graduates, thus jeopardising its future University College London has left the campus, BT has a black hole where its pension fund ought to be, BT is making huge losses, BT's share price approaches zero, the market has no confidence in BT's future and the market has a better understanding of BT's drastic decline than either or both the SCDC and the SCC.
A telephone company that cannot replace ancient and poorly performing aluminium cables with fibre-optic ones and bring a telephone exchange closer to Martlesham Heath to provide better broadband and telephone reception does not rank high in my estimation of its capabilities and investment strategies. "Innovation", like charity, begins at home. They are neglecting their core business and the goodwill of their customers.
Ipswich Town Centre:
Ipswich Town Centre has been going steadily downhill ever since I moved here 22 years ago. It has lost, not gained employment. Looks shabby and is of no interest to investors except spec-builders along the harbour front from which industry was removed. Just look at the area around the old, empty, grim and grimy County Hall and its surroundings, including the traffic.
Proposals should be based on something more solid than mere wishful thinking and a lack of realism.
2.2
Drawing No. 600995679_001, Site 4
The AECOM report deals exclusively with Adastral Park and the proposed housing site. What is shown extends all the way to the Main Road (C376), then follows the C355 along its eastern boundary and then what looks very much like the C356 along the southern boundary. There is nothing wrong with showing Site 4 like that except that AECOM has carefully avoided the present, never mind the future problems within that area and "C" roads are not much good for a substantial increase in traffic caused by just developing that site, e.g. with a secondary school about its location we are still kept in the dark at this late stage even though it is obvious that its location will have traffic implication.
By ignoring items which will surface and bite everybody who is busy brushing under the carpet items like:
The deplorable junction layout at Gloster Rd. / Barrack SQ. which causes queues, delays, carbon emission and sulphur fumes caused by cars leaving BT in a continuous stream and blocking cars leaving, or trying to leave, the industrial area in the afternoon.
The entirely home-made (SCC) disaster of the small roundabout in front of Tesco which gives right-of-way to shoppers and causes queues, delays, carbon emission and sulphur fumes along Anson Road and blocking Gloster Road and Beardmore Park.
Tesco, which cannot even accommodate present demand with queues stretching at times all the way to the A12 / Anson Road / Eagle Way roundabout due to its poor internal layout.
The drawing omits altogether the A12 / BT (Barrack Sq.) / Eagle Way roundabout which is the cause of delays on the A12 carrying industrial and commercial traffic and is therefore of economic importance. This delay is caused entirely by BT. Any expansion of employment there, however fanciful and unlikely, can only make matters worse and they have been very bad for a long time, see attached photo, without the SCC making any attempt to improve matters. Please note and internally digest that a reduction, not an increase in carbon emission, is government policy. There is more to repeating the mantra of a reduction in the use of private cars, it also means enabling free flow and not causing queues to industrial and commercial vehicles.
This important junction has likewise been completely ignored in all other treatments of the area which makes the AECOM report unreliable.
Of interest too is the omission on the drawing and any further mention of the Martlesham Heath shopping centre. An admission that since planning permission was granted to Tesco to build yet another one of their miserable, depressing, frustrating, disappointing and unsatisfactory supermarkets on a wrong site, creating a monopoly, ours collapsed and died. It cannot be emphasised enough that any five year old knows of the devastating effect a supermarket has on surrounding shops for many miles around and that the decision by the SCDC's planning committee to foist one on this area inspires no confidence on any of their other decisions. Due to its circular route I cannot even use public transport to go to Tesco but have to use the car, as everybody else has to now, whereas before the greengrocer, delicatessen, ironmonger, etc. were within easy walking distance.
2.3
Overall Road Network
A1214 : already at saturation level and has been for years,
Foxhall Road : Hold ups at both ends, at its junction with the A12 and at the Heath Road roundabout forming long queues at both ends in the morning and at Heath Road in the afternoon, not exactly a carbon- free zone. Cannot absorb any more.
Not forgetting the long queues forming at all junctions along St.Helens Street along which vehicles have to wait for any number of changes of traffic lights before they can proceed to the next set of traffic lights, and so on.. That area too will be affected by what is proposed for this area.
"The A14 and A12 in particular carry out .... and the level of service currently offered by these routes should, where possible, be preserved". OMIT "where possible" and INSERT "must". The level is already below an acceptable level. The very idea that a housing estate, for that is what
SCDC Response: 4, 12, 13, 15, 16, 17, 19, 20
Mrs Jean Potter, Waldringfield Respondent Name: Parish Council Submission Agent Respondent ID: 509 ID: 509 ID: SUBMISSION Comments on LDF Core Strategy Housing Distribution Updated Preferred Option 7/09 by Waldringfield Parish Council
Summary Waldringfield Parish Council strongly objects to the increase in IPA housing numbers, which will make all the disastrous impacts of the proposed new town at Adastral Park even worse. There is no justification for going beyond the 1,050 figure, and there is no need to create a 'new community'. This totally inappropriate development will urbanise a beautiful rural area and have an overwhelming impact on local communities, the road system and the environment.
Distributing the houses over the IPA or the whole of the district would lessen the impact on any one community and provide much needed affordable rural housing.
Section 1.02 "No decision will be taken in respect of individual sites submitted to the Council until the Core Strategy has been all but agreed" [our emphasis]. With the possible exception of very small scale, uncontroversial developments, no decisions should be taken until the Core Strategy has been fully adopted, i.e. has passed the independent examination stage.
Sections 2.0, 4.01 & 8.02 "Comments are now sought solely in respect of these limited aspects of the Updated Preferred Option 7/09", "This consultation is therefore very focused" Waldringfield Parish Council complained to Phil Ridley, SCDC Head of Planning, that the public will not be given any opportunity to use the new evidence (that has only been made available since the previous consultation, as listed in Appendix 1) to inform their comments on anything in the LDF other than these 'limited aspects'. We argued that policies and strategies that were formulated before this evidence became available cannot be changed now that the evidence is available, and that there is no justification for denying the public the opportunity to comment on the broad strategy and policies in the light of evidence that has only appeared since the previous consultation.
Mr Ridley's response contained the following, which does answer our point: "Whilst such comments [on the strategic housing] may raise wider issues, these issues should be framed and will be considered in the context of the revised housing distribution."
"If your council is of the opinion that these recent evidence base documents have a direct impact on other district wide policies, then I would advise you to include those comments in your response. In doing [so] it would help if you explained why and how the evidence base document affects other parts of the document and in your Council's opinion what changes would be required."
However, the misleading instructions in the document itself have not been changed, so most people will not realise that they are allowed to comment on wider issues than the housing numbers. This undermines the validity of the consultation exercise.
Section 3.05 "... not everyone will be happy with what is proposed" This is true! In fact there has been an almost unanimous rejection of the proposed strategy by people living in the affected areas of the IPA and the Colneis peninsular. For example, in the Preferred Options consultation an analysis of individual responses to SP3 (Strategic Policies, Ipswich) reveals that 2 respondents supported the policy and 86 objected to it. The implication of this argument is 'whatever we do, someone will be unhappy, so we can ignore public opinion'. This is simply not true - there are other strategies (e.g. dispersed housing across the whole district) that would almost certainly be less unpopular than the one proposed.
Section 5.09 "The main concerns related to the area East of Ipswich and Felixstowe/Walton and the Trimley villages where the bulk of the new homes are proposed. It is essentially in response to these issues that the original housing distribution strategy is now proposed to be revised." The implication of this is that the updated housing distribution (i.e. an increase in the IPA allocation from 1,050 to 2,000 houses) is in response to the concerns of the public. In fact it is exactly the opposite of what the public said in response to the previous consultation, in which the overwhelming majority objected to the concentration of 1,050 houses in one place.
Section 5.12 "... the broad scale and distribution of development has evolved and refined over time as a result of public consultation" The decision to concentrate the housing distribution in the IPA into one large site was taken in complete opposition to the results of public consultations. For example, the February 2007 Issues & Options consultation produced the following result: * Option 1 (1 large site): 14% * Option 2 (2 or 3 large sites): 51% * Option 3 (a number of small sites): 35% However, in the following consultation (February 2008, Further Issues & Options), one of the questions was "Is your preference for one area of growth only or for more than one?" ('more than one' presumably meaning up to 5). Option 3 was totally ignored, despite the fact that it got more than double the support for option 1. Where was the opportunity to choose a large number of small sites? No figures were provided for the answers to the quoted question, no mention was made of the responses to this question in the Task Group's discussion, and the many arguments presented by the public in this and later consultations, in favour of a distributed allocation have been consistently ignored. The final decision to go for one large site is easily the least popular.
Section 5.17 "None of the five options considered offered a perfect solution" This is a gross understatement - they were all appalling. However, the need to decide between them could have been avoided if a distributed housing strategy had been chosen. As it was, the decision to go for Area 4 (East of the A12) was made by applying the criteria in a completely biased way, conjuring up non-existent 'advantages' and ignoring Area 4's many disadvantages (see Waldringfield Parish Council's response to the Preferred Options consultation, December 2008). SCDC have failed to provide any response to the points made by Waldringfield Parish Council, in particular our criticisms of the supposed 'advantages' of Area 4. Our conclusion is that these criticisms still stand, the 'advantages' are non-existent, and the choice of Area 4 is therefore fatally flawed. Section 5.19 "All of these options however were rejected in favour of a Preferred Option dispersed strategy of "organic and evolutionary growth". No explanation has ever been given for the inconsistency between this decision in Felixstowe and the opposite decision in the IPA. The well argued and valid points supporting distributed housing in Felixstowe (LDF Core Strategy Preferred Options, §3.45) apply equally to the IPA.
Section 6 SCDC's responses to many of the public's comments are totally inadequate. Many important points have been lost in the summaries, and many of the responses fail to deal with the real issues....
Section 6.03 Felixstowe/Walton and Trimley Villages Comment 3: "The A14 is unable to cope now let alone with increased traffic from the new housing" Response: "The traffic studies which have been done indicate that the A14 even with the additional lorry traffic which will result from the port expansion will be able to cope with the housing numbers proposed". Assuming this refers to Suffolk Coastal District Council Local Development Framework Housing Allocations Proposed Strategy Transport Appraisal, Sept. 2009, this document is seriously flawed (see comments on Appendix 1). Even if these flaws are ignored, the document says: "It is expected that the impact at the A14/A12 junction will be significant, and therefore a mitigation scheme will be required to ensure this does not have a detrimental impact on the operation of the junction." (§7.7)
A major bottleneck on the A14 is the Orwell Bridge. This is not considered in the Transport Appraisal, but it is in the EERA Newmarket to Felixstowe Corridor Study, which says:
"Demand on the Orwell Bridge is forecast to increase in the future. The Highways Agency, in the A14 Girton to Felixstowe Congestion Study, forecast that the stress level on the Orwell Bridge will increase to 0.90 in 2009 and 0.98 in 2014. The Highways Agency East of England Transport Model indicates that, by 2021, daily traffic volumes may have reached 76,000, representing a stress level in the order of 1.12. In the morning peak period, the model forecasts an eastbound "demand" flow of over 4,400 pcus, compared to an "actual" flow of 3,400. This suggests that over 30% of the demand in the peak hour will not actually be able to flow through the link because of congestion." (§4.18) [our emphasis].
"When the CRF (Congestion Reference Flow) is reached (i.e. a stress level of 1.0), hourly traffic demand is likely to exceed the maximum hourly throughput of the link, with the result that traffic flow breaks down with speeds varying considerably, average speed drops significantly, and the sustainable throughput is reduced and queues are likely to form." (§4.17)
The problems described above do not take account of the extra traffic due to the proposed 2,000 and 1,000 houses in the IPA and the Felixstowe area respectively, or the possible port expansion.
Ipswich Policy Area - East of A12 Comment 1: "The numbers of houses currently proposed is too great." Response: "To reduce the numbers would mean not meeting RSS requirements as well as resulting in a development which was little more than an overgrown housing estate" The numbers could easily be reduced by re-assigning some of the allocation to the rest of the district (where there is a large identified need for affordable housing), thus keeping the total the same. Dispersal of the allocation over many sites would not result in an 'overgrown housing estate'.
Comment 2: "1,000 is insufficient to provide a standalone Community" Response: No mention is made of the rather telling fact that only one respondent made this comment - David Lock, on behalf of BT, the owners of the land in question. The many comments questioning the need for a new standalone community have been ignored.
SCDC's support for this position is in stark contrast to the arguments previously used to justify a single site of 1,050 houses, which apparently was needed to create a sustainable community. No mention had been made previously that 1,050 would not be enough. No explanation has been given as to why 1,050 houses were considered sufficient to create a sustainable community in 2008 but now 2,000 are needed. Did the planning officers get their sums wrong (by a factor of 2)?
Response: "A larger allocation provides the basis for a significantly improved range of community facilities" This is a self-justifying, circular argument: 2,000 houses are needed to justify providing the facilities, but the only reason the facilities are needed is to service the 2,000 houses! According to the RSS, a genuine need only exists for 1,050 houses - if this number were built, and they were dispersed over the IPA or better still throughout the rest of Suffolk Coastal, the need for new facilities and infrastructure would be far less (and the cost to the taxpayer less).
Response: "The evidence suggests that the benefits do indeed outweigh the disbenefits." No justification is given for this conclusion. What evidence? What supposed benefits? No evidence of genuine benefits has been provided, but there are many disbenefits: * Urbanisation of a rural area * Destruction of local communities * Impact of additional traffic on the roads * Damage to environmentally sensitive areas nearby, and the wildlife they protect * Increase in pollution and greenhouse gases * And many more....
Comment 3: "Adverse impact on existing communities at Martlesham, Martlesham Heath and Waldringfield" Response: "... but which triggers the need for additional infrastructure, particularly secondary education ..." Even 2,000 houses are insufficient to trigger the provision of a new secondary school (according to Future Secondary School Provision Alternative sites Assessment IPA, "Demand for one new secondary school would normally be required for 5,000 new homes" (§3.2.3)) Even taking into account the existing shortfall, a new school will not be justified (see comments on Appendix 1).
Response: "It also offers the opportunity to better mitigate the potential impact of visitors and residents on the neighbouring countryside and estuary ..." It is perverse and illogical to argue that more houses will have a lesser impact, even with 'mitigation'.
Response: "The lie of the land in the proposed area, coupled with the fact that much of the land involved either has been or is scheduled to be used for mineral extraction, is such that the degree of the disbenefit from damage to the landscape, loss of agricultural land and the like from the increased size of this allocation is limited, ..." This ignores the fact that the mineral extraction is a temporary situation, with planning permission conditional on the land being returned to its original state when the extraction has finished. Building in this location actually means the loss of agricultural land, or more accurately lowland heathland, which it was within living memory (pre-1960s for most of it). Lowland heathland is a scarce habitat which should be conserved and re-created: "In areas that support lowland heathland, there should be a presumption in favour of re-establishing heathland on derelict land or land that has been used for mineral extraction." (UK Biodiversity Action Plan) [our emphasis].
Comment 4: "Unacceptable impact on the neighbouring wildlife and countryside" Response: "Development on this scale must be undertaken as part of a comprehensive development which places significant emphasis on mitigating these potential impacts." 'Mitigation' is a word that is grossly overused in this document. 'Papering over the cracks' would be a more appropriate phrase. Doing the wrong thing, then insisting that mitigation is put in place to lessen the impact is not a sensible strategy. No amount of 'mitigation' will be able to undo the damage created by such an enormous and inappropriate development. This damage will be made far worse by doubling the number of houses. Twice the number of houses means twice the number of people, dogs, cats, cars, boats, etc, as well as twice the amount of noise, light pollution, car exhaust pollution, water consumption, etc., and therefore twice the amount of impact on the neighbouring wildlife and countryside.
The response that the impact on the neighbouring wildlife and countryside can be overcome is contradicted by SCDC's own Appropriate Assessment: "Any development is likely to bring additional pressure to any of the sites of European interest, however the area near Martlesham identified as a "preferred option" could have particularly negative impacts upon the Deben Estuary SPA/SSSI" (SCDC Core Strategy Appropriate Assessment, Appendix 4)
Comment 5: "Unacceptable Impact on the primary and local road network" Response: "However the impact of 2,000 homes as opposed to 1,000 on individual junctions etc when linked to new and improved transport infrastructure is limited but will help to secure the necessary developer funding to secure these upgrades to a good standard" How can the impact of 2,000 homes as opposed to 1,000 be 'limited'? 2,000 homes will have roughly double the impact of 1,000 homes: twice the number of car journeys and twice as much traffic congestion. This is confirmed by comparing the figures in the two Transport Appraisals (Aug 2008 and Sept 2009): person trips per hour for the total dwelling allocation is 1087 (970 houses) and 2240 (2,000 houses) - an increase of 106%. (Aug 2008: Table 8, Car Driver, Total Trips figures: 555 (am) + 532 (pm) = 1087. Sept 2009: Table 3.2, Scenario1, Car Driver, Total Trips figures 1143 (am) + 1097 (pm) = 2240) (see comments on Appendix 1).
In either case, upgrades to road junctions, etc would presumably be proportionate to the increase in traffic. Surely developer funding to 'secure these upgrades to a good standard' can be demanded no matter how many houses are proposed. A dispersed housing policy would avoid having to do any major upgrades, because the traffic impact would be much more diluted.
The argument that securing developer funding to pay for changes that are only needed because of the new housing, is (as with the general point about infrastructure) a self-justifying, circular argument. If this new town were not built, the developer funding to widen roads, etc would not be needed.
The Transport Appraisal says: "The combined impact of the allocations to the east of Ipswich and the Market Towns will have a considerable impact on this difficult junction [the A12/ A1214 Junction]." (§7.5.2) and: "the impact on the local road network, in particular the A12, is unavoidable and considerable improvement would be required at a number of A12 junctions to preserve existing service levels" (§4.5.1) Both these quotes support Comment 5.
Conclusion: "Consideration should be given to an alternative housing distribution" Response: The response to this comment fails to address the issue; it is simply a repetition of responses to comments 1-6, and suffers from the same failings. An 'alternative housing distribution' means distributing the houses over several (or even better, many) small sites, instead of one large site. It doesn't mean having to find another large site capable of accommodating 2,000 houses, which is the implication of the sentence: "The area has lower negative impacts on landscape quality and public amenity overall than other potential alternatives"
Section 7.01 "Allocations are expressed as minimum figures consistent with the approach of the Regional Spatial Strategy - The East of England Plan". Although the East of England Plan figures are indeed minima, this only means that SCDC is free to exceed them in the LDF if it wishes. If the LDF figures could be treated as minima, it would make a farce of the whole enterprise of strategic planning - nobody would know even approximately how many houses will actually be built! The figures provided in the LDF are not minima, they are the actual numbers that SCDC's strategy requires to be built. There is no justification for specifying the LDF figures as minima, to be exceeded by developers if they so wish.
The comment of GO-East on SP18 is "We suggest that the allocations are expressed as a range rather than a specific number to ensure the policy is sufficiently flexible", which at least has the merit of specifying the limits to the housing numbers. It also implies that GO-East view the 'specific number' as an actual figure, not a minimum, because they see it as being not sufficiently flexible, whereas if it were a minimum, it would be infinitely flexible.
Section 7.02 "The location for such a community remains at Martlesham although the location is specified as to south and east of Adastral Park" This is a much more precisely specified location than in the previous version of the LDF, which says: "The area of search for housing sites will extend in a "half collar" around the employment area at Martlesham Heath, including BT at Adastral Park. Opportunities for sites include within Martlesham village, on the old Felixstowe Road, the sand quarries east of Adastral Park and the farmland north of Waldringfield Road." (LDF Core Strategy, Preferred Options, §3.21) No reason has been given for narrowing the 'area of search' to the south and east of Adastral Park. In fact the opposite has happened - the advantage of a wider search area previously given has been removed: "There is also the ability to separate the area into distinct sections, thereby giving the opportunity to phase the development and also not to rely on one landowner" (Future Location Of Strategic Housing Growth In The Ipswich Policy Area , §4.3) [our emphasis]. There is only one landowner in the location to the 'south and east of Adastral Park': BT.
It is therefore difficult to avoid the conclusion that the LDF Core Strategy is being written to dovetail precisely with BT's planning application, C09/0555. (The new housing number, 2,000, is also exactly the number in the BT planning application). Instead of plan-led development, we now seem to have a BT-led planning strategy!
"Allocations at Key Service Centres to meet local needs and affordable housing provision" This allocation falls far short of meeting the need for affordable housing in rural areas, which is currently running at 2,722 homes per year in Suffolk (Delivering affordable housing in rural Suffolk, Ian Tippett Babergh's Strategic Housing Manager, 9 October 2009).
Section 7.03 "An allocation of 2,000 new homes be made at Martlesham". There is no justification for doubling the allocation. There is no identified need for the extra 950 houses. All the problems created by a 1,050 house development will be made much worse by a 2,000 house development.
"... integrate the development into the remainder of the Martlesham community, ..." It is difficult to see how this new development will be integrated into the Martlesham community when it is divided from Martlesham Heath by the A12 and several BT office buildings and car parks, and from Old Martlesham by the Martlesham Heath Business and Retail Park.
There seems to be confusion over whether the new community will be integrated or self contained. The quote above suggests the former, whereas "It is of sufficient size to provide a relatively self contained community" (§6.03, IPA Comment 1) and "the opportunity to provide for a more self contained development" (§6.03, IPA Comment 3) suggest the latter. Is it intended to be integrated or self- contained?
Section 7.06 "The target will be 330 new homes overall of which 1 in 3 will be affordable ones". Why is this target only mentioned for Key Service Centres? It should apply to all the areas: "There is a need for affordable housing across the district" (LDF Core Strategy, Preferred Options, §7.06) We wouldn't be so cynical as to suggest that the reason there is no mention of this target for the IPA is that BT don't want to have their profits reduced by having to provide 1 in 3 affordable homes, and that SCDC are acquiescing in this. The target of 1 in 3 affordable homes should be clearly stated as applying to the whole of the district, including the IPA. Section 8.02 "... the broad strategy that you have already commented, and which has achieved a large measure of agreement ...". The broad strategy hasn't achieved anything like a 'large measure of agreement'. The only 'large measure of agreement' that has been achieved is that it has been almost universally opposed by local residents in the IPA and Felixstowe.
Appendix 1 Suffolk Coastal District Council Local Development Framework Housing Allocations - Proposed Strategy Transport Appraisal - September 2009 It is admitted that: "... much of the analysis has been qualitative, and partial ..." (§8.7), and that there were many restrictions to the study method: * no new survey work * no new transport network modeling * no consultation * no iteration or optimization * no detailed traffic data available * a large range of uncertainties * calculations largely based on 2001 census data (i.e. 8 years old) (§1.3)
Yet despite all these problems, "no over-riding concerns have been identified" (§8.7) The Transport Appraisal may have failed to identify any over-riding concerns, but that is a failing of the document rather than because there are no causes for concern....
The Transport Appraisal misses out several major impacts on the road system: * the Orwell bridge (see comments on §6.03, Felixstowe/Walton and Trimley Villages Comment 3) * the A12/Barrack Square roundabout. Why was this omitted? It is the central junction onto the A12 from the proposed site, and is likely to take a large proportion of the traffic. * the road into Waldringfield. This is often congested. It is single track in places, with no pavements or street lighting. The residents of the proposed new town are very likely to visit the attractions of Waldringfield, which has the only beach on the river Deben between Woodbridge and Felixstowe Ferry, a popular riverside pub, the river itself with its boating possibilities, and many attractive footpaths along the Deben Estuary mud flats and surrounding countryside. The road cannot be widened, so it is inevitable that congestion will increase further with 4,800 people living 1.5 km up the road. * the use of Newbourne Road (from the Waldringfield Heath crossroads to the Red Lion at Martlesham) as a rat-run to avoid congestion on the A12. This is already happening, but with the extra traffic and the introduction of traffic lights on the A12 (with consequent delays), it will inevitably get much worse.
There doesn't seem to be anywhere in the Transport Appraisal that says what assumption is being made about the percentage of working householders who will have jobs at Adastral Park. (This is important because the lower this percentage is, the more commuting will occur). It does say: "Scenario 1, which accommodates 2,000 houses on Site 4, directly adjacent to a key employment area, would put employment opportunities and homes together and make travel to work by non car means a more realistic option." (§4.5.1). Also: "the sites proximity to Adastral Park allowing more trips to work to be made by other modes" (§3.2). Both of these statements ignore the evidence...
The evidence strongly suggests that the people who will live in the houses will be a completely different group from those employed in the area. Currently, only 3% of the employees at Adastral Park live within 1 mile of their work (according to the BT Planning Application C09/0555, Travel Plan, §5.11), and, since this is not due to a shortage of housing in the area, this percentage is unlikely to increase significantly with the new housing. It is therefore likely that at least 97% of the working residents of the new housing estate will work further afield. Adastral Park is a long way from the major sources of employment in Ipswich Town Centre and Ransomes Europark, with poor public transport links to the former and none to the latter. Trends in home working will make it even more likely that the future employees at Adastral Park will not live nearby.
The 5 scenarios used in the Updated Transport Appraisal do not make sense. All 5 scenarios consider the impact of 2,000 houses in the IPA (Table 2.3). So there is no straightforward way to answer the question "what is the impact of 2,000 houses at Adastral Park, compared with 1,050?" Scenarios 2-5 are totally unrealistic - SCDC's argument for 2,000 houses is that they all need to be in the same place (to "provide the basis for a significantly improved range of community facilities"). If 1,050 are located at Adastral Park what possible reason would there be to add an extra 950 to one of the other sites? These scenarios (2-5) are not mentioned anywhere else in the LDF documents, or in any of the other evidence documents.
Estimated peak hour person trip generation for proposed allocations East of Ipswich give a minimum of 2240 trips per day (this assumes the rush hour peaks last an hour each, and there is no extra traffic during the rest of the day, so it is obviously an underestimate). This is an increase of 106% compared with the corresponding figure for 970 houses (see table below) - more than double. (Why was 970 used rather than the actual housing proposal of 1,050?)
Person Trip Generation for Site 4 (East of Ipswich) (person trips per hour for the total dwelling allocation)
970 houses in Site 4 (Aug 2008, Table 8)
555 532 1087 2,000 houses in Site 4 (Sept 2009, Table 3.2, Scenario 1) AM PM Total 1143 1097 2240
Nowhere in this document is road safety mentioned. The important question: 'how will the increase in housing numbers affect the frequency and seriousness of road accidents?' is not asked, let alone answered.
Future Secondary School Provision: Alternative Sites Assessment Ipswich Policy Area "Demand for one new secondary school would normally be required for 5,000 new homes. However, given existing shortfalls in the area, this figure has been discounted by 1,500 homes. In addition, the potential development of Adastral Park would lead to approximately 2,000 new homes." (§3.2.3) How is the figure of 1,500 for existing shortfalls arrived at? It certainly does not agree with the figures given in §3.2.2:
The capacity of Kesgrave High School is 1,756 and the current school role is 1,777 - a capacity shortfall of 21. This is set to rise by over 100 pupils by 2012/13, giving a projected shortfall of 121. The capacity of Farlingaye High School is 1,839 and the current school role is 1,876 - a capacity shortfall of 37. This is set to fall by approximately 100 pupils by 2012/13, giving a projected over-capacity of 63. There is therefore a combined shortfall of 121-63 = 58 pupils, or 580 homes (assuming 1,000 homes generate 100 secondary pupils). This is very different from a shortfall of 1,500 homes.
What is the basis for the claim that 5,000 homes are required to justify building a secondary school? At the ratio assumed above, this would generate 500 pupils, which is very small for a secondary school. A more normal size is 1,200 pupils, requiring 12,000 houses to justify it (we are not suggesting 12,000 houses are built!)
Even if the shortfall is 1,500 homes, added to 2,000 new homes this would still only give 3,500 homes, 1,500 less than the 5,000 the report states are needed to justify a new secondary school. And even if 2,000 houses + the shortfall were sufficient for a new school, the full 2,000 will not be provided until 2025, so we will have 15 years before the new school is justified. Where will the secondary age pupils living in the proposed new town be educated in the meantime?
"Development on any of the alternative sites could potentially lead to an adverse impact on the landscape and loss of biodiversity." (§4.2.5) We strongly agree with this statement. The obvious conclusion is that they should not be developed.
"Environmental and other constraints at Adastral Park and Site 6 are considered to be surmountable with appropriate mitigation measures, including landscaping." (4.2.9) See our earlier comments on mitigation. Doing the wrong thing, then insisting that mitigation is put in place to lessen the impact is not a sensible strategy.
"there is a risk that the Adastral Park development will create a community which is considered separate from the existing neighbourhoods of Martlesham and Martlesham Heath" (§4.2.32) There certainly is this risk, which is another reason for not developing it.
Sustainability Appraisal "The sustainability of the new policy is higher than the previous version ... Concentrating development in the IPA is considered a more sustainable strategy" (§2.2) 3 reasons are given to justify this conclusion: "i) The employment offer in Ipswich is larger and more diverse than elsewhere in the District..." But the proposed site at Adastral Park is the furthest of the original 5 options from Ipswich, and has poor public transport services to the main centres of employment in Ipswich Town Centre and Ransomes Europark. "ii) TThere is the opportunity to create sustainable settlement(s) with distinctive identity with smaller readily distinguishable villages, neighbourhoods and communities within the larger area." There is no reason to believe (and no evidence supplied) that the one large settlement proposed will be any more sustainable than several smaller settlements. Why does this argument not hold in Felixstowe, where the choice was to disperse the housing? How do the current proposals promote "smaller readily distinguishable villages, neighbourhoods and communities within the larger area"? We already have these - the building of a 2,000 house new town will overwhelm several of them, making them less 'readily distinguishable'. "iii)Public transport provision and foot and cycle paths can be upgraded and promoted to minimise the need to use private motor vehicles with the major service centre of Ipswich nearby." This could and should be done anyway. It is unlikely that many people will switch from driving to cycling into Ipswich town centre, which is 7 miles away. Even if the promotion of public transport and cycling is successful, there will still be many more car journeys resulting from a 2,000 house development than a 1,050 one (more than double in fact - see comments on Transport Appraisal).
"The new policy is marginally less sustainable due to additions of land abutting Adastral Park being identified for development. This is greenfield land that includes current archaeological and biodiversity sites ..." (§2.4) This is certainly true (although we would disagree with the use of the word 'marginally' - 'significantly' would be more accurate). It is also in conflict with the general conclusion in §2.2.
"There is the additional concern about access to the countryside and proximity to the Deben SPA. Mitigation will need to take place ..." (§2.4) Once again the panacea of 'mitigation' is being used to try to lessen the harm done by a misguided policy. It is unlikely to be successful, because people cannot be prevented from visiting attractive but environmentally sensitive sites such as the Deben Estuary. Usually their remoteness acts as a deterrent for many people, but with nearly 5,000 people living just 1.5km away, that deterrent is no longer there.
Appropriate Assessment "Consultation with the public at draft stage was not considered necessary bearing in mind the conclusions of the draft assessment and the opportunity for public consultation at the Submission stage of the Core Strategy" (§4.1.3) The Submission stage of the LDF Core Strategy is too late for any comments on the contents of the document. Only comments on the soundness and legality of the LDF are allowed at that stage.
The document seems to be confused and full of self-contradictions. For example, there are several statements that indicate the extra housing will have an adverse impact on the Deben Estuary... "Natural England commented on the similar policy earlier numbered as SP3 that 'Any development is likely to bring additional pressure to any of the sites of European interest, however the area near Martlesham identified as a "preferred option" could have particularly negative impacts upon the Deben Estuary SPA/SSSI'." (§4.7)
"An allocation of 2000 houses at Martlesham could potentially cause problems to the Deben Estuary, from increased visitor use causing significant disturbance to SPA birds; trampling of water-edge habitat in Martlesham Creek containing a rare snail might also occur ..." (§6.2.31)
"It is therefore possible that visitor recreation activity would substantially increase on the foreshore of Deben Estuary SPA, bringing in high levels of disturbance to what is currently little disturbed and a 'refuge' area for SPA qualifying birds." (§6.2.32)
"It therefore cannot be ascertained that an allocation of 2000 new dwellings at Martlesham will have no adverse affect upon the integrity of Deben Estuary SPA near Martlesham" (§6.2.34)
However, despite these worrying comments, the opposite conclusion is reached... "it is unlikely that visitor recreation activity would substantially increase on the foreshore of Deben Estuary SPA at Martlesham, so there is expected to be no new high levels of disturbance" (§6.2.35)
This circle is squared by invoking 'mitigation', which seems to be little more than the hope that visitors will be deterred by the fact that they live more than 1km away and by the presence of other greenspaces (it is not clear where these will be)....
"with the proposed mitigation, Policy SP2 and related housing policies will have no adverse effect upon the integrity of any European site" (§7.3.1)
"Mitigation ... is based on providing alternative recreational choices for residents" (§7.2.7)
"Provided that strategic housing proposals for development at Martlesham are greater than 1km from the Deben estuary, and improvements to accessibility of natural greenspace are made, it is unlikely that visitor recreation activity would substantially increase on the foreshore of the Deben Estuary SPA at Martlesham" (§7.2.4)
This is totally unrealistic. The new housing will be 1.5km from the river Deben at Waldringfield - closer than any other likely greenspace, and easily within travelling distance, whether by car, bicycle or on foot. There is no possibility that the suggested 'greenspace' will contain a large attractive body of water, suitable for water-based activities and leisure pursuits, remotely comparable to the Deben Estuary.
Another implausible reason for believing that there won't be many extra visitors is the lack of a public car park at Waldringfield...
"The car park at the Deben Estuary at Waldringfield is privately operated for users of the pub and sailing club, and is not available as a starting point for estuary-side walks. Given this lack of available parking, it is possible to ascertain that the integrity of the Deben Estuary at Waldringfield will not be affected by the housing allocations at Martlesham either alone or in combination with housing provisions elsewhere." (§6.2.37)
It is not 'possible to ascertain' anything of the kind. Some people might decide to use the pub's car park and have a drink after their walk. Others might just use the car park and avoid the pub. Others might park somewhere else in Waldringfield, e.g. by the roadside, which happens all too often. Yet others might cycle or walk to Waldringfield. All of which will inevitably lead to "increased visitor use causing significant disturbance to SPA birds" (§6.2.31).
However, the document is confused even about the simple fact of whether or not there is a public car park at Waldringfield...
"with the nearest public car parks being in Woodbridge to the north and Waldringfield to the south." (§6.2.26)
Nowhere in this document is the impact of boating considered. It is highly likely that with around 5,000 people living just 1.5km up the road, the number of people using the river for water sports, power boating, sailing, fishing and canoeing will increase dramatically. It is acknowledged that boats are a problem: "On one estuarine site, disturbance to birds from boats was thought to be the biggest problem" (§5.5.6). However, no attempt is made to discover the extent of the problem, and by how much it will increase due to the new housing.
SCDC Response: 1, 4, 7, 8, 10, 12, 13, 15, 16, 17, 18, 19, 20
Respondent Name: Colin Archer Submission Agent Respondent ID: 568 ID: 568 ID: SUBMISSION Comments on LDF Core Strategy Housing Distribution Updated Preferred Option 7/09
Summary
I strongly object to your proposed increase in the number of houses in the Ipswich Policy Area. This will make all the disastrous impacts of the proposed new town at Adastral Park even worse. I do not feel there is any justification for going beyond the 1,050 figure, and there is no need to create a 'new community'. This totally inappropriate development will urbanise a beautiful rural area and have an overwhelming impact on local communities, the road system and the environment.
Section 1.02 "No decision will be taken in respect of individual sites submitted to the Council until the Core Strategy has been all but agreed". With the possible exception of very small scale, uncontroversial developments, no decisions should be taken until the Core Strategy has been fully adopted, i.e. has passed the independent examination stage.
Section 3.05 "... not everyone will be happy with what is proposed" This is true! In fact there has been an almost unanimous rejection of the proposed strategy by people living in the affected areas of the IPA and the Colneis peninsular. For example, in the Preferred Options consultation an analysis of individual responses to SP3 (Strategic Policies, Ipswich) reveals that 2 respondents supported the policy and 86 objected to it. The implication of this argument is 'whatever we do, someone will be unhappy, so we can ignore public opinion'. This is simply not true - there are other strategies (e.g. dispersed housing across the whole district) that would almost certainly be less unpopular than the one proposed. Section 5.09 "The main concerns related to the area East of Ipswich and Felixstowe/Walton and the Trimley villages where the bulk of the new homes are proposed. It is essentially in response to these issues that the original housing distribution strategy is now proposed to be revised." The implication of this is that the updated housing distribution (i.e. an increase in the IPA allocation from 1,050 to 2,000 houses) is in response to the concerns of the public. In fact it is exactly the opposite of what the public said in response to the previous consultation, in which the overwhelming majority objected to the concentration of 1,050 houses in one place. Section 5.12 "... the broad scale and distribution of development has evolved and refined over time as a result of public consultation" The decision to concentrate the housing distribution in the IPA into one large site was taken in complete opposition to the results of public consultations. For example, the February 2007 Issues & Options consultation produced the following result: * Option 1 (1 large site): 14% * Option 2 (2 or 3 large sites): 51% * Option 3 (a number of small sites): 35% However, in the following consultation (February 2008, Further Issues & Options), one of the questions was "Is your preference for one area of growth only or for more than one?" ('more than one' presumably meaning up to 5). Option 3 was totally ignored, despite the fact that it got more than double the support for option 1. Where was the opportunity to choose a large number of small sites? No figures were provided for the answers to the quoted question, no mention was made of the responses to this question in the Task Group's discussion, and the many arguments presented by the public in this and later consultations, in favour of a distributed allocation have been consistently ignored. The final decision to go for one large site is easily the least popular. Section 5.17 "None of the five options considered offered a perfect solution" This is a gross understatement - they were all appalling. However, the need to decide between them could have been avoided if a distributed housing strategy had been chosen. As it was, the decision to go for Area 4 (East of the A12) was made by applying the criteria in a completely biased way, conjuring up non-existent 'advantages' and ignoring Area 4's many disadvantages. The 'advantages' are non-existent, and the choice of Area 4 is therefore fatally flawed. Section 5.19 "All of these options however were rejected in favour of a Preferred Option dispersed strategy of "organic and evolutionary growth". No explanation has ever been given for the inconsistency between this decision in Felixstowe and the opposite decision in the IPA. The well argued and valid points supporting distributed housing in Felixstowe (LDF Core Strategy Preferred Options, §3.45) apply equally to the IPA. Section 6 SCDC's responses to many of the public's comments are totally inadequate. Many important points have been lost in the summaries, and many of the responses fail to deal with the real issues.... Section 6.03 Felixstowe/Walton and Trimley Villages Comment 3: "The A14 is unable to cope now let alone with increased traffic from the new housing" Response: "The traffic studies which have been done indicate that the A14 even with the additional lorry traffic which will result from the port expansion will be able to cope with the housing numbers proposed". Assuming this refers to Suffolk Coastal District Council Local Development Framework Housing Allocations Proposed Strategy Transport Appraisal, Sept. 2009, this document is seriously flawed (see comments on Appendix 1). Even if these flaws are ignored, the document says: "It is expected that the impact at the A14/A12 junction will be significant, and therefore a mitigation scheme will be required to ensure this does not have a detrimental impact on the operation of the junction." (§7.7) A major bottleneck on the A14 is the Orwell Bridge. This is not considered in the Transport Appraisal, but it is in the EERA Newmarket to Felixstowe Corridor Study, which says: "Demand on the Orwell Bridge is forecast to increase in the future. The Highways Agency, in the A14 Girton to Felixstowe Congestion Study, forecast that the stress level on the Orwell Bridge will increase to 0.90 in 2009 and 0.98 in 2014. The Highways Agency East of England Transport Model indicates that, by 2021, daily traffic volumes may have reached 76,000, representing a stress level in the order of 1.12. In the morning peak period, the model forecasts an eastbound "demand" flow of over 4,400 pcus, compared to an "actual" flow of 3,400. This suggests that over 30% of the demand in the peak hour will not actually be able to flow through the link because of congestion." (§4.18) . "When the CRF (Congestion Reference Flow) is reached (i.e. a stress level of 1.0), hourly traffic demand is likely to exceed the maximum hourly throughput of the link, with the result that traffic flow breaks down with speeds varying considerably, average speed drops significantly, and the sustainable throughput is reduced and queues are likely to form." (§4.17) The problems described above do not take account of the extra traffic due to the proposed 2,000 and 1,000 houses in the IPA and the Felixstowe area respectively, or the possible port expansion. Ipswich Policy Area - East of A12 Comment 1: "The numbers of houses currently proposed is too great." Response: "To reduce the numbers would mean not meeting RSS requirements as well as resulting in a development which was little more than an overgrown housing estate" The numbers could easily be reduced by re-assigning some of the allocation to the rest of the district (where there is a large identified need for affordable housing), thus keeping the total the same. Dispersal of the allocation over many sites would not result in an 'overgrown housing estate'. Comment 2: "1,000 is insufficient to provide a standalone Community" Response: No mention is made of the rather telling fact that only one respondent made this comment - David Lock, on behalf of BT, the owners of the land in question. The many comments questioning the need for a new standalone community have been ignored. SCDC's support for this position is in stark contrast to the arguments previously used to justify a single site of 1,050 houses, which apparently was needed to create a sustainable community. No mention had been made previously that 1,050 would not be enough. No explanation has been given as to why 1,050 houses were considered sufficient to create a sustainable community in 2008 but now 2,000 are needed. Did the planning officers get their sums wrong (by a factor of 2)? Response: "A larger allocation provides the basis for a significantly improved range of community facilities" This is a self-justifying, circular argument: 2,000 houses are needed to justify providing the facilities, but the only reason the facilities are needed is to service the 2,000 houses! According to the RSS, a genuine need only exists for 1,050 houses - if this number were built, and they were dispersed over the IPA or better still throughout the rest of Suffolk Coastal, the need for new facilities and infrastructure would be far less (and the cost to the taxpayer less). Response: "The evidence suggests that the benefits do indeed outweigh the disbenefits." No justification is given for this conclusion. What evidence? What supposed benefits? No evidence of genuine benefits has been provided, but there are many disbenefits: * Urbanisation of a rural area * Destruction of local communities * Impact of additional traffic on the roads * Damage to environmentally sensitive areas nearby, and the wildlife they protect * Increase in pollution and greenhouse gases * And many more.... Comment 3: "Adverse impact on existing communities at Martlesham, Martlesham Heath and Waldringfield" Response: "... but which triggers the need for additional infrastructure, particularly secondary education ..." Even 2,000 houses are insufficient to trigger the provision of a new secondary school (according to Future Secondary School Provision Alternative sites Assessment IPA, "Demand for one new secondary school would normally be required for 5,000 new homes" (§3.2.3)) Even taking into account the existing shortfall, a new school will not be justified (see comments on Appendix 1). Response: "It also offers the opportunity to better mitigate the potential impact of visitors and residents on the neighbouring countryside and estuary ..." It is perverse and illogical to argue that more houses will have a lesser impact, even with 'mitigation'. Response: "The lie of the land in the proposed area, coupled with the fact that much of the land involved either has been or is scheduled to be used for mineral extraction, is such that the degree of the disbenefit from damage to the landscape, loss of agricultural land and the like from the increased size of this allocation is limited, ..." This ignores the fact that the mineral extraction is a temporary situation, with planning permission conditional on the land being returned to its original state when the extraction has finished. Building in this location actually means the loss of agricultural land, or more accurately lowland heathland, which it was within living memory (pre-1960s for most of it). Lowland heathland is a scarce habitat which should be conserved and re-created: "In areas that support lowland heathland, there should be a presumption in favour of re-establishing heathland on derelict land or land that has been used for mineral extraction." (UK Biodiversity Action Plan). Comment 4: "Unacceptable impact on the neighbouring wildlife and countryside" Response: "Development on this scale must be undertaken as part of a comprehensive development which places significant emphasis on mitigating these potential impacts." 'Mitigation' is a word that is grossly overused in this document. 'Papering over the cracks' would be a more appropriate phrase. Doing the wrong thing, then insisting that mitigation is put in place to lessen the impact is not a sensible strategy. No amount of 'mitigation' will be able to undo the damage created by such an enormous and inappropriate development. This damage will be made far worse by doubling the number of houses. Twice the number of houses means twice the number of people, dogs, cats, cars, boats, etc, as well as twice the amount of noise, light pollution, car exhaust pollution, water consumption, etc., and therefore twice the amount of impact on the neighbouring wildlife and countryside. The response that the impact on the neighbouring wildlife and countryside can be overcome is contradicted by SCDC's own Appropriate Assessment: "Any development is likely to bring additional pressure to any of the sites of European interest, however the area near Martlesham identified as a "preferred option" could have particularly negative impacts upon the Deben Estuary SPA/SSSI" (SCDC Core Strategy Appropriate Assessment, Appendix 4) Comment 5: "Unacceptable Impact on the primary and local road network" Response: "However the impact of 2,000 homes as opposed to 1,000 on individual junctions etc when linked to new and improved transport infrastructure is limited but will help to secure the necessary developer funding to secure these upgrades to a good standard" How can the impact of 2,000 homes as opposed to 1,000 be 'limited'? 2,000 homes will have roughly double the impact of 1,000 homes: twice the number of car journeys and twice as much traffic congestion. This is confirmed by comparing the figures in the two Transport Appraisals (Aug 2008 and Sept 2009): person trips per hour for the total dwelling allocation is 1087 (970 houses) and 2240 (2,000 houses) - an increase of 106%. (Aug 2008: Table 8, Car Driver, Total Trips figures: 555 (am) + 532 (pm) = 1087. Sept 2009: Table 3.2, Scenario1, Car Driver, Total Trips figures 1143 (am) + 1097 (pm) = 2240) (see comments on Appendix 1). In either case, upgrades to road junctions, etc would presumably be proportionate to the increase in traffic. Surely developer funding to 'secure these upgrades to a good standard' can be demanded no matter how many houses are proposed. A dispersed housing policy would avoid having to do any major upgrades, because the traffic impact would be much more diluted. The argument that securing developer funding to pay for changes that are only needed because of the new housing, is (as with the general point about infrastructure) a self-justifying, circular argument. If this new town were not built, the developer funding to widen roads, etc would not be needed. The Transport Appraisal says: "The combined impact of the allocations to the east of Ipswich and the Market Towns will have a considerable impact on this difficult junction [the A12/ A1214 Junction]." (§7.5.2) and: "the impact on the local road network, in particular the A12, is unavoidable and considerable improvement would be required at a number of A12 junctions to preserve existing service levels" (§4.5.1) Both these quotes support Comment 5. Conclusion: "Consideration should be given to an alternative housing distribution" Response: The response to this comment fails to address the issue; it is simply a repetition of responses to comments 1-6, and suffers from the same failings. An 'alternative housing distribution' means distributing the houses over several (or even better, many) small sites, instead of one large site. It doesn't mean having to find another large site capable of accommodating 2,000 houses, which is the implication of the sentence: "The area has lower negative impacts on landscape quality and public amenity overall than other potential alternatives" Section 7.01 "Allocations are expressed as minimum figures consistent with the approach of the Regional Spatial Strategy - The East of England Plan". Although the East of England Plan figures are indeed minima, this only means that SCDC is free to exceed them in the LDF if it wishes. If the LDF figures could be treated as minima, it would make a farce of the whole enterprise of strategic planning - nobody would know even approximately how many houses will actually be built! The figures provided in the LDF are not minima, they are the actual numbers that SCDC's strategy requires to be built. There is no justification for specifying the LDF figures as minima, to be exceeded by developers if they so wish. The comment of GO-East on SP18 is "We suggest that the allocations are expressed as a range rather than a specific number to ensure the policy is sufficiently flexible", which at least has the merit of specifying the limits to the housing numbers. It also implies that GO-East view the 'specific number' as an actual figure, not a minimum, because they see it as being not sufficiently flexible, whereas if it were a minimum, it would be infinitely flexible. Section 7.02 "The location for such a community remains at Martlesham although the location is specified as to south and east of Adastral Park" This is a much more precisely specified location than in the previous version of the LDF, which says: "The area of search for housing sites will extend in a "half collar" around the employment area at Martlesham Heath, including BT at Adastral Park. Opportunities for sites include within Martlesham village, on the old Felixstowe Road, the sand quarries east of Adastral Park and the farmland north of Waldringfield Road." (LDF Core Strategy, Preferred Options, §3.21) No reason has been given for narrowing the 'area of search' to the south and east of Adastral Park. In fact the opposite has happened - the advantage of a wider search area previously given has been removed: "There is also the ability to separate the area into distinct sections, thereby giving the opportunity to phase the development and also not to rely on one landowner" (Future Location Of Strategic Housing Growth In The Ipswich Policy Area , §4.3). There is only one landowner in the location to the 'south and east of Adastral Park': BT. It is therefore difficult to avoid the conclusion that the LDF Core Strategy is being written to dovetail precisely with BT's planning application, C09/0555. (The new housing number, 2,000, is also exactly the number in the BT planning application). Instead of plan-led development, we now seem to have a BT-led planning strategy! "Allocations at Key Service Centres to meet local needs and affordable housing provision" This allocation falls far short of meeting the need for affordable housing in rural areas, which is currently running at 2,722 homes per year in Suffolk (Delivering affordable housing in rural Suffolk, Ian Tippett Babergh's Strategic Housing Manager, 9 October 2009). Section 7.03 "An allocation of 2,000 new homes be made at Martlesham". There is no justification for doubling the allocation. There is no identified need for the extra 950 houses. All the problems created by a 1,050 house development will be made much worse by a 2,000 house development. "... integrate the development into the remainder of the Martlesham community, ..." It is difficult to see how this new development will be integrated into the Martlesham community when it is divided from Martlesham Heath by the A12 and several BT office buildings and car parks, and from Old Martlesham by the Martlesham Heath Business and Retail Park. There seems to be confusion over whether the new community will be integrated or self contained. The quote above suggests the former, whereas "It is of sufficient size to provide a relatively self contained community" (§6.03, IPA Comment 1) and "the opportunity to provide for a more self contained development" (§6.03, IPA Comment 3) suggest the latter. Is it intended to be integrated or self-contained? Section 7.06 "The target will be 330 new homes overall of which 1 in 3 will be affordable ones". Why is this target only mentioned for Key Service Centres? It should apply to all the areas: "There is a need for affordable housing across the district" (LDF Core Strategy, Preferred Options, §7.06) We wouldn't be so cynical as to suggest that the reason there is no mention of this target for the IPA is that BT don't want to have their profits reduced by having to provide 1 in 3 affordable homes, and that SCDC are acquiescing in this. The target of 1 in 3 affordable homes should be clearly stated as applying to the whole of the district, including the IPA. Section 8.02 "... the broad strategy that you have already commented, and which has achieved a large measure of agreement ...". The broad strategy hasn't achieved anything like a 'large measure of agreement'. The only 'large measure of agreement' that has been achieved is that it has been almost universally opposed by local residents in the IPA and Felixstowe. Appendix 1 Suffolk Coastal District Council Local Development Framework Housing Allocations - Proposed Strategy Transport Appraisal - September 2009 It is admitted that: "... much of the analysis has been qualitative, and partial ..." (§8.7), and that there were many restrictions to the study method: * no new survey work * no new transport network modeling * no consultation * no iteration or optimization * no detailed traffic data available * a large range of uncertainties * calculations largely based on 2001 census data (i.e. 8 years old) (§1.3) Yet despite all these problems, "no over-riding concerns have been identified" (§8.7) The Transport Appraisal may have failed to identify any over-riding concerns, but that is a failing of the document rather than because there are no causes for concern.... The Transport Appraisal misses out several major impacts on the road system: * the Orwell bridge (see comments on §6.03, Felixstowe/Walton and Trimley Villages Comment 3) * the A12/Barrack Square roundabout. Why was this omitted? It is the central junction onto the A12 from the proposed site, and is likely to take a large proportion of the traffic. * the road into Waldringfield. This is often congested. It is single track in places, with no pavements or street lighting. The residents of the proposed new town are very likely to visit the attractions of Waldringfield, which has the only beach on the river Deben between Woodbridge and Felixstowe Ferry, a popular riverside pub, the river itself with its boating possibilities, and many attractive footpaths along the Deben Estuary mud flats and surrounding countryside. The road cannot be widened, so it is inevitable that congestion will increase further with 4,800 people living 1.5 km up the road. * the use of Newbourne Road (from the Waldringfield Heath crossroads to the Red Lion at Martlesham) as a rat-run to avoid congestion on the A12. This is already happening, but with the extra traffic and the introduction of traffic lights on the A12 (with consequent delays), it will inevitably get much worse. There doesn't seem to be anywhere in the Transport Appraisal that says what assumption is being made about the percentage of working householders who will have jobs at Adastral Park. (This is important because the lower this percentage is, the more commuting will occur). It does say: "Scenario 1, which accommodates 2,000 houses on Site 4, directly adjacent to a key employment area, would put employment opportunities and homes together and make travel to work by non car means a more realistic option." (§4.5.1). Also: "the sites proximity to Adastral Park allowing more trips to work to be made by other modes" (§3.2). Both of these statements ignore the evidence... The evidence strongly suggests that the people who will live in the houses will be a completely different group from those employed in the area. Currently, only 3% of the employees at Adastral Park live within 1 mile of their work (according to the BT Planning Application C09/0555, Travel Plan, §5.11), and, since this is not due to a shortage of housing in the area, this percentage is unlikely to increase significantly with the new housing. It is therefore likely that at least 97% of the working residents of the new housing estate will work further afield. Adastral Park is a long way from the major sources of employment in Ipswich Town Centre and Ransomes Europark, with poor public transport links to the former and none to the latter. Trends in home working will make it even more likely that the future employees at Adastral Park will not live nearby. The 5 scenarios used in the Updated Transport Appraisal do not make sense. All 5 scenarios consider the impact of 2,000 houses in the IPA (Table 2.3). So there is no straightforward way to answer the question "what is the impact of 2,000 houses at Adastral Park, compared with 1,050?" Scenarios 2-5 are totally unrealistic - SCDC's argument for 2,000 houses is that they all need to be in the same place (to "provide the basis for a significantly improved range of community facilities"). If 1,050 are located at Adastral Park what possible reason would there be to add an extra 950 to one of the other sites? These scenarios (2-5) are not mentioned anywhere else in the LDF documents, or in any of the other evidence documents. Estimated peak hour person trip generation for proposed allocations East of Ipswich give a minimum of 2240 trips per day (this assumes the rush hour peaks last an hour each, and there is no extra traffic during the rest of the day, so it is obviously an underestimate). This is an increase of 106% compared with the corresponding figure for 970 houses (see table below) - more than double. (Why was 970 used rather than the actual housing proposal of 1,050?) Person Trip Generation for Site 4 (East of Ipswich) (person trips per hour for the total dwelling allocation) AM PM Total 970 houses in Site 4 (Aug 2008, Table 8) 555 532 1087 2,000 houses in Site 4 (Sept 2009, Table 3.2, Scenario 1) 1143 1097 2240 Nowhere in this document is road safety mentioned. The important question: 'how will the increase in housing numbers affect the frequency and seriousness of road accidents?' is not asked, let alone answered. Future Secondary School Provision: Alternative Sites Assessment Ipswich Policy Area "Demand for one new secondary school would normally be required for 5,000 new homes. However, given existing shortfalls in the area, this figure has been discounted by 1,500 homes. In addition, the potential development of Adastral Park would lead to approximately 2,000 new homes." (§3.2.3) How is the figure of 1,500 for existing shortfalls arrived at? It certainly does not agree with the figures given in §3.2.2: The capacity of Kesgrave High School is 1,756 and the current school role is 1,777 - a capacity shortfall of 21. This is set to rise by over 100 pupils by 2012/13, giving a projected shortfall of 121. The capacity of Farlingaye High School is 1,839 and the current school role is 1,876 - a capacity shortfall of 37. This is set to fall by approximately 100 pupils by 2012/13, giving a projected overcapacity of 63. There is therefore a combined shortfall of 121-63 = 58 pupils, or 580 homes (assuming 1,000 homes generate 100 secondary pupils). This is very different from a shortfall of 1,500 homes. What is the basis for the claim that 5,000 homes are required to justify building a secondary school? At the ratio assumed above, this would generate 500 pupils, which is very small for a secondary school. A more normal size is 1,200 pupils, requiring 12,000 houses to justify it (we are not suggesting 12,000 houses are built!) Even if the shortfall is 1,500 homes, added to 2,000 new homes this would still only give 3,500 homes, 1,500 less than the 5,000 the report states are needed to justify a new secondary school. And even if 2,000 houses + the shortfall were sufficient for a new school, the full 2,000 will not be provided until 2025, so we will have 15 years before the new school is justified. Where will the secondary age pupils living in the proposed new town be educated in the meantime? "Development on any of the alternative sites could potentially lead to an adverse impact on the landscape and loss of biodiversity." (§4.2.5) We strongly agree with this statement. The obvious conclusion is that they should not be developed. "Environmental and other constraints at Adastral Park and Site 6 are considered to be surmountable with appropriate mitigation measures, including landscaping." (4.2.9) Doing the wrong thing, then insisting that mitigation is put in place to lessen the impact is not a sensible strategy. "there is a risk that the Adastral Park development will create a community which is considered separate from the existing neighbourhoods of Martlesham and Martlesham Heath" (§4.2.32) There certainly is this risk, which is another reason for not developing it. Sustainability Appraisal "The sustainability of the new policy is higher than the previous version ... Concentrating development in the IPA is considered a more sustainable strategy" (§2.2) 3 reasons are given to justify this conclusion: "i) The employment offer in Ipswich is larger and more diverse than elsewhere in the District..." But the proposed site at Adastral Park is the furthest of the original 5 options from Ipswich, and has poor public transport services to the main centres of employment in Ipswich Town Centre and Ransomes Europark. "ii) There is the opportunity to create sustainable settlement(s) with distinctive identity with smaller readily distinguishable villages, neighbourhoods and communities within the larger area." There is no reason to believe (and no evidence supplied) that the one large settlement proposed will be any more sustainable than several smaller settlements. Why does this argument not hold in Felixstowe, where the choice was to disperse the housing? How do the current proposals promote "smaller readily distinguishable villages, neighbourhoods and communities within the larger area"? We already have these - the building of a 2,000 house new town will overwhelm several of them, making them less 'readily distinguishable'. "iii)Public transport provision and foot and cycle paths can be upgraded and promoted to minimise the need to use private motor vehicles with the major service centre of Ipswich nearby." This could and should be done anyway. It is unlikely that many people will switch from driving to cycling into Ipswich town centre, which is 7 miles away. Even if the promotion of public transport and cycling is successful, there will still be many more car journeys resulting from a 2,000 house development than a 1,050 one (more than double in fact - see comments on Transport Appraisal). "The new policy is marginally less sustainable due to additions of land abutting Adastral Park being identified for development. This is greenfield land that includes current archaeological and biodiversity sites ..." (§2.4) This is certainly true (although we would disagree with the use of the word 'marginally' - 'significantly' would be more accurate). It is also in conflict with the general conclusion in §2.2. "There is the additional concern about access to the countryside and proximity to the Deben SPA. Mitigation will need to take place ..." (§2.4) Once again the panacea of 'mitigation' is being used to try to lessen the harm done by a misguided policy. It is unlikely to be successful, because people cannot be prevented from visiting attractive but environmentally sensitive sites such as the Deben Estuary. Usually their remoteness acts as a deterrent for many people, but with nearly 5,000 people living just 15km away, that deterrent is no longer there. Appropriate Assessment "Consultation with the public at draft stage was not considered necessary bearing in mind the conclusions of the draft assessment and the opportunity for public consultation at the Submission stage of the Core Strategy" (§4.1.3) The Submission stage of the LDF Core Strategy is too late for any comments on the contents of the document. Only comments on the soundness and legality of the LDF are allowed at that stage. The document seems to be confused and full of self-contradictions. For example, there are several statements that indicate the extra housing will have an adverse impact on the Deben Estuary... "Natural England commented on the similar policy earlier numbered as SP3 that 'Any development is likely to bring additional pressure to any of the sites of European interest, however the area near Martlesham identified as a "preferred option" could have particularly negative impacts upon the Deben Estuary SPA/SSSI'." (§4.7) "An allocation of 2000 houses at Martlesham could potentially cause problems to the Deben Estuary, from increased visitor use causing significant disturbance to SPA birds; trampling of water-edge habitat in Martlesham Creek containing a rare snail might also occur ..." (§6.2.31) "It is therefore possible that visitor recreation activity would substantially increase on the foreshore of Deben Estuary SPA, bringing in high levels of disturbance to what is currently little disturbed and a 'refuge' area for SPA qualifying birds." (§6.2.32) "It therefore cannot be ascertained that an allocation of 2000 new dwellings at Martlesham will have no adverse affect upon the integrity of Deben Estuary SPA near Martlesham" (§6.2.34) However, despite these worrying comments, the opposite conclusion is reached... "it is unlikely that visitor recreation activity would substantially increase on the foreshore of Deben Estuary SPA at Martlesham, so there is expected to be no new high levels of disturbance" (§6.2.35) This circle is squared by invoking 'mitigation', which seems to be little more than the hope that visitors will be deterred by the fact that they live more than 1km away and by the presence of other greenspaces (it is not clear where these will be).... "with the proposed mitigation, Policy SP2 and related housing policies will have no adverse effect upon the integrity of any European site" (§7.3.1) "Mitigation ... is based on providing alternative recreational choices for residents" (§7.2.7) "Provided that strategic housing proposals for development at Martlesham are greater than 1km from the Deben estuary, and improvements to accessibility of natural greenspace are made, it is unlikely that visitor recreation activity would substantially increase on the foreshore of the Deben Estuary SPA at Martlesham" (§7.2.4) This is totally unrealistic. The new housing will be 1.5km from the river Deben at Waldringfield - closer than any other likely greenspace, and easily within travelling distance, whether by car, bicycle or on foot. There is no possibility that the suggested 'greenspace' will contain a large attractive body of water, suitable for water-based activities and leisure pursuits, remotely comparable to the Deben Estuary. Another implausible reason for believing that there won't be many extra visitors is the lack of a public car park at Waldringfield... "The car park at the Deben Estuary at Waldringfield is privately operated for users of the pub and sailing club, and is not available as a starting point for estuary-side walks. Given this lack of available parking, it is possible to ascertain that the integrity of the Deben Estuary at Waldringfield will not be affected by the housing allocations at Martlesham either alone or in combination with housing provisions elsewhere." (§6.2.37) It is not 'possible to ascertain' anything of the kind. Some people might decide to use the pub's car park and have a drink after their walk. Others might just use the car park and avoid the pub. Others might park somewhere else in Waldringfield, e.g. by the roadside, which happens all too often. Yet others might cycle or walk to Waldringfield. All of which will inevitably lead to "increased visitor use causing significant disturbance to SPA birds" (§6.2.31). However, the document is confused even about the simple fact of whether or not there is a public car park at Waldringfield... "with the nearest public car parks being in Woodbridge to the north and Waldringfield to the south." (§6.2.26) Nowhere in this document is the impact of boating considered. It is highly likely that with around 5,000 people living just 1.5km up the road, the number of people using the river for water sports, power boating, sailing, fishing and canoeing will increase dramatically. It is acknowledged that boats are a problem: "On one estuarine site, disturbance to birds from boats was thought to be the biggest problem" (§5.5.6). However, no attempt is made to discover the extent of the problem, and by how much it will increase due to the new housing.
SCDC Response: 1, 4, 10, 11, 12, 13, 15, 16, 17, 18, 19, 20
RESPONSE TO PUBLIC CONSULTATION ON HOUSING DISTRIBUTION Please see relevant reference numbers
ALL AREAS – GENERAL ISSUES
1. The Consultation Process
Comments:
• The time to respond was too short • The ‘drop-in’ sessions were insufficient • No maps were displayed • There should have been public meetings • The consultation system is too complicated • Previous comments have not been listened to • There should be a full new consultation, not focused • There was no publicity
SCDC Response 1: These comments are noted. Eight weeks is longer than the minimum required for this type of consultation. Early warning that the consultation was due to take place during September was provided to all parish and town councils immediately following the Cabinet meeting in July. All the public on our LDF database were also individually informed of the consultation.
A significant number of people did attend each ‘drop-in’ and this number compared favourably to other LDF sessions run previously. With regard to information on display, this was limited due to the nature of the consultation. A number of people were under the misapprehension that what would be on show would be actual sites. This was not the purpose of the consultation at this stage.
The reason for holding “drop-in” sessions as opposed to public meetings was to attract a wider range of people and particularly those who would not feel comfortable in a public meeting environment. The view was also taken that town and parish council meetings would provide a further opportunity for people to express their views locally.
The Council has a new consultation system which is considered to be easier to use than the previous system. We received very few questions about the system during the consultation and those received were easily solved. Details of the consultation system were available on the Council’s website and email and hard copies of responses were all accepted.
All the current and previous consultation comments have been taken into account. Changes to the document have been made as a result of some of these comments. There will always be differing opinions between respondents so the document cannot be changed to directly comply with them all. However, this ensures that the Council is made aware of residents concerns and can make alterations to address these as best as possible. While appreciating that not everyone is able to or wants to respond, the Council also considers the population who do not respond.
The Core Strategy and Development Management Policies Preferred Option was consulted on in full for a 10 week period between Decemeber 2008 until February 2009. This consultation included the full range of topics including housing, the environment, the economy and community issues. A significant number of responses were received to this consultation. In a Cabinet meeting of 7th July 2009, there was a large level of agreement for the document although the housing issues were not agreed which is why this further focused consultation was carried out.
2. Base data
Comments:
• The base information is out of date
SCDC Response 2: The base date for the housing figures in the consultation document was deliberately kept at 31st March 2008. This was to enable people to make a straight comparison with housing information provided as part of the previous consultation that took place over the winter 2008.
The Core Strategy has now been revised to contain housing figures based on the position on the 31st March 2009 and with an end date of 2026.
ALL AREAS – HOUSING NUMBERS AND DISTRIBUTION
3. Numbers of Houses
Comments:
• The numbers proposed are unjustified • The Council should not accept government proposals for the district • Why has the windfall number gone down so much?
SCDC Response 3: The amount of new housing to be provided across the District between 2001 and 2021 is set out in the Regional Spatial Strategy – the East of England Plan, adopted in May 2008. This is set at 3200 for that part of the district within the Ipswich Policy Area and 7000 dwellings for the rest of the district for the period to 2021. These figures are minimums and the Council has no choice but to provide them.
In addition, the government through Planning Policy Statement 3 Housing requires Local Planning Authorities to identify in their LDF’s a 15 year housing land supply from the expected date of adoption of the plan. With the additional round of consultation which has just taken place, the anticipated adoption date for the Core Strategy has now moved to 2011, therefore the end date of the plan will now be 2026.
In order to arrive at the housing requirement post 2021, government advice is that the annual housing requirement should be added to that total figure. For Suffolk Coastal this amounts to an additional 510 per year.
If the Council did not accept government proposals for the district, an Inspector would find the plan ‘unsound’. This could lead to speculative planning applications which the Council would then struggle to resist.
Windfall’ is as defined nationally in PPS3, ie
“Windfall sites are those which have not been specifically identified as available in the local plan process. They comprise previously-developed sites that have unexpectedly become available. These could include, for example, large sites resulting from, for example, a factory closure or small sites such as residential conversion or a new flat over a shop.”
The Council assumes that this definition includes infilling within gardens and residential curtilages.
However, the estimate of ‘windfall’ is restricted to small sites only (less than 0.2 hectares) and not the extensive range as referred to in the national definition. For this reason the figure used in the calculations is likely to be an underestimate. Furthermore, the assumed figure for ‘windfall’, calculated from its occurrence in the 5 year period 2003 to 2008, has been discounted by one third given that it is assumed to be a limited supply. It has also been restricted to the third period 2021-2026.
The Council has historically experienced a significant housing contribution through windfall development and it is therefore justified that the Council should allow for a reasonable amount in the future housing figures. However, there has previously been criticism of the Council's housing figures that they rely too heavily upon unpredictable windfall growth which is contrary to PPS3. The revised estimate means the Council can demonstrate that a windfall allowance has been made, but there is not an overreliance upon windfall in the housing figures.
4. Distribution of Houses
Comments:
• the housing should be more evenly distributed across the district • there should be a wider distribution across the whole of Suffolk • more development should be directed to the market towns and smaller villages to secure their long- term viability • support from some rural communities that the numbers are acceptable • some additional housing could be allocated around Saxmundham and Leiston in association with any new Sizewell C development
SCDC Response 4: The housing numbers that the Council is required to provide are set out in the Regional Spatial Strategy (RSS). Other Councils have housing requirements that need to be met. Within Suffolk Coastal, the RSS housing requirement is split between the Ipswich Policy Area and the remainder of the district. This is the minimum number of houses that the Council is required to provide.
Beyond this broad split it is for the Council to decide how housing development is to be dispersed across the district. The latest proposed strategy has evolved over time and reflects the very different circumstances of the individual settlements and areas across the district (as reflected in the individual strategies formulated for each market town) and has regard to individual community plans. Throughout the Core Strategy preparation process, a number of different housing distribution options have been considered, and consulted upon to arrive at the latest housing distribution to be consulted upon. The Housing Distribution: Updated Preferred Option 7/09 does propose a dispersed distribution, but one that is in accordance with the principles of sustainability, and is in accordance with an agreed Settlement Hierarchy that directs the majority of development to the larger settlements. It also reflects generally the current distribution of the housing stock across the district. This distribution is confirmed as being in conformity with the RSS and follows more general national planning policy advice.
There are a number of policies suggested in the development management policies that provide flexibility to ensure that rural communities can have the right level of development commensurate with their size, to ensure that these villages and small settlements continue to thrive and support existing service provision. As well as the proposed 490 allocations, a significant proportion of the existing planning permissions are within the rural communities, the physical limits boundaries will be looked at to potentially include further windfall sites, policy DM1 offers an incentive to to bring forward exception sites and the clusters policy (DM4) has been introduced. Further opportunities may occur when individual village envelopes are reviewed in consultation with local communities.
See also Responses 15, 16 and 22 relating to housing
5. The Review of the Regional Spatial Strategy (RSS)
Comments:
• What is the relevance of the RSS review and the fact that additional numbers of houses are being discussed?
SCDC Response 5: the RSS review has no bearing on the current discussion on housing distribution. The figures under discussion relate to the current adopted RSS East of England Plan. When the Core Strategy is reviewed it will take account of any revised housing requirements in the RSS.
6. Five Year Land Supply of Housing
Comments:
• The Council does not have the evidence to demonstrate the availability of sites • There is no published Strategic Housing Land Availability Assessment (SHLAA)
SCDC Response 6: Local Planning Authorities through their LDF’s are required to demonstrate a 15 year housing land supply from the expected date of adoption of the plan. They should identify sufficient, specific, deliverable sites to provide the first five years of housing provision.
For Suffolk Coastal, looking forward to 2015 there are adequate sites considered to be sufficiently well advanced as to have a reasonable chance of coming forward if the Core Strategy justifies the location. The Five Year Housing Land Supply Assessment published in December 2009 shows the Council to have a District wide supply of 6.9 years, therefore exceeding the minimum 5 year requirement. However, with the adoption of the Core Strategy not due until early 2011 it is essential that its progress is not delayed thereby ensuring that the Site Specific Allocations development plan document can follow shortly after and housing provision can be made up through properly identified and planned housing allocations.
However, there are sites that have been assessed in terms of their compliance with the draft Core Strategy and in terms of physical and other known constraints. They are identified as such in the Councils (currently) draft Strategic Housing Land Availability Assessment. A number of respondents have commented on the fact that the council does not have a published SHLAA. The information on which it draws is however publicly available. It is, nonetheless, advanced and due for publication and its current absence should not be taken as an indication that early planning decisions on unallocated sites should be taken. Early release of speculative sites could prejudice the overall strategy for the district and more particularly for individual areas.
7. The Balance Between Housing and Employment
Comments:
• Employment numbers generally are reducing due to the recession, home working etc reducing the need for houses • A reduction in employment at the Port should mean a reduction in the amount of housing at Felixstowe • The creation of a ‘Growth Point’ should not simply be based on the presence of the Port • BT is reducing employees, therefore increased housing numbers are not justified
SCDC Response 7: With regard to the rural economy, new housing is promoted at those settlements considered most sustainable, i.e. the market towns and the key and local service centres. These are the settlements that already have a range of facilities, where investment is sought in relation to public transport through the identification of key transport links; and where service providers will be encouraged to continue to invest and to concentrate provision.
With regard to the approaches to East of Ipswich and Felixstowe/Trimleys, both areas are linked to strategic employment sites. With regard to Felixstowe, the strategic objective is for regeneration of the town and for a diversification of the local economy to lessen the reliance on the Port. The scale of new housing proposed is commensurate with this objective, providing for more than locally generated needs and enabling the opportunity for people who currently commute into the town to live closer to their work, thereby lessening the impact on the strategic road network.
With regard to East of Ipswich the proposed housing is linked to a strategic employment site. Within it BT is a major employer but there are a wider range of businesses operating within this area. BT is also an anchor for attracting other ICT related employment. The Council is backing the development of a new Innovation Hub at Adastral park which would provide space alongside support facilities for small businesses. Progress is being made on this project which could result in 200 new jobs in the ICT sector.
ALL AREAS – SUSTAINABILITY APPRAISAL
8. The Sustainability Appraisal (SA) Methodology
Comments:
• Challenges to the methodology and outputs associated with the Sustainability Appraisal (SA) of the Core Strategy & Development Management Policies • Many public objections in particular were in relation to the assessment under-representing the possible environmental impacts which may occur from development • Greater mitigation and provision needs to be given towards greenspace provision – and access to it – in order to suitably minimise or avoid any perceived adverse affects of the Core Strategy • The SA should be updated to reflect the findings of the Water Cycle Study in terms of assessments consistent with SA Objective 10 – water quality.
SCDC Response 8: The SA was undertaken independently by officers at Suffolk County Council in conformity with the requirements of the Planning & Compulsory Purchase Act, 2004 and using national Government guidance on undertaking SA reports.
The SA process has been used to inform the planning policy decision making process for the Core Strategy and predict and analyse the potential impact of alternative policy options. It does not determine or define the policy as some respondents assume. As stated in national Government Guidance:
“it is not the role of the SA to determine the option(s) to be chosen as the basis for the preferred options and the draft plan. This is the role of those who have to decide which strategy is appropriate. The role of the SA is to assist with the identification of the appropriate options, by highlighting the sustainability implications of each…”
Sustainability appraisal is not concerned solely with the environment. It has regard to economic and social matters as well. The Council is satisfied that it has been carried out on an objective basis having regard to all the relevant considerations and utilising all the data available. The methodology for undertaking the SA has been consistent with Government national guidance and best practice. To weight the findings in favour of the environment would not represent an objective appraisal.
9. Appropriate Assessment (AA)
Comments:
• the need to recognise the importance and designation of the environmental sites • the AA fails to evaluate the effect any potential boating recreational impacts associated with the estuary • The report appeared to be contradictory stating that it could not be possible to rule out potential harm to designated sites, but also stating that harm would not be caused due to various mitigation measures. • concern has been raised about the methodology used in the report and the type and extent of mitigation proposals • concern about what happens in terms of the monitoring process for potential impacts. Further visitor management plan studies should be undertaken in advance of proposal decisions. • additional attention needs to be paid to the impact of increased recreational trampling and also any chemical fluctuations caused by surface water run off or discharge from additional waste water treatment infrastructure
SCDC Response 9: The AA was commissioned by the Council and carried out by specialist consultants, with advice from Natural England (NE). The purpose of AA of land use plans is to ensure that protection of the integrity of European sites is a part of the planning process at a regional and local level. Policies SS8 and ENV1 of the East of England Plan also requires that local authority plans avoid harm to environmental sites of European and international importance and seek to provide networks of accessible green infrastructure linked to urban areas. It is a sequential process including scoping for likely significant effects, assessment of potential significant effects and consideration of suitable abatement/mitigation measures for any identified impacts. The AA assessed all relevant parts of the Core Strategy and Development Management Policies. As agreed in consultation with NE, the AA was undertaken using secondary data and has been scrutinised by NE throughout the whole process. This has been clarified in a document published alongside the AA and made available on the Council’s web site.
See also Response 17 relating to the environmental impact of hosuing at Martlesham
ALL AREAS – TRANSPORT
10. The Lack of Depth to the Transport Study
Comments:
• Validity of the data used • No attention paid to the impact on local roads
SCDC Response 10: The transport study that provides input into the choice of housing locations is general and strategic in its nature. Given such a high level context specific transportation measures cannot be identified or costed in detail. However, a broad understanding of the transport mitigation measures required has been identified and modelling work has been carried out to take on board relevant large committed developments that are likely to affect the highway network in the Ipswich Policy Area and the Felixstowe Peninsula.
The key point to note is the traffic study is designed to provide information on principles and not detail. This is the nature of the Core Strategy. More detailed traffic /highways information will obviously be required in relation to individual sites at the next stage ie when specific allocations are made and parameters are set, eg development area, access points etc. It is also at this stage that alternative options in terms of design and access solutions would be considered and consulted upon.
In some cases road improvements to the local road network will be necessary insofar as it will be needed to support new housing (and employment) in this area. These will be an important element of the infrastructure to be funded or contributed towards by development.
See also Responses 11-13, 19 and 26 relating to Transport.
11. The Approach Towards Transport
Comments:
• Insufficient/inadequate alternative public transport to support new homes • Naivety of assuming that people will live close to their place of work
SCDC Response 11: Concern is expressed that existing public transport is insufficient and inadequate and that it is just wishful thinking that residents of the new houses will use public transport or will choose to live close to where they work.
These types of concern are not new. The LDF cannot force individuals to live close to where they work, what they can do is provide the opportunity for them to do so. What the Transport Study does provide is evidence of new public transport routes that need to be created in order to provide a credible alternative to using cars. It therefore provides the evidence base on which to secure investment from public transport providers and for contributions from developers. It also points to the need for improved foot and cycle links to provide a proper network to encourage movement by these means. Given the issues relating to the capacity of the Orwell Bridge, contributions to and early provision of public transport provision should be identified as an essential and early item of infrastructure.
The District Council and Suffolk County Council work continuously to help to provide improved public transport services to the rural communities. A demand responsive scheme has recently been launched.
See also Responses 10, 12, 13, 19 and 26 relating to transport
12. The A14 and Orwell Bridge
Comments:
• Concern over the capacity of the Orwell Bridge • The A14 and its junctions have insufficient capacity to support additional housing, particularly given the predicted number of lorries
SCDC Response 12: A lot of concern has been expressed that the Transport Study carried out on behalf of the Council makes insufficient reference to the capacity of the A14 and in particular the capacity of the Orwell Bridge. It was not the intention that this should be addressed as part of the Transport Appraisal for the Core Strategy because it is being addressed elsewhere.
The scale of development required to be provided within Suffolk Coastal is set out in the Regional Spatial Strategy (RSS) East of England Plan, adopted May 2008. This document was itself supported by transport studies which looked specifically at the strategic road network and what impact these strategic levels of development would have upon it. Key studies are the 2005 Newmarket to Felixstowe Corridor Study; and the Haven Gateway Ipswich A14 Corridor Study in 2007. These studies consider scales of development that are proposed in the RSS, regardless of precisely where they will be located.
It is this second study which is of most relevance. This highlights the fact that the Orwell Bridge is a pinch point, and that there is a possibility that it will reach capacity within the plan period. Part of the reason for this is that it serves a dual function serving both local and strategic movements. In order to address this issue various possible solutions are being considered. The most cost effective short/medium term solution is likely to be a set of wider traffic management measures to reduce the amount of local traffic using this stretch of road. All relevant local authorities, including Suffolk Coastal, are working together, using the land-use planning system where possible, to implement a variety of measures including siting housing close to employment and other facilities, identifying key public transport links and looking to secure investment in improved or new public transport routes, improving bus and rail stations, the introduction of travel plans etc. Further measures might include high- occupancy vehicle lanes, increased park and ride etc.
See also Responses 10, 11, 13, 19 and 26 relating to Transport.
13. The A12
Comments:
• Increased traffic will cause gridlock on the A12 and the junctions with the A1214 and A14
SCDC Response 13: In respect of the eastern fringe of Ipswich, the primary traffic flows are considered to be north and south along the A12, the A14 to Felixstowe and the A1214 into Ipswich. Maintaining the free flow of traffic on the A12 given its strategic importance as a north south route through the District is a major objective. Securing the necessary road improvements to the A12 as would be needed to serve new housing (and employment) in this area would be a major element of the infrastructure that new development would be expected to fund or contribute towards. The transport infrastructure studies for the Ipswich and Felixstowe Areas will provide the basis for arguing for highway improvements as well as other traffic management measures.
Encouraging modal shift towards greater use of public transport and providing alternative options of walking and cycling are also important elements in any transport solution.
See also Responses 1-12, 19 and 26 relating to Transport
14. Other Transport Issues
Comments:
• The impact of Sizewell should be taken into account • The impact on the Woodbridge Bypass
SCDC Response 14: Since the Transport Appraisal was completed, the government has confirmed that Sizewell is one of the locations being considered at the national level to provide a new nuclear power plant. One respondent notes that there is a potential conflict in terms of the A12 if improvements to junctions around Martlesham Heath are undertaken at the same time heavy traffic linked to the construction of a new plant at Sizewell is also on the road and the potential congestion/conflict that this may cause. The point is noted for consideration should Sizewell be selected.
Other issues, such as Woodbridge, are noted.
MARTLESHAM & EAST OF IPSWICH
15. The Approach Towards Housing
Comments:
• Dispersal is an alternative (why Felixstowe but not here?) that is not explored sufficiently • Brownfield sites should be allocated and developed before greenfield ones
SCDC Response 15: With regard to the infrastructure required to meet the needs of 2000 dwellings it will be the same whether the housing is concentrated or dispersed. However, with a concentrated development its provision would be easier to identify and co-ordinate and there would be economies of scale. 2000 dwellings in a single location is sufficient for example to provide a new health centre. A dispersed option merely puts additional strain on existing premises and GP practices and makes it harder to identify any new sites required. The practical effect is that people will live further from amenities – leisure, health, shops, education etc – with a consequential effect on traffic movements and their quality of life.
On larger allocations sites can be identified from the outset. The critical mass for securing new public transport routes and thereby alleviating traffic on the primary and local road networks would also be better achieved on large developments. This is borne out in the infrastructure and transport studies. Furthermore, large developments present the opportunity to create inclusive and interactive communities rather than dormitory suburbs.
The Council’s priority will be to find and allocate previously developed ‘brownfield’ sites if at all possible with ‘greenfield’ sites developed second. This will minimise the loss of agricultural land currently used for food production. The District Council proposes a target of 50% of dwellings being built on brownfield/previously developed land in the district between 2009 and 2026. Considering the nature of the district, with few areas of previously developed land, this target will be challenging.
16. The Principle of Locating 2000 houses at Martlesham
Comments:
• Developing east of A12 especially at this scale will set a precedent for further development in this area in the future • The size of the development compared to Martlesham and other market towns • The urbanising influence a development of this type will have on the local area
SCDC Response 16: Ipswich and the IPA are recognised in regional plans as locations for growth as well as designated as a Growth Point. Its status is that of a ‘Key Centre for Development and Change’ with the clear objective of encouraging people to live close to work and facilities. The Council’s draft strategy for new housing to be developed east of the A12 is clearly consistent with this, largely due to the presence of a substantial employment centre there. However, there is the opportunity, by increasing the proposed housing numbers, to create a self-contained and sustainable community to include community, leisure, education and health facilities as well as employment. This might not be achieved if the number of new houses is restricted to 1000, particularly in respect of local education provision.
No inference should be taken re the future location of housing beyond the current plan period. Those decisions will be made as part of the proper planning process led by a review of the Core Strategy.
The layout and form of the housing development will be carefully planned from the outset so that the impact and perception can be mitigated through careful design and the provision of boundary planting. The area to be developed will contain space for community facilities and infrastructure. The proposed allocation will not subsume existing settlements into a larger development. The existing settlements would retain their rural character. This allocation would provide the opportunity to plan a development that would be well integrated into the existing landscape and related to existing communities without adversely impacting upon them. All of these principles will be clearly set out in an Area Action Plan which will be the subject of public consultation.
See also Responses 7, 15 and 17-21 relating to housing in the IPA.
17. The Environmental Impact of 2000 Houses at Martlesham
Comments:
• Key concerns include: – Impact on the environment - especially the Deben estuary and villages – Loss of agricultural land – Impact on the AONB – Impact on flora/fauna – The mineral working should be restored to greenspace
SCDC Response 17: There is no doubt that developing 2000 dwellings in a single location east of the A12 will represent a significant challenge to ensuring that the character of the area will not be adversely affected, and can be delivered in a planned way to meet all the competing planning demands. It will create a community roughly equivalent to the communities of old Martlesham and Martlesham Heath combined. Key to achieving a successful development will be to define the area within which development can take place, but which includes land required for the provision of strong strategic landscaping to contain built development, to construct new boundaries to development and to limit its impact on the AONB and surrounding rural area, including the estuary which is designated for its national and international importance for wildlife. For developments further than 1km away from designated sites, Natural England are satisfied that, providing a number of mitigation measures are in place, the proposed housing distribution will not have a likely significant effect on the SPA (for more details on these mitigation measures please refer to the comments received from Natural England) The National Trust make specific reference to any development needing to respect the Anglo Saxon landscape. Any scheme would need to have regard to this.
With regard to the numbers of visitors to the estuary, it should be noted that in overall terms the addition of 2000 houses up to 2026 will only increase the housing stock by a relatively small percentage (16.5% across the Ipswich Policy Area) such that this development would not significantly exacerbate existing issues. Waldringfield is an existing visitor honey-pot, visited by many residents of Ipswich and beyond and has for example a thriving sailing club frequented by people who live outside the village etc. A range of mitigation measures is possible in any event. One of the mitigation measures proposed is a new Country Park within the IPA. Reference to this will be made in SP20. Early implementation of the mitigation measures, such as those relating to warden provision, would help address existing as well as future issues.
See also Responses 9, 15, 16 and 18 relating to housing and the AA
18. The Impact of 2000 Houses on Neighbouring Communities
Comments:
• Development will change what is a rural aspect/ambience/character to an urban one • Waldringfield will be swamped
SCDC Response 18: Developing in the area suggested in the Core Strategy will bring development somewhat closer to the village of Waldringfield than is currently the case. Setting a minimum distance and creating strong development boundaries will be required to mitigate this impact in terms of visual impact, noise, light, etc. The design of the road, foot and cycle path layouts will be critical to directing the bulk of traffic movement away from the rural area more generally, and providing good links in particular to alternative areas for recreation.
See also Responses 9, 16 and 17 relating to the AA and housing at Martlesham.
19. The Transport Impact of 2000 Houses at Martlesham Heath
Comments:
• Impact on the local road network, including Waldringfield • Impact on local highway safety • Pollution • Missing data on individual junctions such as A12/Eagle Way/Barrack Square roundabout
SCDC Response 19: Concerns in relation to the impact additional development would have on the local road network are to be expected. The Transport Study considers potential trips across a wide area based on impacts on key junctions but does not look, and is not designed to specifically look at, individual more minor roads. However, securing the necessary road improvements to the local road network insofar as it would be needed to serve new housing (and employment) in this area would be an important element of the infrastructure to be funded, or contributed towards, by development.
With regard to the A12 /Eagle Way/Barrack Square junction this is considered in the Traffic Study albeit not singled out. The report deals with the section of road between A12/Foxhall Road/Newbourne Road and the A12/Tesco roundabout as a corridor. When looking at the potential impact of traffic from 2000 dwellings on land south and east of Adastral Park as suggested in the draft Core Strategy it has been assumed that the majority of traffic will enter and exit this area from those two main roundabouts. The A12/Eagle Way roundabout will effectively then deal with through traffic.
Highway safety and emergency service provision is more relevant at the detailed stage rather than being an issue for the Core Strategy.
See also Responses 10-13 relating to transport issues.
20. Infrastructure
Comments:
• If development has to occur it should be accompanied by the guarantee of new or improved infrastructure provision up front • Lack of schools, health provision and other infrastructure to support the additional population • 2000 dwellings is not sufficient to provide a new secondary school • Adastral Park is not the best location for a new school • Existing communities will struggle in the early phases with access to services such as doctors until new facilities are in place • Impact on emergency vehicles on the A12 • Ipswich Hospital is struggling and unlikely to receive funding from developers • Broadband speeds are below government targets • Impact on waste recycling centre • Simplistic and misleading assumptions of water supply and waste water treatment capacity
SCDC Response 20: The provision of appropriate infrastructure, at the right time, is fundamental to the successful implementation of the Core Strategy. The Council intends that the Local Development Framework for Suffolk Coastal will include an Area Action Plan for Martlesham. This will address infrastructure and its delivery to ensure that requirements are identified as well as the means of achieving them, including the use of developer funding.
An infrastructure study has been carried out for the Ipswich Area which clearly sets out the potential future requirements, timing and phasing of all the main infrastructure. This study is part of the Council’s evidence base and will be used to help argue for funding for infrastructure from both developers and service providers.
See also Responses 10-13 and 19 relating to transport and Response 15 relating to housing.
21. Deliverability
Comments:
• The Council is putting ‘all its eggs in one basket’ by identifying one site • Over-reliance on that one site could prejudice housing land supply • Development at Martlesham is reliant on the extraction of minerals from the site therefore concern that land will not be available within the first phase of the plan to provide housing in this area so additional sites should be investigated.
SCDC Response 21: This issue is raised primarily in relation to housing land supply. Whilst a number of respondents express concern that development on this site is unlikely to take place within the first phase of the plan (to 2015), the Council is satisfied that some early on-site provision could take place. In any event, it should be noted also that this is not the only area where development will take place during the plan period in the wider Ipswich Policy Area. There are a number of outstanding planning permissions and other brownfield opportunities. It is considered that any concerns in this regard can be addressed.
FELIXSTOWE & TRIMLEYS
22. The Approach Towards Housing
Comments:
• A reduction in housing numbers is unjustified and not backed up by a sound evidence base • The Council is simply responding to objections rather than considering the evidence • There is nothing wrong with being a ‘retirement town’ – this may be Felixstowe’s ‘niche’ • 1000 houses is still too many
SCDC Response 22: In Felixstowe housing growth has not kept pace with employment growth. In the 5 years April 2003 to April 2008 (ie pre-recession) the average annual construction rate was only 36 dwellings per year. As a result commuting into the town exceeds commuting out and affordable housing has not been achieved in any significant numbers. An independent study of the town in 2005 revealed some negative aspects of the town – a population age imbalance, an ageing population, the reliance on one major employer, the threat to services and facilities, a failing resort, the fragility of the town centre and a lack of affordable housing. The study advocated growth, with a range of scenarios put forward. It also promoted the need to support jobs.
The Council has responded to public consultation and recognised that, although limited growth for the right reasons has some support, there are doubts at this time about the ability of the town’s infrastructure to accommodate it. There is concern for the environmental setting, and there are doubts about the predicted jobs occurring at a rate that would complement the proposed housing growth. A commitment to securing the regeneration of the town nonetheless remains a key objective of the Strategy and to do this, a certain level of growth is required.
Therefore, it might be more practical in the earlier period of the Core Strategy to manage growth. This should be distributed across settlements of Felixstowe, Trimley St Martin, Trimley St Mary and Walton in locations within or abutting the built up areas avoiding as far as possible prime agricultural land for essential food production. The environmental setting of the town and access to the countryside will, therefore, remain undisturbed until such time as an increase in the pace and scale of change is demonstrated to be in the best social and economic interests of the town.
See also Response 4 relating to housing distribution
23. Environmental Impact
Comments:
• Potential detrimental impact on the countryside and landscape setting of Felixstowe and the Trimleys • There will be an unnecessary loss of high quality agricultural land • Too much greenfield land is being developed unnecessarily
SCDC Response 23: With regard to greenfield sites, the strategy remains clearly one where brownfield sites should be developed first. Additional work has already been commissioned to identify what brownfield opportunities exist within the town, but will also include “developed” areas of greenfield land e.g. redundant farm buildings, where such opportunities exist within the distribution strategy as currently framed.
See also Response 9 relating to the AA.
24. Relationship With the Port
Comments:
• A reduction in employment at the Port should mean a reduction in the amount of housing • The creation of a ‘Growth Point’ should not simply be based on the presence of the Port
SCDC Response 24: The Port is an important economic driver within the Haven Gateway sub-region and within the national context e.g. around 40% of all UK food imports enter the country via Felixstowe. The strategy is both to support the continued growth of the Port as well as to encourage greater diversification within the local economy. The Core Strategy has to plan for the longer term beyond the current economic recession. More people currently commute into the town to work than commute out. Providing an additional level of housing to begin to address this imbalance will have added benefits of providing potentially more spending within the town and reducing private motor traffic on the A14.
25. Infrastructure
Comments:
• There is an obvious lack of infrastructure to support new housing • Additional infrastructure should be in place first before houses are constructed
SCDC Response 25: The provision of appropriate infrastructure, at the right time, is fundamental to the successful implementation of the Core Strategy. The Council intends to prepare a ‘Delivery Plan’ in some form to ensure that requirements are identified as well as the means of achieving them, including the use of developer funding. The Community Infrastructure study provide the evidence base to underpin this.
See also Responses 10-13 relating to transport.
26. Transport
Comments:
• The A14 junctions (Dock Spur, Trimley, Seven Hills, etc) do not have the capacity • Walton High Street and Trimley High Road will be overloaded (gridlocked?)
SCDC Response 26: Continuing concern is expressed that scales of development are still too much given the fact that it is a peninsula, with limited road and rail access. In particular there is a lack of alternative road access for HGV traffic during ‘Operation Stack’. The Transport Study commissioned by the Council makes clear that for this area the impact of development on the transport network has been much more difficult to define than for elsewhere due to the draft strategy which is for one of dispersed rather than concentrated development. The findings are cautioned on this basis. It concludes that the most impact is likely to be on the local road network rather than the A14. The exact nature of this impact is difficult to assess as no individual sites are identified. Broad assumptions have been made in relation to individual areas in terms of development potential for guidance only. They do not and cannot confirm the level of development of any potential development site as this is not its role.
Relief to Walton High Street and Trimley High Road may be ensured by the construction of a new link road from the High Road to Candlet Road. However, pending further assessment, there is currently considerable concern as to whether acceptable access from / egress to Candlet Road can be achieved. Furthermore, there is a significant risk of any through road acting as a “rat-run” from Felixstowe to the A14. The selection of sites to be allocated in order to implement a strategy of dispersal will need to be made with this in mind.
See also Responses 10-13 relating to transport.
OTHER SETTLEMENTS
27. The Settlement Hierarchy
Comments:
• Few comments received. Key concerns of those submitted:
– Orford & Gedgrave, Otley, Westleton and Yoxford confirm capacity to absorb further development but do not request a change in their status – Darsham Parish Council has evidence to support upgrade to Key Service Centre – Bucklesham Parish Council requests downgrading to Other Village – Impact of development at market towns on rural roads – Warning of over-development of market towns – Lack of development opportunities in Local Service Centres
• Woodbridge - concern that 200 new dwellings on greenfield sites could be too much • Early phases of development should be spread across the market towns and not concentrated • Felixstowe is not considered to be a major centre
SCDC Response 27: These comments are all noted. The Core Strategy has now been altered to include a proportion of the proposed allocations to be within Local Service Centres.