Felixstowe Peninsula Area Action Plan

Analysis of Responses to the Issues and Options Public Consultation October 2015

Consultation Period 19th October 2015 - 30th November 2015

Suffolk Coastal…where quality of life counts Contents Record of how Issues and Options consultation documents were distributed and promoted ...... 4 General Comments ...... 7 Do you have any thoughts on the approach the Council has followed? Is there an alternative approach that you think should be considered for the more detailed distribution of housing in the , Walton & the Trimleys as set out in the Core Strategy and why? ...... 7 Presentation of documents...... 15 Evidence Base...... 18 Spatial and Sustainability...... 19 Q1. How can links with the Port be enhanced? ...... 19 Q2. Any opportunities for improvements to the road and rail networks? ...... 19 Q3. Which parts of the road network are at capacity? ...... 19 Q4. How can links between the AAP and Felixstowe Futures be successful? ...... 21 Housing...... 22 Q5. What sites identified in the SHLAA 2014 need to be allocated/ brought forward for development? ...... 22 Q6. Which SHLAA 2014 sites should be discounted? ...... 22 Q7. Do we need to consider any other residential sites? ...... 22 Q9. What type and style of developments do communities want to see on future residential sites? Which sites would be appropriate for flats and other smaller units and which sites would be appropriate for larger units? ...... 22 Q10. What will be the cumulative impact of bringing these residential sites forward? ...... 22 Q8. Is the Council correct to remove the areas to be protected from development not within the Physical Limits Boundaries such as around Falkenham Church...... 43 The Economy...... 43 Q11. Are all the employment sites within the Felixstowe Peninsula still required? ...... 43 Q12. Are there any other potential employment sites which need to be brought forward? ...... 44

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 1 Q13. Should uses on employment sites be restricted to traditional B1 (Business), B2 (General Industry) and B8 (Storage and Distribution) uses or do we need to take a more flexible approach? ...... 46 Q14. Do any other sites surrounding the Port of Felixstowe need to be included within the Strategic Employment Areas? ...... 46 Q15. Is the current town centre boundary still appropriate? ...... 47 Q16. Should any areas be included or excluded from the town centre boundary? ...... 48 Q17. Does the primary shopping area need to be extended to include areas fronting the Triangle? ...... 48 Q18. Should the boundaries of the existing District Centres be re-defined? ...... 49 Q19. Do any other District Centres or Local Centres need to be identified as part of the Felixstowe Peninsula AAP? ...... 49 Q20. Is it necessary to protect the existing car parks through a specific allocation? ...... 50 Q21. Can the tourism needs of Felixstowe be met under one blanket criteria based policy? ...... 51 Q22. Are there any tourism related policies which the Council need to retain as specific policies? ...... 51 Environment...... 53 Q23. Should policies protecting Landscape and Townscape features be combined as there are certain similarities within these designations which seek to avoid material adverse impact upon these areas? If so, should there be one policy to cover these designations, or should some division be maintained? ...... 55 Q24. Is the criteria within the Special Landscape Area policy (AP13) still appropriate? ...... 56 Q25. What does the Coastal Change Management policy need to include? ...... 56 Q26. Local Plan Saved Policy AP1 on Conservation Areas is more detailed that the other policies. Is this extra detail justified, and if so does this warrant a separate policy for Conservation Areas? ...... 57 Q27. Should the policy on Areas to be Protected from Development be combined with the policy on Conservation Areas, as Areas to be Protected from Development have similar protection to areas identified in conservation areas which should not be developed? ...... 58 Q28. Should policies be written to consider proposals for development affecting protected wildlife or geodiversity sites or landscape areas or are they adequately covered by the Core Strategy? ...... 58 Q29. Which sites across the Felixstowe Peninsula need to be identified to protect and enhance biodiversity and geodiversity as detailed Core Strategy policy SP14? ...... 59 Q30. Which sites across the Felixstowe Peninsula need to be identified and protected to resist settlement coalescence as detailed by Core Strategy policy SP15? ...... 59 Q31. How can the Felixstowe Peninsula AAP promote a network of green infrastructure? ...... 59

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 2 Community and Well-Being issues...... 60 Q32. Are the current open space designations appropriate? ...... 60 Q33. Are there any other areas which ought to be protected through an open space designation? ...... 60 Q34. What are the opportunities for improving green infrastructure within the Felixstowe Peninsula? ...... 61 Q35. What types of open space, sport and play facilities, community facilities are needed to generate a sustainable community? ...... 62 Q37. Would the Felixstowe Peninsula benefit from greater community facilities/opportunities? ...... 64 Suggestions regarding specific ‘saved’ Local Plan policies and future policy development...... 65 Maps of new sites submitted through Issues and Options Consultation Period…………………………………..………………………………………………………………………………………………………..…69

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 3 Analysis of Response to the Felixstowe Peninsula Area Action Plan Issues and Options Consultation

Issues and Options Consultation 15 December 2014 – 27 February 2015.

Below is a series of table outlining the measures the Council undertook to promote and advertise the Issues and Options Consultation. The actions and extent of the distribution and consultation activities was guided by the SCDC Statement of Community Involvement (adopted September 2014) as well as government regulations and examples of best practice. The information is provided as a record of what the Council undertook for that particular stage and as Local Plan documents evolve other methods of consultation and engagement may be used from time to time.

Record of how Issues and Options consultation documents were distributed and promoted.

Type Document Date sent How documents were published and who received a copy Consultation Site Allocations and Area Specific Policies DPD 17/12/2014 - Published on SCDC website documents - Published on JDi - SCDC Members -Town/parish clerks -Members of the working group -Libraries Felixstowe Peninsula Area Action Plan 17/12/2014 - Published on SCDC website - Published on JDi - SCDC Members -Town/parish clerks -Members of the working group -Libraries Map Booklets Map booklet for Woodbridge Housing Market Area 17/12/2014 - Published on SCDC website (HMA) - Published on JDi - SCDC Members -Town/parish clerks -Members of the working group -Libraries Map booklet of East Policy Area (EIPA) 17/12/2014 - Published on SCDC website HMA - Published on JDi - SCDC Members Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 4 -Town/parish clerks -Members of the working group -Libraries Map booklet for Framlingham HMA 17/12/2014 - Published on SCDC website - Published on JDi - SCDC Members -Town/parish clerks -Members of the working group -Libraries Map booklet for Saxmundham HMA 17/12/2014 - Published on SCDC website - Published on JDi - SCDC Members -Town/parish clerks -Members of the working group -Libraries Map booklet for Felixstowe HMA 17/12/2014 - Published on SCDC website - Published on JDi - SCDC Members -Town/parish clerks -Members of the working group -Libraries Draft Woodbridge HMA 17/12/2014 - Published on SCDC website Sustainability -Members of the working group Appraisal EIPA HMA 17/12/2014 - Published on SCDC website -Members of the working group Framlingham HMA 17/12/2014 - Published on SCDC website -Members of the working group Saxmundham HMA 17/12/2014 - Published on SCDC website -Members of the working group Felixstowe HMA 17/12/2014 - Published on SCDC website -Members of the working group Saved Policies Saved Policies 17/12/2014 -Members of the working group Letters General letter 11/12/2014 -Everyone on LDF database Statutory Consultees 11/12/2014 -Statutory consultees Letter to town/parish council 11/12/2014 - Town/parish councils Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 5 Promotional Poster 11/12/2014 -6 posters sent to every Town/parish councils material -Libraries - Additional posters also sent on request Drop in session poster 16/01/2015 -GP surgeries -Dental Practices -Members Leaflet -Town/parish councils - SCDC Members - Additional leaflets also sent on request Press releases Press release 1 15/12/2014 -Published in Coastline magazine - Published in East Anglian Daily Times - Published on SCDC website Press release 2 13/01/2015 -Sent to some parish magazines to be included in their February issue+ other magazines - Published on SCDC website Social Media Twitter Posts January – - SCDC Twitter Feed February - Visit Felixstowe Twitter Feed

Public Drop in sessions were held at various locations across the district.

Venue Date of Session Trimley St Martin Memorial Hall 26/01/2015 Kesgrave Community Centre 27/01/2015 Walton Community Hall 29/01/2015 Saxmundham Town Hall 29/01/2015 Felixstowe Town Hall 03/02/2015 Riverside Centre, Stratford St Andrew 05/02/2015 Council Chamber, Council Offices, Woodbridge 09/02/2015

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 6 The drop in sessions, publication and engagement undertaken generated a lot of interest in the consultation documents. The Council received the number of representations for each document as seen in the table below.

Document Number of Responses Site Allocation and Area Specific Policies DPD 831 Felixstowe Area Action Plan DPD 254

Below is a summary of each individual representation received in respect of the Felixstowe Peninsula Area Action Plan. The comments are presented in the order of the consultation questions outlined within the Issues and Options consultation document. Against each representation is a summary of the comments, the Council’s analysis of the comments and how these have impacted on the Preferred Options document.

FELIXSTOWE PENINSULA AREA ACTION PLAN Analysis of Response to the Felixstowe Peninsula Area Action Plan Issues and Options Consultation

Respondent Summary of comments Analysis / Comment Recommendation

General Comments Do you have any thoughts on the approach the Council has followed? Is there an alternative approach that you think should be considered for the more detailed distribution of housing in the Felixstowe, Walton & the Trimleys as set out in the Core Strategy and why? General Comments Recommendation Suffolk County Discussions which have taken place are revealing Suffolk County Council are a key partner References have been made throughout the Council a number of matters which will need to be in the delivery of the AAP and the Preferred Options document to the input Suffolk considered. These include, but are not limited to: Council welcome their continued County Council have had and these requirements involvement and engagement. These have been translated into policy requirements  Assessment of highway impacts, promotion of matters, and others, have been where appropriate. Where areas of further work sustainable travel options and whether or not considered through officer level are required the Council will continue to work in sites can be delivered without cumulative severe discussions as part of the work to partnership with the County Council to ensure this Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 7 transport impacts. prepare the Preferred Options work is undertaken at the relevant times.  Delivery of key infrastructure, including consultation. education, libraries and waste facilities.  Promotion of countryside access in a manner consistent with ecological requirements.  Consideration of how development can meet the needs of an ageing population.  Management of air quality issues in some areas.  Meeting the objectives of the Suffolk Health and Wellbeing Strategy. Historic I note that the SCDC SHLAA formed a significant Comments noted. Information in relation to the range of heritage part of the evidence base, but as noted in our assets, conservation areas and locally listed previous letter we would expect the evidence features is made within the Environment section of base to include a list of all designated heritage the Preferred Options document. The policies assets within the AAP area, and separately within the Preferred Options document identify those on the Historic England 'at Risk' complement those found within the Core Strategy. Register. The AAP area includes a range of heritage assets. In addition there may be other undesignated but locally significant heritage assets. The 2014 Heritage at Risk Register includes 2 of the 3 Martello Towers, the Grade II* listed Church of St Andrew in Felixstowe and Felixstowe South conservation area. Little Glemham Little Glemham Parish Council. With regard to the Noted. All town and parish council’s will be notified of Parish Council Felixstowe Area Action Plan Issues & Options future consultation periods and invited to make Document [Dec'14] the council again agreed to comments. acknowledge receipt of the document, as presented, with no further comment. Kirton Parish Held a village meeting, attended by over 155 Noted. The Planning Policy Team were Opinions expressed at the meeting and in the Council people representing the community of pleased to be invited and attend the consultation response have been included within approximately 600 households. Output from the meeting during the Issues and Options the Preferred Options document. meeting is direct evidence of the community Consultation period. need for a sustainable community to be maintained and developed. Michael Maps of Brown field Site and prime agricultural Noted. Brownfield sites across the Peninsula have been Ninnmey land needed. considered as part of the work the Council Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 8 undertook for the 2014 SHLAA which has demonstrated that brownfield opportunities are limited. Providing a map of these limited opportunities is not considered appropriate. Natural England identifies the prime agricultural land across the country and is available as an up to date on line resource. Comments of Objection Gillian Mason The strategic employment centre of the Residential opportunities in close Preferred housing sites are required to provide peninsula is focused to the south and west, proximity to the port are limited and footpath and cycle links to link in with existing concentrating on the Port and some retail and the housing options are considered to communities as well as providing alternatives to tourism. We would point out that the biggest be in accordance with the Core Strategy use of the private motor car. Sites across the housing sites deemed suitable by the Council regarding housing distribution and Felixstowe Peninsula are well related to local (sites 502e and 451g) are to the north and east, growth across the district. employment opportunities as appropriate. and are therefore not 'sustainable' as this word is defined in para 6.1. No Adastral The Martlesham, Newbourne and Waldringfield The area is covered by the Site No change. New Town Area Action Plan is not mentioned in any of the Allocations and Area Specific Policies documents/maps. The area covered by the DPD, the Martlesham Neighbourhood Martlesham, Newbourne and Waldringfield Area Plan and the planning application for Action Plan, so clearly included in the EIPA has the Adastral Park site which is still been removed from the EIPA in the Allocations & before the Council for consideration. Area Specific Policies documents/maps. Waldringfield & Newbourne are listed in the Felixstowe HMA but are excluded, quite rightly, from the Felixstowe Area Action Plan. Comments of Objection regarding C13/3069/OUT (Land West Of Ferry Road Residential Centre, Ferry Road, Felixstowe. Eric Southgate Site 166b should be discounted, or at least SHLAA site 166b has been discounted. Preferred Options does not include site 166b. protected from severe overdevelopment. 200 potential slums should be reduced to 70 real, sustainable, HOMES. Planning Committee minutes recording The maps include the site at Ferry Road within the " to ensure that any future development is the proceedings regarding the Preferred Options document because of the extant located in the most suitable locations". And you determination of C13/3069/OUT (Land planning permission which establishes the principal

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 9 consider that the "most suitable location" for 200 West Of Ferry Road Residential Centre, of residential development on this site. three storey houses is to cram them into a 4.8ha Ferry Road, Felixstowe) are on public field (A density of 42 houses per hectare), in clear record. line of sight from within an Internationally recognised Area Of Outstanding Natural Beauty, (The Deben Estuary) do you? J Stafford Following my personal experience of the Public consultation is a fundamental As part of the preferred options, public 'consultation' process for the Ferry Road OPA part of any planning application or consultation will be undertaken which will enable (Outline Planning Application), I find these very planning document which the Council greater community involvement and engagement. hollow words. This OPA attracted over 250 local undertake. The debate and reasoning The AAP is unable to change the Council’s decision resident objects, rejection by the Felixstowe for the approval of the outline planning with regards to the Ferry Road application. Town Council, the Felixstowe Society and many application is available in the public others. Despite this, the resident's objections domain. were never fully addressed or discussed and the approval was steamrollered through by SCDC Planning Officers and District Councillors, who did not even represent Felixstowe. This has left residents totally disillusioned with the SCDC Planning process and does little to promote a feeling of democracy or real involvement on planning decisions.

Section 3.4 states "ensure future development is The Council considered the application No change to the AAP. located in the most suitable location" How then on its individual merits and taking into was the Ferry Road OPA approved for 200 houses account material planning on a field in a semi- rural location, with only one considerations. small access road, farthest possible from local facilities and amenities!!

Section 4.9 "the Physical Limits Boundary has The site is still outside of the physical The maps include the site at Ferry Road within the been 'tweaked' (i.e. extended) to include the limits boundary as seen on the 2001 Preferred Options document because of the extant recent Ferry Road OPA" Local Plan Proposals Maps. The AAP planning permission which establishes the principal a. I strongly object to this 'tweaking'. The Ferry seeks to redraw this boundary in light of of residential development on this site.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 10 Road field remains OUTSIDE the current the application that has been approved. Felixstowe Town Boundary, OUTSIDE the current Physical Limits Boundary and remains prime Greenfield Agricultural land. b. Yet in another example of SCDC Planners bending the rules in order to influence and achieve a pre-defined objective.

Section 2.5 states "it will be for the Felixstowe Felixstowe Town Council have been The AAP has been prepared with involvement of Peninsular AAP, through the democratic process, actively engaged in the evolution of the Felixstowe Town Council and District Councillors to identify which of the sites area appropriate" AAP since the Issues and Options which represent the communities across the More hollow words! The Felixstowe Town consultation period. Alongside this, the Felixstowe Peninsula. Councillors were democratically elected by Council has been coordinating a Felixstowe residents to represent their wishes. Felixstowe Peninsula Working Group They rejected the Ferry Road OPA but this which is made up of Felixstowe Town counted for nothing. The OPA decision was Councillors and District Councillors actually made by SCDC Councillors from other engaged in the process to represent the areas (none of whom were elected to represent local community. Felixstowe residents) egged on by Senior SCDC Planners who had clearly already made up their minds on the required outcome of this OPA. Ian Buxton The council ignore local community involvement Public objection does not result in the No change. in the process for the allocation around Ferry refusal of a planning application. The Road. Last sentence para 4.9: Revise the words in Council as local planning authority have a new sentence. SCDC followed due process in to consider these comments along with agreeing the allocation at Ferry Road in other material planning considerations Felixstowe but completely ignored the comments and make a decision as detailed in the from local community. Case Officers report and minutes of the meeting.

How do we change from a culture of consult and Public engagement in the AAP is Public consultation responses have influenced the ignore to one of Consult and debate? The fundamental and does influence the preferred options document in the form of consultation to most people appears to be Council’s thinking and decision making. suggested policy requirements, changes to something forced upon the council to do NOT The preferred options document will be boundaries and how the document and supporting because they really want to change through subject to extensive public consultation maps are presented. During the preferred options consultation. They think its too difficult, which provides further opportunity to consultation the Council will be undertaking drop

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 11 pandering to the lobby groups & so called debate issues and engage with the local in sessions to enable greater community Nimby's but local democracy is being communities. engagement in line with the Council Statement of undermined. its because the local people feel Community Involvement. that they have unsuitable development foisted upon them that they become disengaged or aggressively negative. Percival King An example was the meeting held in Trimley St The meetings in 2007 were focused on No change. Martin on 14th March 2007 at which the Council the preparation of the Core Strategy unveiled their vision of our future. Villagers were which was adopted in July 2013. The aghast at the number of new homes proposed, AAP will be subject to specific public and that the Trimleys had become part of a consultation with the next stage being Greater Felixstowe. The impression was given the preferred options in autumn 2015. that proposals were written in stone with little The Statement of Community room for compromise/consensus. Another Involvement (SCI) sets out how the meeting was promised in the Autumn, but failed residents, businesses and other to materialize. Further meetings were held, at interested parties in the district will be which the Council maintained their stance, but involved in the preparation of the failed to garner support for their proposals. Many Suffolk Coastal District Local Plan. concerns were raised, but appeared to fall on deaf ears. Eric Southgate "We are always open to suggestions as to how Engagement with the local community Public consultation responses have influenced the we can encourage more people to get more is fundamental to the success of the preferred options document in the form of involved in the decisions which shape their future AAP and the Council welcome suggested policy requirements, changes to lives". Your own words. Answer. SIMPLE. Stop comments from every section of the boundaries and how the document and supporting treating the community, who pay your wages, as community. Officers welcome maps are presented. During the preferred options an irritation to be ignored, as lesser beings to be discussions with the local community at consultation the Council will be undertaking drop simply frightened off or locked out of meetings, every opportunity and drop in sessions in sessions to enable greater community told not to contact councillors who could have will be held during the preferred engagement in line with the Council Statement of direct input into decision making for us, and options consultation to facilitate this Community Involvement. intimidating us so that we are too frightened to engagement. challenge you over the "shape of, what's left of, our future lives".

Reference 3.2. Whenever the community quoted The David Locke Report from 2006 is The preferred options document does not make the David Lock report, in any meeting with SCDC, now an old evidence base document. reference to the David Locke report published in we were told in no uncertain terms that the Although it may still contain positive 2006.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 12 David Lock report would cut no ice with them. aspects the AAP does not place any We were once told that "All this sort of thing is reliance on this old evidence. alright on paper but in the real world it carries no weight at all". The 2014 SHLAA provided a range of sites across To do this, policies and proposals should be See SHLAA 2014 methodology regarding the Felixstowe Peninsula which the AAP has then founded on a robust evidence base". Your words. calculation of site density estimates taken forward as part of the preferred options In answer to a FOI request I received the which followed examples of best document. following "There is therefore no exact practice and the guidance as published methodology which was used to determine the by government. The SHLAA is a suggested housing density for each site". Plucking document which demonstrates densities out of thin air may be your idea of a capacity. The AAP translates these 'robust evidence base' but it isn't mine. details into policy requirements. Julie Cornforth I would say that at least 75% of the population of The Council will seek ways and avenues The AAP will be promoted through Coastline when Felixstowe does NOT know about this of promoting the consultation further possible. consultation. Why doesn't SCDC send details to across the Felixstowe Peninsula. every house in Felixstowe? They manage to send Articles in Coastline will be published if out the "Suffolk Coastal" magazine every few its circulation coincides with the months. Put the details in that.....on the FRONT consultation period anticipated in PAGE! PRIOR TO THE CONSULTATION! Autumn 2015. Kimberley There has been inadequate community The Issues and Options consultation ran The AAP will be promoted to a wider range of Williams involvement and more should have been done to for 11 weeks which is an extended stakeholders in the future. consult a wider group of stakeholders including period of time and should have enabled residents and businesses and community groups. communities to engage in the process. Extend the consultation process and engage more meaningfully with the public to raise During the next round of public Public drop in sessions will be advertised through a awareness - only one public evening session is consultation, the Council will seek to variety of avenues and mediums such as posters, not enough, people work during the day and undertake drop in sessions at more online, newsletters, websites. those that do not may have young children so the appropriate times (4-8pm) at a range of day time drop in session was poorly attended in venues across the Felixstowe Peninsula. Walton.

Felixstowe Town Council had to get an extension Felixstowe Town Council considered the Felixstowe Town Council have been actively of time to submit its response which is an Issues and Options document in the engaged in the evolution of the AAP from Issues indication that insufficient time was allocated to manner they considered most and Options to Preferred Options. the process in the first place. There was not time appropriate. How they conduct their

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 13 for a separate public meeting, public involvement meetings is beyond the remit of the has been limited to 30 minutes of public speaking District Council. at the outset of an extra ordinary meeting scheduled to adopt the council`s response when in fact a meeting should have been held earlier to allow public views to be heard before the council formulated its response. The next round of consultation will be The preferred options consultation will seek to Community involvement has been poorly undertaken with greater publicity to avoid the Christmas and new year period. promoted. The process has not been advertised promote increased community well, even the town council had to get an engagement. It is anticipated that the extension of time to out forward its views. Many preferred options consultation will be people in the community are unaware of the undertaken during the autumn 2015 Consultation greater community involvement which will avoid Christmas, easter and over a longer period of time, it was mistake to summer holidays. start the consultation over the christmas and new year period when people are otherwise distracted. Save Trimleys The task of "identifying the most appropriate The SHLAA identifies an indicative The preferred options document outlines a range Against Growth sites" is a futile aspiration. According to Table 2 capacity on each site, the AAP takes of sites which will ensure that the Core Strategy of the FPAAP, which is based on the Strategic these sites and translates them into housing requirement is met. Housing Land Availability Assessment(SHLAA), policies which will guide the future there is capacity on suitable sites ‘submitted to development across the Felixstowe the Council by developers, agents and Peninsula. It is anticipated that only an landowners" to build between 806 and 1107 element of these sites is required to units, depending on house types and sizes. Since deliver the number of units required. land for "at least" 850 houses still needs to be allocated, it is obvious that most if not all of this identified capacity will be taken up. Therefore, identifying "which of these sites ...are the most appropriate" will be a meaningless exercise. Mr J Stafford Section 2.4 states "Policies and proposals should The Core Strategy and the evidence No change. be founded on a robust evidence base" also underpinning that document define the Section 3.3 states "to support identified need housing and job targets for the district within the Felixstowe Peninsular" What 'robust over the plan period 2010-2027. It is evidence' is there of an actual need for large not the role of the AAP to redefine

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 14 scale housing development in Felixstowe? What these requirements that is to be 'robust evidence' is there for any large scale undertaken as part of the Local Plan increase in employment opportunities in Review in the future. Felixstowe that will require such a large quantity of additional housing? With increasing competition from newer ports, Felixstowe Dock expansion is being met mostly through increased mechanisation not manual labour.

Presentation of documents. Ian Buxton The housing numbers in 4.16 are inconsistent The Council will ensure that any future The preferred options document will provide (again) with numbers in 4.3: Align all numbers versions of the document will include consistent and simplified figures throughout. throughout and simplify. consistent numbers and in a more simplified manner. The words, table and numeric are confusing in Paras 4.2, 4.3 and 4.4 and uses terminology that is far from plain English. This leads to suspicion that the council is trying to hoodwink ordinary people through planning terminology and hard to understand numbers. e.g 1760 + 35 = 1795 - 943 = 852 NOT 850.

The para says that there is little to differentiate The principal of development on the The sites identified as preferred options have been sites - which is correct BUT the housing densities sites is similar when considered as part subject to Sustainability Appraisal in accordance are completely different: Explain why the housing of the Sustainability Appraisal process. with the regulations and best practice. densities between the sites should be so different. Felixstowe Page 10, Para. 3.0 Saved Policy AP170 is clear on As the AAP evolves further clarification The preferred options provide the detail which is Town Council how housing developments will be considered in will be given in respect of the number lacking in the Core Strategy. Felixstowe. Core Strategy Policies SP19 and SP21 of units expected on each site. These do not give as much detail. details will provide the background as to how sites will be developed alongside In any case, clearer explanation should be given policy requirements and mitigation on the housing requirements outlined in the Core measures. Strategy including how the allocation of an additional 1,440 homes in the defined AAP area Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 15 will be met and whether the figure of 1,440 is up to date or requires revision. Save Trimleys The phrase "a minimum" in Paragraphs 4.3 and The AAP seeks to deliver the level of The preferred options seeks to deliver the Core Against Growth 4.16 and "It is essential that the Council provides housing as outlined in the Core Strategy targets but will look to over allocate sites over and above the minimum amount of land Strategy. Any increase in numbers will to ensure the Council can maintain a five years needed to meet the target" in Paragraph 4.16 be considered as art of the Local Plan land supply which provides choice of locations for confirms that considerably more than 850 new Review which will need to update the developers and those looking for a new dwelling in houses will be allocated to Felixstowe and the district’s objectively assessed housing the Felixstowe Peninsula. Trimley Villages. It is disturbing that the housing need. needs figures quoted in the above Paragraphs, and elsewhere in the FPAAP, are stated as being factual, without any caveats or indications that they could be considerably higher. Mr J Stafford Section 4.6 - SHLAA indicative capacities for each The details from the SHLAA have been The preferred options include a clear indication of site Table 2 (attached) outlines the sites under provided to demonstrate that across how the Council expect sites to come forward. consideration within the Felixstowe housing the district there is sufficient land market, their size and indicative capacity. available for development. Details of However, to give a true picture of the potential how each site will be delivered will be impact, you should have included the density per included within the preferred options hectare for each site. The table illustrates that document. the density for Site 502e (and also the Ferry Road Field OPA site) is c.0.30% greater than any other site and 60% greater than the average of the sites proposed for Felixstowe, Walton and Trimley. The density is also far greater than the existing housing in this area. Harry The Local Plan Document gives an indicative Regarding infrastructure, Suffolk Coastal Measures to mitigate the impact of transport will Dangerfield capacity of just 1100 dwellings for Felixstowe and District Council Infrastructure Delivery be included within the preferred options document the Trimleys. At an average of, say, 1.5 vehicles Plan May 2014, provides details of what as directed by Suffolk County Council. per dwelling, that would be about 1650 extra infrastructure is required and how it will vehicles at the end of the peninsula. I would be provided, who is to provide the suggest that 1100 dwellings is excessive given the infrastructure, how will the transport infrastructure and the geographical infrastructure would be funded and context. However, I do recognise the definite when the infrastructure is required. need for social/ affordable housing for existing Suffolk County Council as highways local residents. authority have been engaged with the

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 16 production of the AAP.

Joanna Beedel I know we need more houses for the growing A range of housing types and tenures Mitigation measures will be included within the population to live in. There is an increasing will be required as part of any future preferred options document. number of elderly people in Felixstowe who development across the Felixstowe require a bungalow to live in, that would vacate Peninsula. These are expected to some of the bigger houses for families to live in. provide housing opportunities for all How about the schools? Are there enough places sections of the local community. for more pupils? How about the surgeries? They Infrastructure requirements have been are already stretched. Where are all the jobs for identified in the Suffolk Coastal the people who will inhabit these new homes? Infrastructure Delivery Plan which the Will they commute to Ipswich and London to Council will use to consider future work? These are all critical questions to consider requirements across the Felixstowe before the development of large housing estates. Peninsula. Levington & We are extremely concerned about the creeping The Core Strategy does not identify a The preferred options document identifies the Stratton Hall and proposed industrialisation of the A14 need for large scale employment Strategic Employment Areas and General Parish Council corridor between Ipswich and Felixstowe: provision on the A14. Therefore the Employment Areas which will provide a range of *we very strongly believe that it is essential to AAP will seek to concentrate employment opportunities in line with the preserve an open agricultural separation employment opportunities on existing preferred policy requirements. between these two distinct large settlements; sites across the Felixstowe Peninsula. *severely mars the rural landscape and would destroy the treasured open character of the Suffolk countryside if this area was given over to urbanisation; *the local infrastructure, in particular the road network, cannot cope; *this continually reduces the amount of agricultural land for food production in an ever- increasing population; *causes light & noise pollution; Kimberley There is no clearly identifiable need for 850 The AAP seeks to deliver the level of The preferred options seeks to deliver the Core Williams houses to be allocated to Felixstowe in addition housing as outlined in the Core Strategy targets but will look to over allocate sites top those already built or approved since the Strategy. Any increase in numbers will to ensure the Council can maintain a five years adoption of the core strategy. The figures are out be considered as art of the Local Plan land supply which provides choice of locations for of date: commission up to date research on Review which will need to update the developers and those looking for a new dwelling in current and future housing needs. Preserve district’s objectively assessed housing the Felixstowe Peninsula.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 17 greenfield and agricultural land. need. Eric Southgate Your plan for Felixstowe is not. "Organic and The sites identified within the preferred The preferred options document outlines the most evolutionary growth". It is, however. options are considered to represent suitable sites across the Felixstowe Peninsula as A. Grotesque 'URBAN sprawl' burying for ever, organic and evolutionary growth as they well as requiring a range of mitigation measures high grade, food producing, agricultural focus on the areas which are well and policy requirements. countryside with no significant infrastructure related to existing communities, improvements. services and facilities. Sites will come B. A Dumping ground for slums of the future, at a forward in keeping with the adjacent density higher than new builds in Ipswich, (St areas and seek to meet the housing Clements Hospital site is only going to have a needs of the communities across the density of 18 houses per hectare. You have given Felixstowe Peninsula. planning permission for 42 houses per hectare in Ferry Road). C. The constant Gridlocking of the road system, to and from the dock, with thousands of extra cars from these new houses using the A14.

Evidence Base. Kimberley The David Locke report is ten years old and needs The David Locke Report from 2006 is The preferred options document does not make Williams updating to ensure it is still relevant if relying on now an old evidence base document. any reference to the David Locke Report. it for making policy! Although it may still contain positive aspects the AAP does not place any reliance on this old evidence.

Save Trimleys The housing needs figures in the Felixstowe The Core Strategy sets the target with The AAP will seek to meet the housing requirement Against Growth Peninsula Area Action Plan are wrong because regards to housing provision across the outlined in the Core Strategy. not only are they based on data that is nearly 5 district. The AAP seeks to deliver this years out of date but they are also overstated minimum housing target on a range of because the population of Felixstowe and the appropriate sites. The Core Strategy Trimley Villages is going down rather than up. In acknowledges that the target is likely to addition, firm commitments made in the Local be higher in the future but this is yet to Plan to update these figures have also been be determined through up to date broken. Implementation could mean a linear evidence. urban development stretching all the way from Felixstowe to the outskirts of Trimley St Martin. Felixstowe The District Council should provide a summary of The evidence which under pinned the No change. Town Council the evidence base used to support the Core Core Strategy has been used to inform Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 18 Strategy Policy SP5 that which "outlines that at the AAP. Full details of the evidence least 8.5 hectares of additional land within the base can be found on the Council’s district will be allocated to support business and website. A list of employment sites help facilitate the creation of new jobs." The received have been identified in the Town Council has not been made aware of any SHLAA and have been considered proposals for employment land other than core through the Sustainability Appraisal strategy designation in the port area. We would process. welcome further information on the "variety of proposals for employment sites" the District Council states it has received. Michael 3.3 Evidence needed- Housing need survey needs The Core Strategy sets the target with The AAP will seek to meet the housing requirement Ninnmey updating A.S.A.P. regards to housing provision across the outlined in the Core Strategy. district. The AAP seeks to deliver this 4.6 Towards 50% of dwelling comes from minimum housing target on a range of reduction in occupancy Regional figure, appropriate sites. The Core Strategy calculated before 2008 crash. What is the actual acknowledges that the target is likely to figure taken from 2011 census? Should figure be be higher in the future but this is yet to reduced? be determined through up to date evidence.

Spatial and Sustainability. Q1. How can links with the Port be enhanced? Q2. Any opportunities for improvements to the road and rail networks? Q3. Which parts of the road network are at capacity? Mr & Mrs Buck Not enough consideration is given to the impact Suffolk County Council as the statutory Suffolk County Council have identified that any of increased traffic on minor roads in the area of Highways Authority consultee provides future development in the area of Ferry Road will developments; Gulpher Road (currently a "quiet advice in Highways matters and they need to take into account the designation of lane") will struggle to cope with the inevitable have been involved with the Gulpher Road as a quiet lane. This requirement increase in traffic if there is further development preparation of the Preferred Options has been included within the preferred policies. in Ferry Road. Document. Planning Committee minutes recording the proceedings regarding the determination of Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 19 C13/3069/OUT (Land West Of Ferry Road Felixstowe) are on public record. Julie Cornforth You state that the "importance of the Port cannot The A14 is the primary route of access The AAP recognises the importance of the A14 and be underestimated" When you build 1600 plus to the Felixstowe Peninsula and Suffolk directs heavy traffic movements to areas easily dwellings on Felixstowe's peninsula do you think County Council have been involved with accessible from the A14 and away from residential the "port" will continue to thrive? What the preparation of the Preferred areas. Studies undertaken for the Core Strategy happens when the A14 becomes grid-locked due Options Document. The SCDC are clear that the A14 has capacity to deal with the to overuse/accidents? Will that help the Port? Infrastructure Delivery Plan May 2014 level of growth anticipated across the Felixstowe Time wasted - money lost. details what infrastructure is required Peninsula. across the district. Carol Florey The combined A14/A12 section is close to The SCDC Infrastructure Delivery Plan The AAP recognises the importance of the A14 and capacity now particularly the Orwell Bridge. If an May 2014 details what infrastructure is SCDC will continue to work closely with Suffolk accident occurs here Ipswich becomes required across the district and will be County Council to ensure that the road network is completely gridlocked. Being as this is effectively kept under review. SCDC will continue able to serve the needs of the population and two main highways combined it should be at to work with Suffolk County Council to businesses in the Felixstowe Peninsula. least 3 lane and should incorporate another ensure that the necessary upgrades or crossing over the River Orwell. Another option improvements to the road network is would be for the A12 to be diverted through the undertaken at the appropriate times North of Ipswich. Christopher We have the small half-road now, but in the The SCDC Infrastructure Delivery Plan The AAP recognises the importance of the A14 and Leffler event of a major accident blocking the A14 there May 2014 details what infrastructure is SCDC will continue to work closely with Suffolk will be chaos unless this relief road is capable of required across the district and will be County Council to ensure that the road network is carrying even slow HGV and motor traffic in both kept under review. SCDC will continue able to serve the needs of the population and directions. The structure of that road was to work with Suffolk County Council to businesses in the Felixstowe Peninsula. deliberately made a single track with passing ensure that the necessary upgrades or places to stop its use as a 'rat-run'. I believe that improvements to the road network is it's essential that it be upgraded while there is undertaken at the appropriate times time before all the new traffic is generated, to prevent the 'trapping' of the traffic in and out of the peninsula for however long an accident blocks the road. Kimberley The A14 is at capacity, Felixstowe is at the end of The SCDC Infrastructure Delivery Plan The AAP recognises the importance of the A14 and Williams the road and so if you want to improve access for May 2014 details what infrastructure is SCDC will continue to work closely with Suffolk the port the port should be encouraged to invest required across the district and will be County Council to ensure that the road network is in improved rail and road links, may be widening kept under review. SCDC will continue able to serve the needs of the population and the road. It is wrong to assume that the port to work with Suffolk County Council to businesses in the Felixstowe Peninsula.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 20 always be the main employer in Felixstowe it ensure that the necessary upgrades or makes the town vulnerable and alternative improvements to the road network is business should be encouraged undertaken at the appropriate times Julie Cornforth I object to SCDC building 1600 plus dwellings on The SCDC Infrastructure Delivery Plan The Core Strategy outlines the level of growth the Felixstowe Peninsula. Does SCDC think 1600 May 2014 details what infrastructure is expected on the Felixstowe Peninsula and seeks to plus houses on Fxt Peninsula will not have a required across the district and will be balance this growth against employment detrimental effect on the 14/PoF? The A14 will kept under review. SCDC will continue opportunities and community facilities. The Core not be able to cope and some days it may to work with Suffolk County Council to Strategy distributes housing across the district become gridlocked due to various ensure that the necessary upgrades or following the principles of sustainable incidents/accidents. Why kill the Golden Goose improvements to the road network is development. SCDC works in partnership with (PoF) that provides a living for many people who undertaken at the appropriate times other service providers and landowners to ensure live in the area. Also not everyone who lives in that any s106 benefits are delivered for the good Felixstowe wants to work at the Dock/or indeed of the community. In July 2015, SCDC introduced in Felixstowe. It's called personal choice!!!!!! the Community Infrastructure Levy which has Pepper-pot housing where they are needed replaced the previous S106 arrangements. around Suffolk. Not where the developers are going to benefit most. PS Where were the S106 goodies when the developers took over the old Bartlett Hospital?????

Q4. How can links between the AAP and Felixstowe Futures be successful? Landguard The new 'Felixstowe Futures' should have an Noted. The AAP provides links with Felixstowe Futures and Project Officer enabling/ coordinating role for delivery of the seeks to ensure a successful future for the AAP objectives. It should be the link between Felixstowe Peninsula. District - Town and community for all AAP issues. There are some projects where it may become more heavily involved, perhaps hosting externally funded project staff for particular projects. WDC Major Projects Team could possibly provide the model for 'FF'. Delivery of infrastructure / visible change and improvement is imperative to the community's perception of 'FF' success. Felixstowe References to Felixstowe Futures should be Noted. The Council will continue to Felixstowe Futures will be referenced where Town Council updated to refer to the replacement group work and engage with the activities of appropriate within the Preferred Options Felixstowe Forward. Felixstowe Futures as the AAP evolves. document.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 21 Housing. Q5. What sites identified in the SHLAA 2014 need to be allocated/ brought forward for development? Q6. Which SHLAA 2014 sites should be discounted? Q7. Do we need to consider any other residential sites? Q9. What type and style of developments do communities want to see on future residential sites? Which sites would be appropriate for flats and other smaller units and which sites would be appropriate for larger units? Q10. What will be the cumulative impact of bringing these residential sites forward? Felixstowe sites. General comments. Eric Southgate I see from this map that you have taken it upon The physical limits boundaries have not The Preferred Options document will include a yourselves to extend the physical limits boundary been changed, the consultation draft physical limits boundary for public to encompass a field in Old Felixstowe that is at document only published these for consultation. present designated as countryside. Why ask us comment. Changes have been made for our opinions when you have already decided where planning permission has already these matters behind our backs and prior to this been granted and therefore the consultation? principal of development is already established. Kimberley Physical limits of Felixstowe should be clearly Noted. The Preferred Options document will include a Williams identified and constrained to avoid over draft physical limits boundary for public development. consultation. Michael 6.9 Mitigation on noise/light impact of a extra (?) Noted. Mitigation measures will be factored into all future Ninnmey needed for residential dwellings along route to residential sites. dock. Site 502e-Land behind 15 and 16 Conway Close. General comments. Michael 502e- Some localised network enhancement may Noted. No action. Ninnmey be required to receive FW.

4.18 Supported Housing. Good Quality, intelligent Noted The AAP seeks to ensure good design across the

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 22 design, whole life, affordable and (?) to services Felixstowe Peninsula. Self build developments will needs to be requirement as proportion of all New be supported by SCDC on sites within the physical Buildings. ADD Policy is support self build: (UK limits boundaries. less than 10% compared to many European countries around 50% , why? Comments of Objection (Discount site). J Stafford The Felixstowe Peninsula Local Strategy Final The report entitled ‘Local Strategy for The Council acknowledges that the 2006 report is Report by David Lock Associates states that the Felixstowe Peninsula-Final Report’ April now an old evidence base document. All land between Ferry Road and Estuary Drive 2006, was tasked with identifying references to this report and its findings will be should not be developed and why. Whilst this has various future scenarios based upon the removed from the Preferred Options document. been ignored in contradiction to paragraph 3.2 key issues and trends that the Peninsula and 1.6, it would seem perverse if these reasons and its residents currently face and are ignored again regarding site 502e. It seems those that they might face in the future. perverse that Local Objectors and Felixstowe While the consultant team have Town Council were told the David Lock findings developed the scenarios, it is the were not adopted, so could not be used by them communities of the Felixstowe in support of the Objectors Case. However, it Peninsula, and their elected seems quite acceptable for SCDC to 'cherry pick' representatives, who have the from the report when it suits! responsibility to implement a preferred strategy through the Local Plan (LP) process. Please note - Due to the number of comments received regarding this site citing similar responses, the key points have been summarised below; Mr & Mrs The cumulative impacts of the site being The cumulative impacts have been Suffolk County Council has advised that the Whitlock developed adjacent to the Ferry Road application considered and the AAP recognises the cumulative impacts in respect of transport will Ian Buxton site; two development sites in this part of need to be considered through a transport Keith Mahoney Felixstowe. assessment as part of any future planning J Stafford application. The Council will continue to work with Christopher Suffolk County Council to understand the Leffler cumulative impacts of development across the Peter Wain Felixstowe Peninsula. Mary Wain Development would create a precedent for The sites identified in the AAP provide No change. Michael Smith further development; certainty as to where future R Wood development will take place. Once J Catchpole adopted the Council will be in a Carole Lissauer stronger position to refuse John Jay development proposals on sites outside

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 23 of those allocated. Whether the potential density of housing would The number of units proposed in the The preferred options document includes the be appropriate for the site; Preferred Options document is number of units expected on the site. considered appropriate for the location and makes efficient use of land. That brownfield land should be developed before Agreed, however brownfield No change. greenfield sites; opportunities across the district are limited which therefore places a greater reliance on green field sites. Potential commuting distances from the site to Any new development will need to No change. local services including sources of employment; make links to the existing footpaths, cycle ways and road network in the area which will improve access to local services and employment opportunities. Road access, capacity and safety issues: Suffolk County Council as the statutory Suffolk County Council has advised that a transport  Exacerbating existing school related issues, Highways Authority consultee provides assessment will be required as part of any future  Impacts on the Strategic road capacity, advice in Highways matters. planning application which will identify any  Lack of public transport; capacity and safety issues as well as mitigation  Potential affects on Gulpher Road (designation as measures required. The impact on Gulpher Road a Quiet Lane); has also been included as a constraint for this site. Concern regarding proximity to AONB; Although in close proximity to the The Preferred Options document requires low rise  Development of site might damage the appeal of AONB, the development is not expected buildings (maximum 2 storey) to reflect the the AONB and; to cause damage to the appeal of the existing properties and also to minimise any impact  consequently, the tourist offer in Felixstowe; AONB. on the AONB. Loss of prime agricultural land (Grade 1 and 2); The Core Strategy identifies that some No change. prime agricultural land may be lost as a result of meeting the housing needs across the Felixstowe Peninsula. Potential impacts on European sites habitats; No significant impacts on European site AAP requires development to be sympathetic to designations have been identified the surrounding area. because of this proposed development. Less sustainable site due to lack of local services, Any new development will need to No change. amenities, infrastructure and facilities. make links to the existing footpaths, cycle ways and road network in the area which will improve access to local services and employment opportunities. Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 24 No requirement for more private housing in The Core Strategy identifies a housing Sites are identified in the Preferred Options Felixstowe; requirement for Felixstowe over the document to meet the Core Strategy target for next 15 years. growth and development over the next 15 years. New residents will create social disharmony; Noted. No change. Comments of Support. Optima Land Support the delivery of the site. Noted. Site is identified as a Preferred Option. and Property Site 451g-Land at and surrounding Felixstowe rifle club, south of Dockspur roundabout. General comments. Anglian Water May require Mains Diversion. Some localised Noted. Improving the capacity of the sewerage network as network enhancement may be required to the a result of this site has been included as a policy sewerage network. requirement within the Preferred Options. Historic England Potential harm to the setting of WALTON HALL, Noted Mitigating the impact of any potential 395 HIGH STREET (south side) Grade II* AND 362 development on the setting of the listed buildings HIGH STREET (north side) lodge building Grade II. nearby will be included within the Preferred Limited development on east of site. Options. Environmental Site borders the A14 and an air quality Noted and agreed. The preferred options document will include a Protection assessment would be required if this site was policy requirement for a buffer zone as well as an Team developed. A buffer zone would also be needed air quality assessment on this site. in this area to protect any future residential amenity. Carol Florey A buffer zone alongside the A14 and Candlet Noted and agreed. Introducing a buffer between future residential Lorna Adamson Road should be considered in order to protect development and the A14 Dock Spur and Candlet housing in the new development from being Road will be included within the Preferred Options. exposed to poor air quality. Comments of Objection (Discount site). Please note - Due to the number of comments received regarding this site citing similar responses, the key points have been summarised below; Carol Florey Saved policy AP171 identifies this land as a The Local Plan Policy identifies that this The AAP identifies a new area to be protected from Dave Norman physical separation between Felixstowe and the policy will be reconsidered in a review development to the west of the A14 which will Lorna Adamson Trimleys. of the next Local Plan. The AAP maintain the separation between Felixstowe and provides that time for review. Trimley St Mary. Area 451g is Grade 1 farmland identified under Development in this area is considered section 6.6 as valuable. appropriate to balance the need for The AAP seek to protect prime agricultural land future growth in an organic and which is outside of the proposed physical limits evolutionary manner which protects as boundaries. Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 25 far as possible prime agricultural land. The site offers the opportunity to locate new housing in a location close to existing services and facilities which will integrate with the existing communities. Comments of Support. Trinity College Support for site identified in the SHLAA 2014 as Noted. Site identified as a Preferred Option Cambridge Deliverable – approximately 12 hectares capable of accommodating 243-360 dwellings, 1011c – Land at Felixstowe Sunday market site, Sea Road. General Comments. Anglian Water Encroachment advisory zone for WRC (20). Noted. Improving the capacity of the sewerage network as a result of this site has been included as a policy requirement within the Preferred Options. Comments of Support. Blue Street Support for site 1011c (0.58 ha) (identified in the Noted. The site presents an Site identified as a Preferred Option but with Properties SHLAA 2014 as deliverable) with the proviso that opportunity for the redevelopment of commercial/tourist activities on the ground floor policy AP201-Felixstowe: Sea Road Frontages be previously developed land. The Sea frontage of any development which comes forward removed. Road frontage is a key contributor to on this site. the tourist and resort activities of Felixstowe and is to be retained through revised tourism policies in the AAP. Felixstowe sites - General Comments. Michael 50% of the need for dwellings comes from Noted. The AAP seeks to provide the No change. Ninnmey reduction in occupancy Regional figure, housing requirements outlined in the calculated before 2008 crash. What is the actual Core Strategy. Any new calculations figure taken from 2011 census? Should figure be based on objectively assessed needs will reduced? be considered through a future Local Plan review. Christopher The proposed plots of land which could be made Noted. No change. Leffler available for housing seem to be a sensible set of proposals, some I think go back to the plan in about 1980.(without looking it up!) Kimberley There is no such site as Walton Green south it Name of the site will be changed to The AAP will refer to the site in Walton as Land Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 26 Williams was created by Tesco and Bidwells in connection provide further clarity as to its location. north of Walton High Street in the Preferred with applications for a housing development. It is The Core Strategy seeks to resist Options document. wrong to build on this land as it was available for development as far as possible on prime food production. agricultural land. The site could provide a large number of units in a location which is close to existing communities, services, facilities and education opportunities. Other land across the Felixstowe Peninsula identified as prime agricultural land will be protected outside of the physical limits boundaries. Environmental Un-numbered 'unsuitable site', Dock Gate The site is not identified for housing The AAP identifies the site as a General Protection 1/Haven exchange roundabout. I realise that this within the AAP, but is identified as a Employment Area where employment Team site is marked as 'unsuitable' anyway but I need General Employment Area and this may opportunities are to be created and any future to make a specific comment here as if this site have an impact on the AQMA identified residential uses will be resisted. Any future were to have housing it might result in the need at Ferry Lane, Felixstowe. development in this area will need to be for an AQMA due to the amount of heavy traffic accompanied by an air quality assessment and in the area. consider the impact it will have on the AQMA identified at Ferry Lane, Felixstowe. Felixstowe Whilst the Town Council may provide comment Noted. No change. Town Council on the type and nature of development for sites in Felixstowe identified by the SHLAA, no support (or otherwise) for the development of these sites is given or implied and therefore should not be inferred. The Town Council will consider development proposals for Felixstowe in the usual way through its Plans Committee or as otherwise brought to Council for consideration. Defence I can confirm that the MOD has no comments to Noted. No change. Infrastructure make in relation to the Felixstowe Area Action Organisation Plan as it falls outside of any MOD published statutory safeguarding consultation zones. Julie Cornforth The population of Felixstowe is decreasing not The AAP seeks to provide appropriate No change. increasing residential opportunities for the Change To Plan: Tell the truth. population over the next 15 years.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 27 Why is Felixstowe being called a "Major Centre" - The Core Strategy identifies Felixstowe No change as the remit of the AAP does not allow it is a town on a peninsula. as a Major Centre because it is the for the settlement hierarchy to be reconsidered. largest town in Suffolk Coastal and has a The settlement hierarchy will be reconsidered as wide range of employment, education, part of a future Local Plan review. retail and tourism opportunities and facilities.

Why should Felixstowe meet the overall housing The Core Strategy identifies a housing No change. need across the district? target for Felixstowe, Walton and the Trimleys. This housing target is only a part of the overall need across the district. Surely "affordable housing" should be built Agreed, affordable housing should be The residential policies in the AAP make reference around the district where it is needed. built alongside market housing in line to the need for affordable housing provision in line with Core Strategy policy DM2. Sites in with Core Strategy Policy. the Felixstowe Peninsula will be expected to provide 33% affordable housing. We don't need "huge mansions" built on housing The Core Strategy identifies that a range The residential policies in the AAP make reference estates. Local people cannot afford them. Will of house types are to be built across the to the need for mix of house types in line with Core they become second homes for the rich? The district. The sites identified in the AAP Strategy Policy. outskirts of Wickham Market springs to mind. will be expected to provide a mix of units to meet the needs of the wider community. Mr & Mrs Buck The proposed development sites should have Noted. The definition of previously No change. included information regarding whether they are developed land is found within the green field or brown field. National Planning Policy Framework and does not need to be repeated in the AAP. Rt. Hon Therese Site 889: In the event of increase in dwelling Site 889 is not considered to present Site not taken forward as a preferred option. Coffey MP numbers, the proposals for a Eco Village, organic and evolutionary growth as approved by Felixstowe Town Council at Croft detailed in Core Strategy Policy SP21. lane, submitted to Core Strategy by myself The site is in the countryside and Core Strategy Policies and the National Planning Policy Framework seek to resist inappropriate development in

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 28 isolated countryside locations. Mr J Stafford Section 1.4 states "A high proportion of the Noted. The Council is aware of the No change. population are of retirement age and benefit retired people bring to the local communities within the peninsula have fewer economy through increased spend in people of working age than many other local services. communities within Suffolk. The age profile could become critical to the vitality of the Felixstowe Peninsula and the services it provides if the slow population growth.....". The benefit of the 'grey pound' has been ignored in this equation. It is a proven fact that retired people currently have more disposable income and a higher propensity to spend than their younger counterparts. This actually of benefit to the local economy, not a disadvantage. Julie Cornforth How can you support a strong, vibrant healthy See Natural England Technical The AAP will include reference to prime community if you build on the Grade 1 Information Note TIN049. agricultural land and the need to protect this as far agricultural land that is needed to grow food on as possible in line with the Core Strategy. to feed them? The only Grade 1 Agricultural Land Policy to protect agricultural land. in SUFFOLK is found in Felixstowe. How do Government policy for England is set you minimise waste and pollution and reduce out in the National Planning Policy carbon by building more houses in a confined Framework (NPPF) (paragraph 112). space like Felixstowe? More houses - more cars! Decisions rest with the relevant planning authorities who should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of higher quality.

The Agricultural Land Classification (ALC) provides a method for assessing the quality of farmland to enable

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 29 informed choices to be made about its future use within the planning system. It helps underpin the principles of sustainable development.

The Core Strategy seeks to protect prime agricultural land as far as possible but this needs to be balanced against other policy requirements such as meeting housing needs, locating new housing in locations well related to existing communities, services and facilities, as well as providing a range of sites which provide organic and evolutionary opportunities for growth.

The site north of Walton High Street meets most of these policy requirements and when considered on balance the loss of prime agricultural land is not reason in itself to discount the site for future development.

Suffolk is known as the "Bread Basket of England" Noted. The AAP seeks to protect farming opportunities Re:- Food Security - DEFRA leadership key. Report across the Felixstowe Peninsula by proposing 1st July 2014 "The food security report supports physical limits boundaries which represent organic the idea of "sustainable intensification" - and evolutionary growth and protect farming producing more food with fewer resources - and opportunities outside of these boundaries. calls on Defra to stem the decline in UK self- sufficiency and deliver more resilience in the UK food system. It notes that for key cereal crops, for example WHEAT, yield levels have not increased for over 15 years" see www.parliament.uk 5.2 Felixstowe has quite a few "employers" Noted. A large proportion of the No change.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 30 contributing to the economic growth and district’s workforce is employed in the prosperity of the whole district. It's called faming industry. "FARMING" Perhaps you would like to see the www.votebritishfood.com website. It states "Buying safe, traceable British food is vitally important but it is a FACT that our self-sufficiency has fallen steadily for the past 30 years. It's already down to 60%" So why does SCDC want to build on the best agricultural land that we have. GRADE 1 ???? You "encourage brownfield development where The Core Strategy acknowledges a lack No change. it is not of high environmental value" "The DEFRA of previously developed land across the Agricultural Land Classification states that in early district. Where possible previously 2000's it estimated that Grade 1 and 2 together developed land will be brought forward form about 21% of all farmland in England". in line with planning policies. Kimberley Much of the land identified in the SHLAA is grade The Core Strategy acknowledges that The preferred options document (and the Core Williams 1 and 2 agricultural land and should not have the loss of prime agricultural land will Strategy) acknowledges that some prime been included in the SHLAA because the core be avoided as far as possible. Outside agricultural land will be lost where this represents strategy says that growth for Felixstowe will be of the physical limits boundaries, the organic and evolutionary growth. organic and preserving wherever possible Council will seek to protect the prime agricultural land that is being used for food agricultural land which will continue to production. Use brownfield sites in Felixstowe provide faming and food production only, spread housing more widely across the opportunities. Housing figures will be district. Review whether then housing quotas updated as part of the work the Council which are over ten years olds still apply will undertake as part of a Local Plan review. Land adjacent to the AONB in Walton is grade 1 Outside of the physical limits The preferred options document does not propose agricultural land with diverse wildlife which will boundaries, the Council will seek to any development on sites which will have a be lost if houses are built on it, and the land protect the prime agricultural land detrimental impact on the AONB. should be preserved for food production which will continue to provide faming and food production opportunities. The presumption in favour of sustainable The Core Strategy acknowledges that No change. development is flawed where it causes the loss of prime agricultural land will irreparable damage to land, especially grade 1 be avoided as far as possible. Outside agricultural land and is wrongly used by planners of the physical limits boundaries, the to justify propping up the building industry, Council will seek to protect the prime

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 31 economically it is not sustainable as we have agricultural land which will continue to seen in Portugal and the USA. provide faming and food production opportunities. Some sites in the SHLAA are green field and must Previously developed land across the No change. not be built on as they needed for food district is limited and will not deliver the production number of units required. Therefore development on green field sites is necessary. The Walton site will be detrimental to the The site is considered to represent Development on the site north of Walton High Countryside and must be preserved for food organic and evolutionary growth, well Street will protect other sites across the Felixstowe production. related to existing communities, Peninsula. services, facilities and education opportunities. The sustainability appraisal fails to adequately The Sustainability Appraisals have been Revised Sustainability Appraisal information will be consider the environmental impact of building in updated and revised following public published alongside the preferred options Walton North: preserve the land in Walton for consultation responses. document. food production. The APP must protect grade one agricultural land The Core Strategy acknowledges that No change. at all cost to encourage diversity of wildlife and the loss of prime agricultural land will maintain sufficient land supply for food be avoided as far as possible. Outside production. of the physical limits boundaries, the Council will seek to protect the prime agricultural land which will continue to provide faming and food production opportunities. The AONB and agricultural land mist be protected Noted and agreed. The preferred options document will seek to I do not accept the statement though "except protect the AONB. where in the public interest to do so" as this is too wide and open to abuse. Felixstowe References made to the "Best and Most Versatile Noted, the references to best and most The preferred options document will use the same Town Council Agricultural Land" are not highlighted in Core versatile agricultural land are taken wording as the Core Strategy for consistency. Strategy Policy SP21 as stated but can be found in from the NPPF. Core Strategy SP21 Chapter 11 and paragraph 112 of the NPPF. makes reference to “prime agricultural land for essential food production”. Mr & Mrs Buck The importance of good agricultural land does Outside of the physical limits The preferred options document (and the Core not seem to be taken into account. We should be boundaries, the Council will seek to Strategy) acknowledges that some prime

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 32 safeguarding our ability to continue producing as protect the prime agricultural land agricultural land will be lost where this represents much of our own food as possible. which will continue to provide faming organic and evolutionary growth. and food production opportunities. Trimley St Martin and Trimley St Mary. General Comments. Environmental Sites 936, 383a, 451b, 451c, 451d, 383b, 383f, Noted. The AAP seeks to identify policy requirements and protection 451f and 607 within the Trimleys will need to mitigation measures. Issues with regards to air Team have cumulative traffic effects considered with quality will be included where appropriate within regard to air quality. Traffic from these sites the Preferred Options document. travelling into Felixstowe using the route via High Street Trimley and not the A14 needs to be calculated and air quality impacts at the junction of High Road West and Garrison Lane will need to be determined. This junction has in recent times become more congested along the Trimley High Road West arm at peak times. Anglian Water Water Mains Crossing Site 451c. Noted. The Preferred Options will make reference to the water mains crossing the site. Comments of Support (Discount sites). Rt Hon Therese Trimley St Martin - Agree that 920 and 889 are Noted. The Council works in The Preferred Options has been informed by Coffey MP completely unsuitable; partnership with Suffolk County Council Suffolk County Council as Highways Authority. Trimley St Mary - Concern that the current road in respect of highways issues. Where transport assessment or highways issues network could not cope with significant have been identified these have been included development on 383F. Agree with unsuitability of within the Preferred Options. 383c,d,e & 451e as too far away from centre. Agree that 920 and 889 are completely Noted. No change. unsuitable. Percival King Sounds good in theory; in practice, you cannot The Core Strategy seeks to provide The AAP seeks to introduce a new area to be legislate where people live/work or their mode of opportunities for organic and protected from development in between Trimley transport as the go about their daily routines. evolutionary growth across the St Martin and Trimley St Mary which will seek to I consider all the sites, apart from 607 located in Felixstowe Peninsula. This is done by maintain the separation between the villages. the Trimleys to be inappropriate for the following locating new residential opportunities reasons: which have the appropriate mix of New residential development will be expected to a. All consist of prime agricultural land. housing types, values and affordable provide a range of house types and tenures as well b. Four of the sites represent a green belt, which provision in locations close to existing as the appropriate level of affordable housing Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 33 distinctly divides the two historic and individual communities. provision in line with the Core Strategy Policy. settlements that are the Trimleys. Their use for homes would, in effect, merge the villages. The new residential developments will Whilst the planned numbers may meet the provide footpath and cycle way links to required target, the type is unlikely to, for, in the existing communities and built up reality it is only affordable houses that are in areas which will encourage people to demand. The fact that it is not now incumbent on use means of transport other than the developers to provide 33.3% of the total build in private motor car. affordable homes if it is considered not financially viable for them so to do; this could result in ta Maintaining the gap between Trimley St significant shortfall. Building large numbers of Martin and Trimley St Mary is important speculative homes, presumably to boost the and the AAP will seek to ensure that number of affordable homes, merely exacerbates these communities retain their the problem, because few are purchased by local individual character and do not become people. Quite frankly the demand for affordable merged. homes, in my opinion, can only be met by, local authorities, once again, building homes for rent/assisted purchase. Kimberley Provided the new sites coming forward are Opportunities for development on In principal any development opportunities on Williams brownfield only. previously developed land are previously developed land within the physical Anything that helps to reduce the number of new extremely limited across the district. limits boundary will be supported. Although homes to be built on greenfield sites is Where possible the Council will seek to opportunities are limited the Core Strategy welcomed. facilitate and encourage redevelopment promotes the delivery of previously developed of previously developed land. land.

Site 936 – Land to the north of Heathfields. General comments. Environmental Site 936 borders the A14 and an air quality Noted. The AAP does not seek to take this site forward as Protection assessment would be required if this site was a Preferred Option. It is not a location the Council Team developed. A buffer zone alongside the A14 are seeking to encourage future residential should be considered in order to protect housing development. in the new development from being exposed to poor air quality. Site 451d – Land surrounding Trimley Old Rectory, Church Lane. General comments.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 34 Historic England Potential impact on LB - content for Suffolk Noted. The Preferred Options document identifies the Coastal to assess the impact and the level of any potential impact development in this area may harm that might result. If sites 451d is brought have on the Old Rectory and any future developers forward; then the green 'wedge' of land between need to be sympathetic to the setting of this 383f, 607 and 451f that contains the two Grade II heritage asset. listed churches and the Grade II listed Old Rectory will become an increasingly important. The Preferred Optionsalso identifies land between Recommended that this land be identified as an Church Lane and Thurmans Lane as an area to be 'Area Protected from Development'. protected from development.

Stephen Bozier 451c, 451d Desirability of accessing sites off Suffolk County Council as highways The Preferred Options document makes specific Howlett Way. authority has been consulted on the reference to the primary vehicular access being off potential access requirements for all Howlett Way. sites. Lorna Adamson Site actually 9.2ha, Traffic impacts, Question Noted. The Preferred Options document takes into results of SA report account highways comments from Suffolk County Council. As the AAP progresses the SA will be revisited in light of consultation comments and engagement with communities and stakeholders. Comments of Support. Denise Scott Support for 451D. Noted. The AAP includes this site as a Preferred Option. Site 451b – Land off Grimston Lane and High Road. Comments of Objection (Discount site). Historic England Historic England has concerns over site 451b, Noted. The Preferred Options document includes which would impact on the setting of the Hand in reference to the impact residential development Hand Public House and Nos 251 and 253 High on this site may have on the setting of the Hand in Road. Hand Public House. Denise Scott Opposed to 451B. Noted. The AAP includes this site as a Preferred Option. Trinity College, Land off High Road (Opposite 'Hand in Hand') Noted. The AAP includes this site as a Preferred Option Cambridge Extension of 0.15ha to deliverable site 451b but limits the extent of the site to not go beyond submitted by promoter of site. the rear of 21 Grimston Lane. Percival King I consider all the sites, apart from 607 located in The Core Strategy seeks to provide The AAP seeks to introduce a new area to be the Trimleys to be inappropriate for the following opportunities for organic and protected from development in between Trimley reasons: evolutionary growth across the St Martin and Trimley St Mary which will seek to a. All consist of prime agricultural land. Felixstowe Peninsula. This is done by maintain the separation between the villages. Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 35 b. Four of the sites represent a green belt, which locating new residential opportunities distinctly divides the two historic and individual which have the appropriate mix of settlements that are the Trimleys. Their use for housing types, values and affordable homes would, in effect, merge the villages. When provision in locations close to existing the then Secretary of State for the Environment communities. threw out an appeal for homes on site 383f, he emphasised the above in the strongest possible Maintaining the gap between Trimley St terms. Martin and Trimley St Mary is important and the AAP will seek to ensure that these communities retain their individual character and do not become merged.

Site 607 – Land at 182 High Road. Comments of Support. Percival King 607 good, all other sites bad. Noted. The AAP proposes a change to the Trimley St Mary physical limits boundary to include other sites off the Josselyns and Thomas Avenue. As a result site 607 is within the physical limits boundary. Historic England Historic England does not wish to comment in Noted. The Preferred Options policy outlines that any detail on these sites, but note our comments on future development in this part of Trimley St Mary the open land to the north set out above, and in will need to be sympathetic to the setting of Mill addition we note that site 451f will have some Farmhouse. adverse impact on the setting of Mill Farmhouse (Grade II listed). No doubt this site once formed part of its agricultural holding, but retaining the open land to the north will ensure a degree of protection to its remaining agrarian setting. Site 383f – Land south of Thurman’s Lane and opposite to High Road. General comments. Historic England Historic England does not wish to comment in Noted. The Preferred Options policy outlines that any detail on these sites, but note our comments on future development in this part of Trimley St Mary the open land to the north set out above, and in will need to be sympathetic to the setting of Mill addition we note that site 451f will have some Farmhouse. adverse impact on the setting of Mill Farmhouse

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 36 (Grade II listed). No doubt this site once formed part of its agricultural holding, but retaining the open land to the north will ensure a degree of protection to its remaining agrarian setting. Site 451f – Land adjacent to Mill Farm, 38 Thurman’s Lane. General Comments. Historic England Sites 451f. Historic England does not wish to Noted. The Preferred Options policy outlines that any comment in detail on these sites, but note our future development in this part of Trimley St Mary comments on the open land to the north set out will need to be sympathetic to the setting of Mill above, and in addition we note that site 451f will Farmhouse. have some adverse impact on the setting of Mill Farmhouse (Grade II listed). No doubt this site once formed part of its agricultural holding, but retaining the open land to the north will ensure a degree of protection to its remaining agrarian setting. Trinity College, Addition of approximately 0.26 ha to SHLAA 2014 Noted. The AAP includes this site as a Preferred Option Cambridge site 451f (identified as deliverable) Comments of Support. Trimley St Mary The Parish Council supports the sites identified as The Council is working in partnership The AAP includes this site as a Preferred Option Parish Council suitable but comments that these sites are only with infrastructure providers such as along with a range of policy requirements to help suitable subject to the infrastructure provision Suffolk County Council and Anglian the delivery of this site. that will be necessary. Water to determine the range of infrastructure required. Bucklesham sites. Site 914-Land north of White House, The Street. General comments. Historic England Potential impact on LB - content for LA to make Noted. Noted. judgement The Council will ensure that any future Site not taken forward as a preferred option. Site 914 is identified for 7 houses, presumably development on this site takes into fronting the existing road. This development may account the setting of the listed building have some negative impact on the setting of a nearby. Grade II listed house, but Historic England is content for the Local Planning Authority to assess Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 37 whether the provision of housing outweighs any harm that might result.. Anglian Water Sewers Crossing Site. Noted. Site not taken forward as a preferred option. Comments of Objection (Discount site). Rt. Hon Therese All sites- Bucklesham - Most sites are too big and Noted. No sites are identified as Preferred Options within Coffey MP too far away from village centre. Bucklesham. Kirton/ Falkenham sites. General comments. Kirton & Community view is that no more than 30 units Noted. Kirton is the largest local service The level of growth outlined in the Preferred Falkenham are needed, these should be a mixture of centre within the Felixstowe Peninsula Options document is considered appropriate for Parish Council affordable and sheltered units. Reference para and is expected to take some growth the settlement. 4.86 of the Core Strategy. over the plan period. Issues and Options is inconsistent with Core Noted. Kirton is the largest local service The level of growth outlined in the Preferred Strategy which states that Key Service Centres centre within the Felixstowe Peninsula Options document is considered appropriate for may be required to have as many as 30 units. and is expected to take some growth the settlement. Kirton is a Local Service Centre so this figure over the plan period. should be less. Kirton should not become a dormitory, Noted Services and appropriate infrastructure are to be improvements to services and infrastructure supported where possible and may be delivered required. through the Community Infrastructure Levy. If development at B&M Concrete site is Application approved by the Council in Additional site included to propose a location for approved. The AAP must not include any other June 2015. sheltered housing/bungalows as required by public sites in Kirton. consultation responses. Overwhelming consensus that there is a need for Noted Policy requirement for sheltered sheltered housing in Kirton. housing/bungalows to be included within the Preferred Options. Village does not require any more 4/5 bedroom Noted Any future development will be required to detached houses, these do not reflect community provide a mix of dwelling types and tenures. need. None of the sites are appropriate without Noted. Sites included within the Preferred Options improvements to roads, footpaths and sewers. document will have a policy requirement for Some of the sites have major surface water improvements to footpaths and sewers. drainage issues. Selection of sites is flawed – one owner of a site Sites were submitted to the Council Site not taken forward as a Preferred Option. has stated no intention of developing it. following various “calls for sites”. All sites submitted are available to view. Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 38 However where ownership changes (as was the case with this site) the Council can only rely on the most recent information. Timescales for the AAP must be greatly The Council is following government The AAP is expected to be completed within the expedited. It is clear that by the time the policy advice to ensure plans are prepared and next 12-15 months. has been approved and used the majority of sites adopted in a timely manner. Producing will have been developed. the document in accordance with the timetable will provide certainty for local communities and enable to Council to demonstrate a five year housing land supply. Indicative figures for each site must be removed Noted and agreed. The SHLAA is part of Any figures within the Preferred Options document as they are very misleading. the evidence base, it is for the AAP to will be used to give a minimum indication of what determine the number of units on each level of development is expected on the site. site. Sewerage system cannot cope with current level Noted. The Council will work with Mitigation measures included within the Preferred of housing in Kirton. Overflows at high pressure Anglian Water to ensure that any Options. along Bucklesham Road and streams of sewerage mitigation measures or improvements can be seen near the church. are brought forward as part of the AAP. Site 950 – Land adjacent to village hall, Falkenham Road. General comments. Anglian Water 950: Water Mains Crossing Site, Sewers Crossing Noted. Site not taken forward as a Preferred Option Site. Christopher Pleased that AONB is being protected. Noted. Site not taken forward as a Preferred Option Leffler Site 951 – Land east of Church Lane. General comments. Anglian Water 951: 305mm potable water main on edge of site. Noted. Site not taken forward as a Preferred Option Historic England 5 separate sites of varying capacity are identified Noted. Site not taken forward as a Preferred Option around the village. Historic England is satisfied that none would adversely impact on the historic environment, but would request that the northern boundary of site 951 is formed of native species hedging so as to protect the wider setting Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 39 of the Grade II listed Church of St Mary and St Martin. Kirton & Church Lane is too narrow to be used as access Noted Sites on Church Lane not taken forward as a Falkenham for new housing. Preferred Options. Parish Council Site 325a – Land to the rear of 101-137 Bucklesham Road. General comments. Anglian Water 325a: May require Mains Diversion. Water Mains Noted. AAP includes this site as a Preferred Option with a Crossing Site, Sewers Crossing Site. policy requirement that drainage in this area needs to be improved before any development can come forward. Site 712 – Land to the rear of 18 Falkenham Road. General comments. Rt. Hon Therese It is my understanding the Falkenham Road site Noted. Planning permission granted on this site for 43 Coffey has been backed in a local consultation session units in June 2015. Application reference run by the Parish Council. Concerned about over DC/14/4225/FUL. development if all the other sites were approved. Kirton & SCDC should insist on a change of the housing Planning applications are considered on A change to a specific planning application is Falkenham mix currently seen as part of the application on their own merits by Development currently beyond the remit of the AAP. Planning Parish Council this site. Management colleagues and ultimately permission granted on this site for 43 units in June the Planning Committee. 2015. Application reference DC/14/4225/FUL. Comments of Support. Maaike Lensen The provision of affordable housing in Kirton will Noted. The AAP will seek to deliver 33% affordable increase the range of housing options available to housing in line with Core Strategy Policy DM2. younger families in the village. Mark King The provision of affordable housing in Kirton will Noted. The AAP will seek to deliver 33% affordable increase the range of housing options available to housing in line with Core Strategy Policy DM2. younger families in the village. More homes needed for young families, Noted. The AAP will seek to deliver 33% affordable especially Kirton where house prices are high. I housing in line with Core Strategy Policy DM2. strongly support this proposal. Comments of Objection (Discount sites) - Due to the number of similar objections towards sites 325a, 770, 951 and 950 in Kirton/Falkenham, Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 40 the comments have been summarised as below: Please note - Due to the number of comments received regarding this site citing similar responses, the key points have been summarised below; Jane Bartle  Inadequate access and potentially difficult Kirton is identified in the Core Strategy Planning permission was granted for 43 units on a Donna Sperling approach road to site; Development would lead as a Local Service Centre and therefore site at Falkenham Road in June 2015. As a result, John Jay to increased levels of traffic and may overburden is expected to take an element of Kirton has taken some growth during the plan J Durrant local road network; No footways; growth and development over the plan period in line with its position as a Local Service Sarah King  Additional housing will overburden the sewer period (2010-2027). Centre. Helen King system; R & T King  Detrimental affect on residential amenity - The Council has been working with A further site has been identified as a Preferred Paul & Caroline especially noise, disturbance and light pollution; partners such as Suffolk County Council Option (Site 325a, Bucklesham Road) which will Skippins  Development will block views of the countryside; and Anglian Water to identify provide a small number of further housing Peter  Infilling could ruin the character of the village of infrastructure constraints in the village. opportunities in the village over the remainder of Woodmass Kirton whilst Estate development would the plan period. Ann Worledge overwhelm it; Any potential development across the Mr & Mrs  No requirement for additional private open district will be expected to meet Core Payne market housing in Kirton/Falkenham; Strategy policies in relation to Brian Baker  No local employment opportunities in affordable housing provision and Fred Last Kirton/Falkenham; housing mix and type which will provide Mrs J Crosbie  Development would adversely affect the value of a range of housing opportunities for all. Mr & Mrs D my property; Piotrowski Future development needs to take into  Insufficient infrastructure to support further Eleanor development; account impact on landscape and the Piotrowski natural environment and these issues  No local employment opportunities in Olivia will be revisited through the Kirton/Falkenham; Piotrowski Sustainability Appraisal process which  Detrimental affects on the natural environment; Colin & Sue evolves alongside the production of the  Confusion regarding the volume of future Walker AAP. housing being proposed for Kirton. Andrew  Site 770 is landlocked unless 951 is developed. Camplin  Proposed housing mix does not meet Kirton’s needs.  Remarks concerning the scoring findings in Sustainability Appraisal.

Ref 3004 - Land at Bucklesham Road, Kirton. Trinity College, Support for site for housing (0.2 ha) by promoter Site is very small and would only Site is not included within the Preferred Options as Cambridge of site. provide a limited number of units which the Council considers it appropriate to identify Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 41 Map of site provided at the end of the document may not deliver the appropriate level of other sites. affordable housing provision or a mix of housing types and tenures as required by the local community. Ref 3020 - Land at Kirton Road, Falkenham. Stephen Support for site for housing (2.21 ha) by Noted. Site is adjacent to existing Site is not included within the Preferred Options as Creasey promoter of site. properties but would lead to an the Council considers it appropriate to identify Map of site provided at the end of the document increase in ribbon development in this other sites. location and may lead to settlement coalescence between Kirton and Falkenham. Ref 3002 – Land at Searson’s Farm, Cordy's Lane, Trimley St Mary. Trinity College, Support for site for housing (0.41 ha) by Site is adjacent to existing properties Site is not included within the Preferred Options as Cambridge promoter of site. but is considered to be an isolated the Council considers it appropriate to identify location on the edge of the countryside other sites. Map of site provided at the end of the document which is only accessed via a single track carriageway. Small site would only provide a limited number of units which may not deliver the appropriate level of affordable housing provision or a mix of housing types and tensures as required by the local community. Ref 3003 - Land at Great Street Farm, Trimley St. Mary. Trinity College, Support for 1 ha site for housing by promoter of Noted. Site is not included within the Preferred Options as Cambridge site. the Council considers it appropriate to identify Map of site provided at the end of the document other sites. Ref 3011a - Land at Candlet Road, Felixstowe. Christchurch Large scale site with potential for 500+ dwellings Site refused planning permission by Site is not included within the Preferred Options as Property and associated infrastructure on a site north of Planning Committee in June 2015. The the Council considers it appropriate to identify Company Candlet Road. Subject to planning application site is not considered to represent other sites. Limited DC/15/1128/OUT which was refused. organic and evolutionary growth of Felixstowe as required by the Core Map of site provided at the end of the document Strategy. Across the Felixstowe Peninsula, the sites identified as

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 42 preferred options provide the number of units required to meet the Core Strategy targets. Ref 3028 - Land at Manor Terrace, Felixstowe. Dave & Tricia Support for small site to be used for housing by Noted. Sits is currently used for caravan Site is not included within the Preferred Options as Bewers promoter of site. accommodation which supports the the Council considers it appropriate to identify Map of site provided at the end of the document tourism industry of Felixstowe and other sites. should be retained. Ref 3031 - Land off Thurmans Lane, Trimley St Mary. Resubmission of SHLAA site 383h ADP Limited Site submitted for residential development by the Noted. Site is small and below the Site is not included within the Preferred Options as promoter of the site. 0.25ha threshold outlined in the SHLAA. the Council considers it appropriate to identify Access could only be achieved from other sites. Thurmans Lane which the County Council have discounted. Adjacent to an area proposed to be protected from development and future development may have an impact on setting of Listed Buildings nearby.

Q8. Is the Council correct to remove the areas to be protected from development not within the Physical Limits Boundaries such as around Falkenham Church. Kirton & Special protection for Falkenham Church and the Noted The Preferred Options will include the Area to be Falkenham Churchyard to remain. Essential to retain the Protected from Development in Falkenham. Parish Council protection as well as the removal of the physical limits boundary.

The Economy. Q11. Are all the employment sites within the Felixstowe Peninsula still required? Hutchinson Noted that this plan is now superseded by the Noted. Boundary of the Strategic Employment Area has Ports UK proposed Map of Employment Areas and been redefined in the AAP. Limited Proposed Strategic Employment Areas in Felixstowe (Revised Jan 2015). Comments will be The Preferred Options document and the maps made on this proposed Map separately. accompanying will define the extent of the

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 43 Strategic Employment Area and General We suggest that the boundary coloured red Employment Areas. follows the quay line at the Port (i.e. new berths 8 & 9); plus FSR 2; all of Trinity Terminal and the North Rail Terminal; additionally the boundary might extend 70m seaward from the quay this is the extent of the Ports limits of jurisdiction. EDF Energy The document recognises that the Felixstowe Noted. The AAP recognises the strategic importance of the Networks Ltd Peninsula economy is dominated by the Port of Port of Felixstowe and its contribution to the wider Felixstowe which is of strategic importance economy. within the regional and national economies. EDF Energy supports the Council's approach to protect its use as it plays an important function for sea transport of goods to the existing Sizewell B station and could potentially serve the future Sizewell C station. Please note - Due to the number of comments received regarding this site citing similar responses, the key points have been summarised below; Felixstowe The Port has been automating jobs rather than Noted. The Council have been in The AAP seeks to provide a more robust and Town Council creating new ones, those people who had their discussions with the Port of Felixstowe balanced employment base across the Felixstowe jobs made redundant need to be redeployed first, to understand their current position Peninsula which will reduce the reliance on the Kimberley before encouraging inward migration, besides which has informed the AAP. Port for employment opportunities. Williams not everyone wants to live where they work as evidenced by the relatively lower cost of housing in Felixstowe compared to other parts of the District.

Q12. Are there any other potential employment sites which need to be brought forward? Discounted SHLAA 2014 site 998 - Land to the rear of Street Farm, Levington Lane, Bucklesham. Artisan Proposed for mixed use employment and The site was discounted in the 2014 The AAP does not identify this site as a preferred Planning & residential led scheme (2.17 ha). SHLAA because the site is poorly related option as other sites are considered more Property to the existing settlement and access is appropriate to meet housing and employment Services Ltd There is an identified need recorded at paragraph only available through an existing needs across the Felixstowe Peninsula. 5.4 of the FPAAP 2015 for a further 8.5 ha of commercial site. additional land within the district which is

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 44 required to support business and help facilitate the creation of new jobs. It is expected that part of the 8.5 hectares of employment land needed will be located within the Felixstowe Peninsula area in order to facilitate potential employment generating uses. The land at Street Farm is capable of delivering some of that employment land need and that should be recognised in the emerging plan. General comments. Christopher I believe that the District would do well to The AAP seeks to provide a more robust The vision and objectives for the AAP recognise the Leffler encourage new businesses by setting and balanced employment base across need for a more balanced economy across the provisionally low business rates for them for, say, the Felixstowe Peninsula which will Felixstowe Peninsula. two years, to encourage entrepreneurship. reduce the reliance on the Port for employment opportunities. The plan does not notice the small District Centre Parade of shops not identified as a District Centre. in Walton from the Garrison Lane junction The parade of shops at Garrison Lane towards the Main centre. does not meet the criteria identified for a District Centre. Although these shops provide local shopping opportunities they are not adjacent to a supermarket like the other District Centres. Michael David Lock recommended a non- Port Business/ Local employment opportunities at land The AAP includes a requirement for employment Ninnmey Science Park away from the Port, Master plan north of Walton High Street would units to be delivered alongside residential units on suggested West Walton, alongside Dockspur provide another site for employment the site north of Walton High Street. roundabout: not part of FPAAP. across the Felixstowe Peninsula.

Hutchinson We suggest that the boundary coloured blue Noted. Boundary of the Strategic Employment Area has Ports UK follows the quay line at the Port (i.e. new berths been redefined in the AAP. Limited 8&9). The whole of Trinity Terminal and the North Rail terminal. The Preferred Options document and the maps accompanying will define the extent of the Strategic Employment Area and General Employment Areas.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 45 Q13. Should uses on employment sites be restricted to traditional B1 (Business), B2 (General Industry) and B8 (Storage and Distribution) uses or do we need to take a more flexible approach? Save Trimleys Paragraph 5.6 of the FPAAP states: "The Council Noted. The AAP seeks to provide a more The vision and objectives for the AAP recognise the Against Growth expects that the type of business activity on the robust and balanced employment base need for a more balanced economy across the employment sites will be restricted through across the Felixstowe Peninsula which Felixstowe Peninsula. future policies to ensure that only appropriate will reduce the reliance on the Port for uses take place at particular locations, e.g. employment opportunities. The only restricting storage uses in locations where HGV's strategic employment area identified is may have a detrimental impact on the rural road the Port of Felixstowe. Any future network and local residents." Comment By STAG: strategic allocations will need to be It is good that this expectation seems to exclude considered through a Local Plan review. the use of land at Innocence Farm as a Distribution Centre and rail head. Felixstowe As part of its evidence base, the Town Council Noted. This work will form part of the No change. Town Council recommends that the District Council investigate evidence base to support the a future how port-related expansion plans may impact review of the Local Plan. local projections across a range of scenarios, having regard to social economic and environmental factors.

Q14. Do any other sites surrounding the Port of Felixstowe need to be included within the Strategic Employment Areas? Mr J Stafford The document fails to mention the fact that Port Noted. The AAP seeks to provide a The vision and objectives for the AAP recognise the is facing a threat of increasing competition from more robust and balanced employment need for a more balanced economy across the new and existing ports within the U.K, and also base across the Felixstowe Peninsula Felixstowe Peninsula. European ports such as Rotterdam. A significant which will reduce the reliance on the proportion of this investment is in automation. Port for employment opportunities. Whilst there is some potential opportunity for employment is supporting activities, much of this will be offset by increased automation in core port operations. Also the perceived link between dock 'expansion' and new housing needs in Felixstowe is spurious and misguided. Few jobs now have the long term security needed to justify uprooting your family each time you change jobs. Hutchinson HPUK on behalf of the Port of Felixstowe Noted. The vision and objectives for the AAP recognise the

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 46 Ports UK welcomes the publication of this important importance of the Port of Felixstowe. Limited document and the recognition of the importance of the Port on the local, regional and national economy. Keith Mahoney The document understandably does not mention Noted. The AAP seeks to provide a The vision and objectives for the AAP recognise the the fact that Port faces the threat of increasing more robust and balanced employment need for a more balanced economy across the competition from investment in capacity at new base across the Felixstowe Peninsula Felixstowe Peninsula. and existing ports within the U.K. A significant which will reduce the reliance on the proportion of the investments is in automation. Port for employment opportunities. In order to remain competitive Felixstowe Port must follow so whilst there is opportunity for employment in supporting activities this will be offset by increased automation. What is the strategic plan for developing other employment opportunities to reduce the risk and reliance on the continued success of the port other than tourism? There is no mention of this in the document.

Q15. Is the current town centre boundary still appropriate? Felixstowe Felixstowe town centre has become a destination Noted. Felixstowe town centre The AAP seeks to protect the vibrant and Town Council in its own right and provides a unique tourism provides a range of shopping facilities successful town centre for town centre uses. opportunity due to its relationship and proximity and services which serve communities to the seafront. Any policies relating to across the Felixstowe Peninsula and Felixstowe Town Centre should seek to further afield. The Council recognises acknowledge and further enhance this. the retail attractions as well as the tourist attractions found in the town centre. The Town Council proposes that the Town Centre Noted. The Council welcomes the The AAP proposes a revised boundary which boundary be redrawn in accordance with the proposed revisions to the town centre includes the areas below as suggested by the town map provided. boundary as suggested by the town council: council.  Waverley Hotel,  Auction Rooms on Orwell Road,  Ranelagh Road Car Park,  Area adjacent to railway station,  Rear parking areas on Fleetwood Road and off

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 47 Cobbold Road. Policies AP180 and AP181 should be reviewed Noted. The AAP has included the key aspects of these within the AAP to be included within any policies Local Plan policies as preferred options. for the town centre as a whole The Town Centre Management Plan was a Noted. Although Town Centre The AAP has included the continuation of the worthwhile process which produced several Management is beyond the scope of the shared space scheme (between Orwell Road and benefits for the town, such as shared space. This AAP the further continuation of the Bent Hill) within the preferred options document. should be revisited to create a new up-to-date shared space scheme is welcomed. Town Centre Management Plan. It is important to restrict residential uses in this Noted. The AAP seeks to protect ground floor uses to area to upper floors only and to limit office space retail only and welcomes no retail uses on upper to upper floors as per policy AP180 floors in accordance with the Use Classes Order and Permitted Development Rights. Carol Florey I support the change of boundary in the North Noted. The preferred options document includes a revised West Corner as it seems strange to cut across the boundary for the town centre which includes this middle of a site. site.

Q16. Should any areas be included or excluded from the town centre boundary? Christopher The first two areas should be included. The areas Noted. The preferred options document includes a revised Leffler fronting the Triangle should be included. The Car boundary for the town centre as well as a policy Parks are a vital part of the local economy for which seeks to protect car parking opportunities both residents and tourists. It is difficult for us across Felixstowe. residents to find a parking place in the season, and increasingly at other times of the year. It may be necessary to consider building more capacity by either adding a second storey at Ranelagh Road, or building downwards for an underground area.

Q17. Does the primary shopping area need to be extended to include areas fronting the Triangle? Felixstowe The expansion of 'other facilities' for the town Noted. The AAP needs to be in The preferred options document includes town Town Council centre referred to in Core Strategy Policy SP21 accordance with the NPPF, Use Classes centre policies which promote retail activity should be given more detail. The Town Council Order and Permitted Development alongside other uses and facilities which are found would support a revision of this paragraph where Rights which give flexibility to town within the town centre. it refers to the 'sequential test as stated in NPPF centre uses and other facilities normally paragraph 24'. found within town centres.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 48 The Town Council recommends extending the Noted. The preferred options document includes an Primary Shopping Area, as defined by saved extension to the primary shopping frontage, as policy AP179, to include the areas of Hamilton well as a policy which seeks to retain retail uses Road and Cobbold Road to the east and south of within the primary shopping area. The Triangle. Policy AP179 to be retained in a format which retains a flexible control over a range of uses, whilst preserving primarily retail uses. Carol Florey I support the idea of extending the primary Noted. The preferred options document includes an shopping frontage to include the Triangle shops. extension to the primary shopping frontage.

Q18. Should the boundaries of the existing District Centres be re-defined? NO SPECIFIC COMMENTS RECEIVED

Q19. Do any other District Centres or Local Centres need to be identified as part of the Felixstowe Peninsula AAP? Carol Florey I would suggest the parade of shops near to the The parade of shops at Garrison Lane Parade of shops not identified as a District Centre. crossroads of High Road and Garrison Lane does not meet the criteria identified for should be considered as a District Centre or the a District Centre. Although these shops Walton District Centre extended to include it. I do provide local shopping opportunities not consider the parade of shops at Faulkeners they are not adjacent to a supermarket Way sufficient to be considered as a District like the other District Centres. Centre. Felixstowe Page 27, Map Extract 2: This should be redrawn Noted. Surgery to be included within The AAP includes a revision to this District Centre Town Council to include the surgery but not the adjacent open the District Centre. boundary as a preferred option. space. The AAP includes a revision to this District Centre This should be redrawn and extended in both Walton District Centre extended to boundary as a preferred option. directions from the Garrison Lane junction to include Surgery and Public House on the Longcroft to include the various premises along corner of Maidstone Road. Extending this road. the District Centre further is considered inappropriate because it will include a The AAP includes a revision to this District Centre large number of residential units. boundary as a preferred option. The Town Council supports the identification of both the Spar supermarket and parade of shops Noted. on High Road East, opposite Brackenbury Sports Centre; and, Lidl Supermarket and the parade of

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 49 shops at Undercliff Road West, near the Individual shops are not shown on the maps Ordnance Roundabout as District Centres. supporting the preferred options document.

The Town Council supports the concept of Noted. Individual shops provide smaller retail areas to be identified as Local shopping opportunities across the Centres and would include the vicinity of Beach district through Core Strategy Policy Station Road traffic lights and the junction of DM30 which identifies individual shops Wadgate Road/Grange Road. A clear policy is as a Key Facility. required to protect the character of these. Michael 5.2b New District- Walton-cum-Felixstowe The parade of shops at Garrison Lane Parade of shops not identified as a District Centre. Ninnmey between Chester Road and Garrison Lane (Traffic does not meet the criteria identified for Lights). a District Centre. Although these shops provide local shopping opportunities they are not adjacent to a supermarket like the other District Centres.

Q20. Is it necessary to protect the existing car parks through a specific allocation? Carol Florey I strongly support the idea of free parking after 3 The management of car parks and The AAP seeks to protect car parking provision in car parks adjacent to the primary shopping charges within these is outside of the across the Felixstowe Peninsula. area. scope of the AAP. Hutchinson In respect of 2 of the Landguard Car Parks this Noted. The preferred options does not list the car parks Ports UK land is leased from the Felixstowe Dock and across the Felixstowe Peninsula Limited Railway Company and not owned by SCDC. It is suggested the wording is amended in both the text and table to refer to Car Parks being 'operated' by SCDC not 'owned'. Felixstowe The Convalescent Hill site provides a good Noted. The AAP seeks to protect car parking provision Town Council opportunity for a comprehensive development. A across the Felixstowe Peninsula, but multi-level design incorporating, as a minimum, redevelopment opportunities will be supported as the existing public parking provision within a mix and when these come forward as long as they of resort, parking and residential use could be maintain the same level of car parking provision considered here. Potential references for such a within the same area. designed could include the Design Brief referred to in AP199 and the David Lock report. Similar potential exists at Garrison Lane car park. This large site could lend itself to a design

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 50 incorporating retail and parking. Coach parking is known to be required and this site provides, at present, the optimum location for this.

Q21. Can the tourism needs of Felixstowe be met under one blanket criteria based policy? The Theatres The Trust supports measures to enhance and Noted. The Spa Pavilion is an essential The AAP outlines a number of preferred policy Trust promote tourism and tourism facilities and are part of the tourism and resort in options which consider tourism uses in Felixstowe. pleased the Spa Pavilion is acknowledged as an Felixstowe and is to be protected and important local facility. However, to reflect enhanced. planning guidance at Para 70 of the National Planning Policy Framework, the AAP should also seek to protect, as well as enhance existing community and cultural facilities. Facilities such as the Spa Pavilion support the social and cultural well-being of the local community and tourists and to the local economy.

Q22. Are there any tourism related policies which the Council need to retain as specific policies? Felixstowe Resort began in Victorian times (c.1891). The Noted. Historic references to The AAP outlines a number of preferred policy Town Council Town Council requests that the character of each Felixstowe will be corrected in the options which consider tourism uses in Felixstowe. of the distinct sections of the Felixstowe coastal preferred options document. The AAP frontage are protected by specific policies in the seeks to protect the coastal frontage of AAP. Paragraphs 11.160-11.219 of the 2001 Local Felixstowe and identifies individual Plan and its corresponding Proposals Map are character areas which are the focus of regarded by Members as being generally still the policies. valid and provide a reference point for this. All the policies referred to in that section should be updated for inclusion in the AAP; with the exception of AP202, which has been implemented, and references made in 11.212 to the Marine Aggregate Terminal, which are now obsolete. Vivien Grant I notice that Land at Felixstowe Sunday market Any redevelopment of the Sunday The AAP includes a preferred policy which outlines site, Sea Road, is included in the above plan as a market site would be conditional on the how the Sunday Market site will be redeveloped SHLAA site within the Felixstowe Housing Market retention of tourist/resort/commercial for residential uses but with a focus on Area (Table 2, Page 14). I do not understand how activities on the Sea Road frontage in tourism/retail/commercial activities on the Sea

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 51 this area can be included, as it is a long standing line with the long standing policy as well Road ground floor frontage. feature of Felixstowe and attracts crowds of as the successful relocation of the visitors each year. In the Plan, Mannings and the Market. Sunday market are noted in paragraph 5.35 on page 30 as being combined with ' important tourist attractions' and 'provide a fundamental contribution to the resort'. How can these two aspects be reconciled? Carol Florey The Sea Road Promenade area is a disgrace and Noted. The AAP outlines a number of preferred policy should be identified as an area for immediate options which consider tourism uses in Felixstowe attention. It is in the centre of the tourism area and the aspirations for the sea front. and is an absolute disgrace. Graham Felixstowe Ferry is supposed to be part of the Noted. Felixstowe Ferry will be shown on the maps Henderson Town yet apart from comment on houseboats supporting the preferred options document and and some references to tourism we get no the AAP recognises the unique character of specific mention in the document. Nor are we Felixstowe Ferry in the tourism policies. included on the document maps of Felixstowe and the Trimleys. Historically there was SCDC planning policy that No. Felixstowe Ferry is still outside of Felixstowe Ferry is shown as being outside of the stated that there would be no further building the physical limits boundary and is physical limits boundary on the maps supporting allowed at Felixstowe Ferry. Has this now been subject to the countryside restraint the preferred options document. dropped from policy? policies. Outside of the physical limits boundaries, new development is severely restricted. I would remind you of a survey some years ago Noted. The AAP recognises the unique character of by County Council that Felixstowe Ferry was the Felixstowe Ferry in the tourism policies. hottest tourism spot in Suffolk with over 200,000 annual visitors. Landguard A single tourism strategy for Felixstowe would be Noted. The Council recognises the The AAP outlines a number of preferred policy Project Officer useful providing a joined up approach to all the different areas on the Felixstowe sea options which consider tourism uses in Felixstowe elements that make up the tourism offer; front and identifies these in the AAP. and the aspirations for the sea front. attractions, accommodation, retail, food/drink, Issues such as signage, car parks, marketing/events/promotion. signage/marketing/promotion are Felixstowe coastal strip has 4 distinct areas that outside the scope of the AAP. attract visitors: Felixstowe Ferry & Golf Course, Spa and Seafront Gardens, Pier/Leisure Centre to

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 52 Manning's/Martello Park, and Landguard. Although the character of each area needs to be kept distinct they need to be joined up with pedestrian, cycle, bus routes, car parks, signage and facilities. A single pedestrian/cycle accessible promenade from ferry to Landguard would be a good start.

Environment. General comments. Please note - Due to the number of comments received regarding this site citing similar responses, the key points have been summarised below; Gillian Mason It is essential that the AAP seeks to develop a Areas to be protected from The AAP identifies land north of Conway Close as a Trevor Mason revised and relevant policy on areas to be development relate to areas which preferred option. protected from development, and those areas make a significant contribution to the which are adjacent to the AONB, should be open character of an area and are not included. Site 502e cannot be deemed "suitable" used in relation to the landscape and when measured against sustainability and areas adjacent to the AONB. The site environmental assessments. This site, together north of Conway Close (502e) has been with 502-502c, should form part of those areas of subject to Sustainability Appraisal and high environmental importance which help form considered against a range of the townscape and communities within the environmental policy constraints. peninsula. The development at Ferry Road went These have identified that the site is against the Core Strategy environmental policies, suitable for potential development. and saved Local Plan Policies; this should not be allowed to happen with any more greenfield The Council’s considerations in relation sites. to the development at Ferry Road are well documented in the Case Officer report and the Minutes associated with that decision. RSPB All designated wildlife sites should be identified. All designated sites are taken into The AAP includes reference to the relevant These should include non-statutory sites such as account alongside planning applications designations where appropriate or where County Wildlife Sites, as well as those benefitting and future redevelopment proposals or mitigation measures are required. from statutory protection such as SSSIs and potential allocations. European sites (SPAs, SACs and Ramsar sites). In addition, sites supporting priority habitats and Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 53 species under the Natural Environment and Rural Communities Act (2006) should be identified. It should be noted that such protection should not be limited to consideration of impacts from development directly on or adjacent to a protected site, but should include indirect impacts such as those of increased recreational pressure. Michael Should River Orwell, north shore be a AONB? Noted. The maps supporting the AAP identify this area as Ninnmey part of the AONB.

6.18 Settlement time line between the orwell- Noted. The AAP will ensure that the evolution of Deben rivers much longer than (?)- from BC 2500- Felixstowe will be detailed correctly. now. Becker- Roman (Castle till 15c) LANGUARD (HENRY VIII) MARTELLO TOWERS (8 now 9 1/2) RAF FELIXSTOWE/BAWDSEY (RADAR HOME) COLD WAR BUNKER Felixstowe Suggest that a paragraph dedicated to the DEP The Deben Estuary Plan is just one The AAP includes reference to the Deben Estuary Town Council (Deben Estuary Plan) be included in the AAP. document within the evidence base Plan where relevant. which the AAP is based upon. Graham Para 6.17 makes reference to the DEP Plan but Noted. The Deben Estuary Plan is just The AAP includes reference to the Deben Estuary Henderson only states that there may be a need to take one document within the evidence base Plan where relevant. similar risk base on estuaries as for coastal zones. which the AAP is based upon. It should not be "maybe a need" but applied. There are other aspects of the DEP Plan that need inclusion once agreed by council but I assume can only be after it has been adopted/endorced by Council in March. AQMAs (Air Quality Management Zones) Julie Cornforth Why have only 1 AQMA in Felixstowe. Air The Council’s Environmental Protection The AAP does not include reference to an pollution in Felixstowe doesn't just stop in one Team deal with issues of air quality additional AQMA. place! The prevailling winds takes the pollution across the district. AQMA’s have been from the dock over Felixstowe town so it might identified in various places across the be an idea to test the air quality in other district and are closely monitored to locations around the town and the A14? Test the determine whether air quality is air quality all around Felixstowe and the A14 to increasing, decreasing or is static. No

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 54 ensure that the Air Quality within these areas is additional AQMA’s are identified at this not to the detriment of the environment or time. public health. Hutchinson Suggest amended and additional wording, ... at Noted. The Council’s Environmental No change to the AAP. Ports UK Ferry Lane, Felixstowe. This is as a result of Protection Team are aware of the Limites concentrations of Nitrogen Dioxide above the reasons for the AQMA and continually national objective in 2009. The most significant monitor the air quality in and around sources of NO2 at the AQMA have been Ferry Lane. identified as Container Handling (37%), External Heavy Duty Vehicles (29%) and Background Concentrations (23%) emissions from and associated with the Port of Felixstowe. Environmental The continued monitoring of nitrogen dioxide Noted. Issues surrounding air quality The preferred options document includes Protection levels within the AQMA allows us to determine will be explored further as the AAP reference to the need for air quality assessments, Team what the levels are and whether they are evolves through consultation. the requirement to mitigate the impact of future increasing, decreasing or static, it does not in development on air quality and monitoring to itself actually enable us to ensure that air quality ensure that any future development across the is not detrimental. This is tackled by the peninsula does not have a negative impact on the statutory Air Quality Action Plan which has been AQMA identified at Ferry Lane, Felixstowe. produced for the AQMA - the aim of which is to protect Public Health only. Air quality affecting 'the environment' itself is not covered or tackled by the Local Air Quality Management process but will obviously be positively impacted upon.

Q23. Should policies protecting Landscape and Townscape features be combined as there are certain similarities within these designations which seek to avoid material adverse impact upon these areas? If so, should there be one policy to cover these designations, or should some division be maintained? Michael 6.9 Mitigation on noise/light impact needed for Noted. The AAP seeks to identify future No change to the AAP. Ninnmey residential dwellings along route to dock. requirements as opposed to mitigating the existing issues. Felixstowe The Town Council would recommend that Noted. The preferred options document outlines policies Town Council division of policies protecting Landscape and for landscape, access to the countryside, heritage Townscape features be maintained. as individual policies. Historic England The European definition of Landscape includes Noted. The AAP includes a preferred policy which focuses Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 55 urban landscapes and therefore there may be on areas to be protected from development. some logic to combining policies to protect Conservation Areas are covered by Conservation natural landscape and urban landscape features, Area Appraisals and Core Strategy Policy SP15. but care will be needed to ensure there is no blurring of the issues resulting in a loss of protection. We would specifically advise that the policy on Areas to be Protected from Development is not combined with policies on Conservation Areas. Some conservation areas contain sites that are currently negative features where development might result in enhancement. Historic England generally favours separate policies specific to the needs of the historic environment.

Q24. Is the criteria within the Special Landscape Area policy (AP13) still appropriate? Felixstowe The Town Council requests additional No part of Felixstowe is covered by The maps accompanying the preferred options Town Council information on where sites designated as Special Local Plan ‘Saved’ policy AP13-Special document show the environmental designations Landscape Areas are in Felixstowe. Landscape Area. The only Special across the Felixstowe Peninsula. Landscape Area within the Felixstowe Peninsula is in Kirton.

Q25. What does the Coastal Change Management policy need to include? Marine The MMO feels there is merit in also including Noted. The evidence base supporting The preferred options document makes reference Management reference to East Inshore and East Offshore the AAP is comprehensive and includes to appropriate evidence base document where Organisation Marine plans as another document to consider many documents and studies including appropriate. aligning with. The East Inshore and East Offshore the Marine Plan. Marine Plans are available on line via the link provided https://www.gov.uk/government/collections/ma rine-planning-in-england.

Under sections 5.7 to 5.11 Felixstowe port and its importance are discussed. This would be an appropriate area to mention the East marine plan ports policies, especially PS3 which supports port growth and development. Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 56

Section 6.11 makes reference to climate change and links can be made to the east marine plan. Michael Coastal/river defence dual purpose- Noted. No change to the AAP Ninnmey defence/tourism. Felixstowe Any Coastal Change Management policy must not Noted. Upon further consideration of The AAP includes an explanation as to the current Town Council preclude development within areas that are the Shoreline Management Plan and thinking and position on Coastal Change protected from flooding or erosion. Town Council discussions with the Coastal Management Areas for the Felixstowe Peninsula. is firmly of the view that when considering such a Management Team, the AAP does not policy, full regard to existing defences should be require a Coastal Change Management included. Similarly, the 30m buffer zone may be Policy because the Shoreline too restrictive in several otherwise suitable Management Plan seeks to hold the locations if adequate coastal protection measures existing coast line in Felixstowe. have already been introduced. Graham 6.15. This para makes vague reference to Noted. The Environment Agency are a The AAP includes references to flood risk Henderson following Waveney policy of no building within a statutory consultee in respect of flood constraints in the appropriate areas across the 30m buffer of projected 100 year risk zone. This risk and any future development will be Felixstowe Peninsula. It also includes an makes no logical sense as the 30m distance could directed to locations which are in areas explanation as to the current thinking and position still be on a flood plain. A policy should be not at risk of flooding. A Coastal on Coastal Change Management Areas for the adopted of NO building in an EA specified flood Change Management Policy is not Felixstowe Peninsula. cell or below 5m contour line on coast and required because the Shoreline estuaries. It does concern me that planning Management Plan seeks to hold the committees get comment from the Environment existing coast line across the Felixstowe Agency on planning applications but members of Peninsula. the Committee do not have these specific recommendations brought before them at meetings as they are not statutory.

Q26. Local Plan Saved Policy AP1 on Conservation Areas is more detailed that the other policies. Is this extra detail justified, and if so does this warrant a separate policy for Conservation Areas? Christopher The Ferry Area should be both a Vulnerable area Felixstowe Ferry is outside of the The maps accompanying the AAP clearly show Leffler and a conservation area. The wild area between defined physical limits boundary and these areas as being outside of the physical limits the Recreation Ground pitches and the A14 therefore not a location which the boundary. should be retained as it is as a conservation area Council expects to see future where dog walkers and children are daily looking development. The area north of the for recreation. A14 and Candlet Road is also outside of

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 57 the physical limits boundary and the AAP seeks to protect this area from future development.

Q27. Should the policy on Areas to be Protected from Development be combined with the policy on Conservation Areas, as Areas to be Protected from Development have similar protection to areas identified in conservation areas which should not be developed? Felixstowe The Town Council believes that the extra detail Noted, however Core Strategy Policy The AAP includes a separate policy for Areas to be Town Council provided in the saved Policy AP1 on Conservation SP15 provides the strategic policy with protected from development. These areas and Areas is justified and a separate policy for respect of conservation areas in parallel conservation areas are shown on the maps Conservation Areas is warranted. The policy on with the Conservation Area Appraisals accompanying the preferred options document. Conservation Areas and policy on Areas to be published for the individual areas. Protected from Development should be kept Areas to be protected from separate as there are locations in Felixstowe that development have been identified and do not fall in to the conservation area but which are covered by a separate policy. require specific protection under a policy similar to AP28.

Q28. Should policies be written to consider proposals for development affecting protected wildlife or geodiversity sites or landscape areas or are they adequately covered by the Core Strategy? RSPB Core Strategy policies need to be 'supported by Noted. Core Strategy Policy SP14 No change to the AAP. appropriate detail' (see para.6.5) within the AAP outlines the Council’s position to to ensure protection/consideration of national Biodiversity and Geodiversity and it is and international wildlife sites not considered appropriate to repeat (SPA/SAC/Ramsar/SSSI) and protected and this policy (or a similar policy) within priority species is commensurate with that given the AAP. to e.g. the Heritage Coast and AONB. We recommend that a specific policy emphasising the importance of biodiversity and protected sites should be included. Felixstowe Policies should be written to consider proposals Noted. Core Strategy Policy SP14 No change to the AAP. Town Council for development affecting protected wildlife or outlines the Council’s position to geodiversity sites or landscape areas to support Biodiversity and Geodiversity and it is the Core Strategy policies SP14 and SP15 as per not considered appropriate to repeat Page 33, Para. 6.5. this policy (or a similar policy) within the AAP. Policy requirements relating to green Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 58 Undoubtedly there will be many ways in which infrastructure and access to the countryside have the Felixstowe Peninsula AAP can promote a Noted and agreed. The AAP will seek to been included within the Preferred Options network of green infrastructure; however this facilitate the necessary green document. wide ranging issue requires additional time to infrastructure and access to the consider. countryside alongside development which comes forward across the Felixstowe Peninsula.

Q29. Which sites across the Felixstowe Peninsula need to be identified to protect and enhance biodiversity and geodiversity as detailed Core Strategy policy SP14? NO SPECIFIC COMMENTS RECEIVED

Q30. Which sites across the Felixstowe Peninsula need to be identified and protected to resist settlement coalescence as detailed by Core Strategy policy SP15? Michael 6.22 Coalescence already taken place Felixstowe, Noted. The AAP identifies an area to be protected from Ninnmey Walton and Trimley St Mary. development between Felixstowe and Trimley St Mary to resist any further settlement coalescence. Save Trimleys Retained Policy AP171-Felixstowe Peninsula- The site north of Walton High Street has The AAP identifies an area to be protected from Against Growth Separation of Town from Trimleys requires a been identified as this presents an development between Felixstowe and Trimley St buffer area of greenfield separation, whose size opportunity for organic and Mary to resist any further settlement coalescence. has not been defined, to be retained between evolutionary growth in a location well A preferred policy detailing policy requirements to Walton and Trimley St Mary. If properly enforced, related to existing services, facilities and bring the residential allocation forward is also this could mean that some or all of the prime education opportunities. The Council is included. food producing farmland described as "at and aware that this would lead to the loss of surrounding Felixstowe Rifle Club, south of some prime agricultural land but on Dockspur Roundabout" (Site 451g), could be balance is considered appropriate. excluded from the sites deemed to be suitable for housing allocations. It will be remembered that this area of farmland was previously the subject of a rejected Planning Application for a Tesco Superstore and a new housing development.

Q31. How can the Felixstowe Peninsula AAP promote a network of green infrastructure? Julie Cornforth The David Lock report stated that the AONB Noted. The AONB is defined by Natural The AAP includes a policy in relation to accessing should be extended. England as the statutory body. Links to the countryside as well mitigation measures to The Haven Gateway Plan also stated that there the countryside from new development ensure that new development provides links to

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 59 should be "green corridors" for the wildlife. sites will be welcomed as part of the green infrastructure opportunities. Perhaps SCDC should consider the protection of AAP. wildlife in the Felixstowe area.

Community and Well-Being issues. Q32. Are the current open space designations appropriate? Julie Cornforth It was identified in the Haven Gateway Green Noted. Development sites have been The AAP includes a policy in relation to accessing Infrastructure Plan that Felixstowe has the least identified by taking into account the the countryside and what steps will be taken to accessible "Natural Green Space" at present. The impact they will have on the ensure that deficiencies identified in the evidence town's location together with the scale of the countryside and the opportunities they base are overcome. port means that there are limited opportunities present to improve access to the to gain easy access to the countryside. So why countryside. ruin what little countryside that we have left.

Q33. Are there any other areas which ought to be protected through an open space designation? Ian Buxton All current green space should be protected. The Noted. The development proposed in The maps accompanying the preferred options area of outstanding natural beauty to the North the AAP is not considered to have a document show the physical limits boundary for of Ferry and Gulpher Roads to the Deben estuary detrimental impact on the AONB and the settlements in the Felixstowe Peninsula. These should be protected from development and protects the open countryside outside boundaries protect the countryside by directing enhanced access provide for local people to of the built up area. future development to areas within the physical enjoy. limits. Carol Florey I cannot see the Grove mentioned anywhere but Noted. The Grove is an important area The maps accompanying the preferred options this should be an area to be protected from of open space and recreation for the document shows the Grove outside of the physical development. I also believe all existing parks and Felixstowe community. It is protected limits boundary of Felixstowe. playing fields should be covered in this way. from future development through Core Strategy Policy SP16 and DM32. The Grove is also outside of the physical limits boundary so development in this area is considered inappropriate. Christopher The allotment sites, all 5 of them need protecting Noted. Allotments are protected by No change. Leffler as well as the public open spaces. There is a Core Strategy Policy DM33 and it is not statutory proportion of plots per quantity of appropriate to repeat this policy in the housing units, and it is vital if the areas are to be AAP. developed intensively, that those who wish to

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 60 have plots should be able to get them. Allotment land is not marginal, it is essential for food, health via exercise as well as the produce, and mental health. Sport England Suffolk Coastal DC have recently completed a The Playing Pitch Strategy is part of the No change. Playing Pitch Strategy (PPS) which seeks to assess evidence base which supports the AAP. existing and future needs for playing fields and Playing fields are protected under Core other outdoor sports facilities within the district. Strategy Policy SP16 and DM32 and it is Sport England believes that playing fields should not appropriate to repeat these policies be protected from inappropriate development within the AAP and the PPS will help to identify key sites within the Felixstowe AAP area which should be designated to strengthen their protection. This could include playing fields and other outdoor sports facilities such as artificial pitches, tennis courts, bowling greens etc.

Q34. What are the opportunities for improving green infrastructure within the Felixstowe Peninsula? Michael 7.1 Widen access to physical activity of all types Noted. The Suffolk Coastal Leisure The preferred options include references to Ninnmey for all ages for improved well being and Health. Strategy which is part of the evidence making links to existing sports and play facilities as Sports field provision fallen/ significant restriction base underpinning the AAP identifies appropriate. on access is school sport fields. Review across the measures to increase physical activity whole FPAAP area. and leisure opportunities across the district. 7.2 Create a river to river walk, make a walkway from Jacobs Ladder to Dip Promenade, possible The Council will consider proposals for to add cycle route? extending the promenade on their merits and in partnership with the relevant bodies and organisations if and when funds and projects come forward. 3.9 Public Access to Sea/rivers needs is improve (Public access, when dock closed Public Quay; removed. Proper Quay needed at Orwell mouth to support Sea/River trips: LANGUARD- HANWICH; SHOTNEY; IPSWICH Seatrips- Felixstowe Ferry- LANGUARD. Ferry-

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 61 Woodbridge- Sutton Hoo Promote tourism/Leisure/Sport ect 6.10/14 Coastal/river defence dual purpose- defence/tourism. RSPB Para. 7.1 states that the Felixstowe AAP has the Noted. The Haven Gateway Green The preferred options include reference to green opportunity to identify site specific projects such Infrastructure Strategy is part of the infrastructure requirements where appropriate as playing fields, green links, allotments and evidence base which supports the Core and promotes access to the countryside through other facilities which are fundamental to the local Strategy and the AAP. The Core an individual policy. communities. We note that opportunities should Strategy details the Council’s approach also be sought to enhance local ecological to Biodiversity and Geodiversity is networks through the restoration, enhancement, outlined in Core Strategy Policy SP14 buffering and linking of sites of biodiversity value. and it is not appropriate for the AAP to We recommend that strong links are made to the repeat this policy. outputs of the Haven Gateway Green Infrastructure Strategy. As recommended above, this could be used to generate advice for developers regarding green infrastructure and biodiversity measures targeted at the requirements of the Felixstowe peninsula. Felixstowe Undoubtedly there will be many opportunities for Noted. The Felixstowe Cycle Strategy is The preferred options include requirements to Town Council improving green infrastructure within the part of the evidence base which ensure that new developments provide links to the Felixstowe Peninsula; however this wide ranging supports the AAP. existing network of footpaths and cycle ways. issue requires additional time to consider. The AAP should support the proposals contained within the Felixstowe cycle infrastructure review recently conducted by Suffolk County Council for opportunities for improving the cycle network within the Felixstowe Peninsula.

Q35. What types of open space, sport and play facilities, community facilities are needed to generate a sustainable community? Felixstowe Clickett Hill is not open space, it has planning Noted. Clickett Hill is included within the Strategic Town Council permission as industrial land and therefore this Employment Area. The preferred options designation has been superseded. Please can the document will include reference to the Spa Cliff Gardens be renamed to Spa Gardens. Gardens.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 62 With regards to the types of open space, sport and play and community facilities needed to The preferred options document makes reference generate a sustainable community, the AAP to a range of community facilities throughout. should overtly reference where these are included in the Leisure Strategy. Yes, the Felixstowe Peninsula would benefit from greater community facilities/ opportunities. Theatres Trust In regards to the question on page 40, we Noted. These facilities are covered by No change. recommend that this section include policy for all Core Strategy Policy DM30 which seeks community and cultural facilities that are to protect Key Facilities across the important to quality of life, for which we would district. It is considered inappropriate support the comment that the Felixstowe to repeat this policy within the AAP. Peninsula AAP can play a key role in ensuring that facilities are retained and guarded against inappropriate development. . Sport England Community indoor and outdoor sports facilities Noted. These facilities are covered by The preferred options include references to all help to generate a sustainable and healthy Core Strategy Policy DM30 and DM32 ensuring that development is linked into existing community. Facilities include playing fields, which seek to protect key facilities and footpaths and cycle ways which provide access to tennis courts, bowling greens, multi-use games sport and play facilities across the community facilities and recreation opportunities. areas, swimming pools, sports halls, youth district. It is considered inappropriate facilities (skate parks etc.) and informal areas for to repeat this policy within the AAP. sport (parkland for kick abouts). Landguard Allow cycling on the promenade (A similar sized Cycling along the Promenade is not No change. Project Officer seaside town - Bognor Regis, has already within the remit of the AAP. successfully implemented this). A network of better off road, well signed family safe cycle routes joining up the Peninsula. Well placed car parks and facilities so people from outside the Peninsula can access the network. It would relieve pressure on car parks in the town, near to the coast. Encourage more local people to cycle to school, work and during leisure time.

These facilities, as well as being for the The AAP takes into account the Suffolk The preferred options document identifies the community can also be important attractions for Coastal Leisure Strategy and identifies Leisure Centre as a attraction. visitors/tourists. The Leisure Centre review is an the Leisure Centre as an important

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 63 opportunity to provide top class, wow factor tourist and resident attraction in the swimming/leisure pools with slides, small outside town. Any proposals to redevelop the heated pool, etc. This would provide excellent Leisure Centre would be considered on facilities for the community and also be a major their merits in accordance with the AAP boost to tourism which would finance annual and Core Strategy policies relating to maintenance costs. It would also have the regeneration and redevelopment. secondary benefit of boosting regeneration of commercial properties along sea road and the wider town, and allow the town to compete with other seaside destinations. Q36. What are the opportunities for improving the cycle network within the Felixstowe Peninsula? NO SPECIFIC COMMENTS RECEIVED

Q37. Would the Felixstowe Peninsula benefit from greater community facilities/opportunities? Landguard Raise profile of the town and improve image. Noted. The AAP seeks to identify the Council’s aspirations Project Officer Encourage younger people and families to stay/ for the Felixstowe Peninsula and promotes the move into the town. Improve fitness, health and area in a positive manner. wellbeing. Increase tourism, create jobs, boost local economy and encourage further outside investment. Educational capacity. Eric Southgate Spaces are available here because parents are Noted. Suffolk County Council as The AAP includes the requirement to link sending their children to any school that they can education authority have been involved development to existing education opportunities get into off the Felixstowe peninsular because with the preparation of the AAP. across the Felixstowe Peninsula. the local schools are below government approved levels according to OFSTED. Not Fit For 'Looked After Children' means not fit for purpose of anyone else’s children. Carol Florey I challenge the statement 'there is capacity across Noted. Suffolk County Council as No change. the area for both primary and secondary education authority have been involved education.' As I understand it there was only an with the preparation of the AAP. additional capacity of 100 when the new Academy was built. This is not capacity to cope with 850 new families.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 64 Suggestions regarding specific ‘saved’ Local Plan policies and future policy development. Need for retention of ‘saved’ Local Plan policies. AP208 - Felixstowe urban fringe. Please note - Due to the number of comments received regarding this site citing similar responses, the key points have been summarised below; Gillian Mason Policy AP208-Felixstowe Urban Fringe-this policy Areas outside of the defined physical It is not considered necessary to repeat Core Trevor Mason saved from the Local Plan has served Felixstowe limits boundaries are protected by Core Strategy policy in the AAP. A newly defined well in terms of protecting its limited countryside Strategy Policy SP29: Countryside. This physical limits boundary is shown within the and open green space. Following the breaching policy acknowledges the important preferred options document for public of this policy in granting OPP on fields in Ferry economic, social and environmental consultation. Road, the green space left in that area provides assets that areas outside of the valuable recreational opportunity and general settlements bring to local communities "well being" to residents, visitors and tourists. As and the district. such the policy should be retained in the AAP, and not replaced by one which extends the town boundary. As smaller towns and rural villages in the district are protected from development, so Felixstowe should be afforded the same entitlement. AP171 - Felixstowe Peninsula - separation of town from Trimleys. Save Trimleys Retained Policy AP171-Felixstowe Peninsula- Noted, the AAP will seek to resist The preferred options document identifies a new Against Growth Separation of Town from Trimleys requires a settlement coalescence where possible area to be protected from development to the buffer area of greenfield separation, whose size but in some locations communities will west of the A14 Dock Spur to maintain the has not been defined, to be retained between become closer as the organic and separation between Felixstowe and Trimley St Walton and Trimley St Mary. If properly enforced, evolutionary growth comes forward as Mary. The preferred options document identifies a this could mean that some or all of the prime anticipated by the Core Strategy. It will site for residential development with some food producing farmland described as "at and be important to retain the separation of business units and open space. The site is surrounding Felixstowe Rifle Club, south of Felixstowe and Trimley St Mary but the considered to be broadly in accordance with the Dockspur Roundabout" (Site 451g), could be Local Plan Policy is considered to be too Core Strategy and is extremely well related to the excluded from the sites deemed to be suitable for restrictive and in part has already been existing communities, services and facilities and housing allocations. It will be remembered that eroded by developments such as education opportunities which on balance this area of farmland was previously the subject Felixstowe Academy and the outline overcome the loss of the prime agricultural land in of a rejected Planning Application for a Tesco planning permission granted for up to this location. Superstore and a new housing development. 190 units on land south of Walton High

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 65 Street. AP206 – Felixstowe – Landguard Fort /207 – Felixstowe – Land around and adjacent to Landguard Fort. Landguard AP206/207 pertaining to development of The AAP will seek to develop a policy The preferred options document contains a specific Project Officer Landguard as a visitor attraction are out of date. which focusses on Landguard in respect policy in respect of Landguard which strikes the Under the S106 agreement with the port an of the unique character of this area. balance between the unique landscape, scheduled interim visitor centre/cafe have been installed. Proposals which boost tourism uses but ancient monument, visitor pressures and proximity Car parking has been increased but is still are sensitive to the protected to the port. insufficient. The Landguard Partnership is seeking landscapes on the Landguard Peninsula funding to improve the visitor offer in terms of will be supported. The Council will access and interpretation, including the fort, continue to be an active part of the museum and nature reserve. There is still Landguard Partnership and the AAP will uncertainty over when/if FSR2 will go ahead be complementary to the work of the which will have a further impact on Landguard. partnership. Balance of needs of increased visitors and Nature Reserve/SSSI. There seems to be no policy regarding the Felixstowe--Shotley Foot Ferry? AP170 – Felixstowe – restraint. Felixstowe The District Council should provide assurance The AAP will seek to ensure that The preferred options document provides further Town Council that the principles of AP170 will be covered by Felixstowe grows and develops in an detail as to how Felixstowe will grow and develop. the AAP. appropriate way which is in accordance with the Core Strategy and the NPPF. AP187 – Felixstowe - Enhancement scheme. Felixstowe Whilst the Town Council acknowledges the AP187 was superseded by the Core The preferred options document provides details Town Council reason given for removing policy AP187 (as being Strategy. Any future developments will of the mitigation measures that are required for that most improvements will be achieved be judged on their own merits and will some developments across the Felixstowe through the imposition of landscaping conditions be expected to ensure they do not have Peninsula. attached to planning permissions as part of a detrimental impact on the normal development control considerations and surrounding area through loss of light or by this means resources will become available) poor design. the AAP should provide some comment on how the appearance of industrial areas will be enhanced. AP175 – Felixstowe – Carr Road.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 66 Felixstowe Policy AP175: This must be retained as it is critical Noted and agreed The preferred options document includes a specific Town Council to avoid potential container traffic in this area. policy in respect of the Carr Road/Langer Road Policy SP5 in the Core Strategy defines general General Employment Area. employment areas as being B1, B2 & B8 unless "specified in specific policies". Carr Road needs to continue to be restricted to B1 & B2 only to minimise heavy lorry movements. Similarly, Bridge Road should be restricted to B1 & B2 only to minimise heavy lorry movements to and from this site and consideration should be given as to how the number of containers currently located in this area can be reduced. AP193 – Felixstowe - Clifflands carpark. Felixstowe Policy relating to Clifflands Car Park has not been Noted. The preferred options document contains a Town Council fully implemented and should be retained. "Bus tourism policy which covers Clifflands car park. Station, Garrison Lane" should now be renamed to the area north and east of the Garrison Lane / Langer Road junction. Comments in Support of future policy development. Felixstowe With regards to houseboats, the Town Council Noted. The preferred options document contains a Town Council would like the see a policy which supported tourism policy in respect of Felixstowe Ferry which replacement of existing houseboats (rather than addresses the issue of house boats and access to new/additional number). Houseboats, where the River Deben. appropriate, are part of the character of Felixstowe Ferry. Wm Morrison There is no indication that the future policy Noted. The Council has undertaken The AAP does not include a specific reference to Supermarkets would require Retail Impact Assessments to be some additional work to consider retail retail impact assessment, therefore the threshold Ltd carried out where applications for retail schemes capacity across the district. in the NPPF is that which the Council will use in are proposed on edge or out-of-centre sites. Our respect of future retail applications. client's view is that this should be required in association with any application for retail development of 1,000sqm and above to reflect recent changes in consumer shopping habits and the changing face of convenience goods retailing: stores are becoming smaller and people are

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 67 generally shopping more frequently.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 68 Maps of new sites submitted through the Issues and Options consultation

A number of sites were submitted to the Planning Policy and Delivery Team during the Issues and Options consultation for the Site Allocations document and the Felixstowe Peninsula AAP.

Some of these sites were resubmissions of sites previously identified in SHLAA 2014 as ‘deliverable’ or ‘discounted’ and are therefore not included as maps but are listed for clarification in the main document - Appendix 3: Tables of all sites considered. All new sites, and those where the boundary of a previously submitted site has been altered, are included below.

The new sites submitted are accompanied with lists of relevant constraints which have been identified on the Council’s GIS system and a brief summary of the sites’ status. The sites are laid out in a similar way to the SHLAA for consistency. Sites are drawn with a red boundary. A key is provided to identify policy designations on maps.

© Crown Copyright and database rights 2012 Ordnance Survey 100019684

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 69 FELIXSTOWE PENINSULA AAP 3002 Felixstowe housing market sub area Site Parish Address Size Constraints ref (ha) 3002 Trimley Land at Searsons 0.41  Saved policy AP172 – Felixstowe Port – Protection of St Mary Farm, Cordys the AONB Lane  AONB to west  Adjacent to countryside management site  Listed buildings to the south (Searson’s Farmhouse, grade II; Cartlodge to W of Searson’s Farmhouse, grade II; Barn to SW of Searson’s Farmhouse, grade II.  Site to east may be archaeological interest

Site discounted The site lies outside the physical limits boundary and therefore is in countryside. Development of the site may result in harm to the setting of nearby listed buildings. Potential encroachment on an existing employment site. Contrary to Saved policy AP172 – Felixstowe Port – Protection of the AONB.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 70 3028 Felixstowe housing market sub area Site Parish Address Size Constraints ref (ha) 3028 Felixstowe Land at Manor 0.19  Adjacent to Landguard Nature Terrace Reserve  Flood Zone 2 and 3  < 0.25ha threshold.

Site discounted Site forms part of an existing caravan site. Site to be retained for tourism purposes. SP8 - Tourism

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 71 3003

Felixstowe housing market sub area Site Parish Address Size Constraints ref (ha) 3003 Trimley St Great Street 1.01  Listed buildings to north-east Mary Farm  Allotments to north/north-west  Site of archaeological interest to south  SWT consultation area  TPO nearby  Public Right of Way nearby

Site discounted Development of this site had the potential to create development of a potentially undesirable ‘backland’ nature. The site would be accessed from High Road and issues regarding the siting of an electricity sub-station within the access area would need to be investigated further.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 72 3004 Felixstowe housing market sub area Site ref Parish Address Size Constraints (ha) 3004 Kirton Land at Bucklesham Road 0.20  N/A

Site discounted Site has been discounted in favour of an alternative site receiving greater community support.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 73 3011a Felixstowe housing market sub area Site Parish Address Size Constraints ref (ha) 3011a Felixstowe Land north of 31.7  Floodzones 2&3 in NE corner of site Candlet Road  Area which may be of archaeological interest  BAP species (including badgers) have been recorded on site  Sites and monuments: Cowpasture Farm

See DC/15/1128/OUT Planning application refused 12.06.2015.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 74 3020 Felixstowe housing market sub area Site ref Parish Address Size (ha) Constraints 3020 Falkenham Land at Kirton Road 2.21  Listed building to east

Site discounted Falkenham is classified as an ‘other village’ and is therefore located in countryside. The site was considered to relate poorly to Kirton and would constitute potential ribbon development creating a potential risk of coalescence between Falkenham and Kirton.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 75 3022a Felixstowe housing market sub area Site Parish Address Size Constraints ref (ha) 3022a Trimley St Land to the rear of Mill 3.0  Allotments to NE Martin Lane  Sites and monuments in site to NW

Site discounted Resubmission and enlargement of SHLAA 2014 site 383a. Site 383a was identified as suitable in SHLAA 2014 however concern exists as to the suitability of Mill Close as an access route through an existing housing estate. Highways Authority was not in favour of direct access from High Road.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 76 3022b Felixstowe housing market sub area Site Parish Address Size Constraints ref (ha) 3022b Trimley St Land to the west of 1.66  Sites and monuments in site to Martin High Road NW, SW and

Site discounted Resubmission of discounted SHLAA 2014 site 383. The site was discounted as being poorly related to existing settlement. Although the original site has been reduced from 2.35 ha to 1.66 ha the issue of relative remoteness remains.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 77 3022c Felixstowe housing market sub area Site ref Parish Address Size (ha) Constraints 3022c Trimley St Mary Land at Thurmans Lane 3.54  Listed buildings to west  TPOs to west  Badgers recorded 35m west

Site discounted Resubmission of discounted SHLAA 2014 site 383c. The site was originally discounted due to Highways advice: Thurman’s Lane not suitable to serve further development. To prevent potential coalescence between Trimley St. Mary and Trimley St. Martin, and to protect the setting of nearby listed buildings, the preferred option for this site is for it to be designated as an Area to be Protected from Development.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 78 3022d Felixstowe housing market sub area Site ref Parish Address Size (ha) Constraints 3022d Trimley St Mary Land at Thurmans Lane 1.24  Listed buildings to SW  Sites and monuments to SW

Site discounted Resubmission of discounted SHLAA 2014 site 383d. The site was originally discounted due to Highways advice: Thurman’s Lane not suitable to serve further development. To prevent potential coalescence between Trimley St. Mary and Trimley St. Martin, and to protect the setting of nearby listed buildings, the preferred option for this site is for it to be designated as an Area to be Protected from Development.

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 79 Key to site maps

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 80

Planning Policy and Delivery Team Suffolk Coastal District Council Council Offices Melton Hill Woodbridge Suffolk IP12 1AU

Tel: 01394 444761 / 01394 444558 E-mail: [email protected]