East of Ipswich Plan Area Housing Market Area Maps

O - 5608 - 2446 - Grundisburgh - None 5608 Object East of Ipswich Plan Area Housing Market Area Grundisburgh

Respondent: Grundisburgh & Culpho Parish Council (Mr John Agent: N/A Ager) [2446]

Full Text: Grundisburgh and Culpho Parish Council response to Site Allocation and Area Specific Policies Development Plan Document.

On 15th Sept 2014 Parish Councillor Ann Willetts and District Councillor Anthony Fryatt met with two planning officers to discuss the Site Allocation and Area Specific Policies Development Plan Document as it affects Grundisburgh. They seemed to agree that as the housing allocation for Grundisburgh in the Local Plan 2010-2027 is NIL and total completions since 2010 is 21 with 24 outstanding then it would seem reasonable to retain the existing Physical Limits boundary. The Parish Council were surprised and disappointed that in the document received from District Council for consultation it is still suggested that the village Physical Limits be extended. Grundisburgh and Culpho Parish Council objects to the proposed Physical Limits changes for the following reasons. In Table 2 Indicative Housing Provision Eastern Ipswich Housing Market Sub-Area 2010-2027 (please see attached document)

Grundisburgh has a nil housing allocation 2010 - 2027. 21 properties have already been built or have been granted planning permission since 2010 with another 24 awaiting a legal agreement S106. This suggests that Grundisburgh has already exceeded the number of new properties/people that can be assimilated into the village. The Parish Council therefore, considers it unreasonable to extend the existing physical limits boundary of the village.

The area known as Ablitts Meadow was built as an exception site so it is understandable that that should be included but not the extended garden areas along Stoney Road. 2 sites listed in the SHLAA table, 514, 22-24 Stoney Road have a status 'not suitable' as Anglian Water advise of the waste water treatment works capacity, and highways advise of insufficient width of access and 515, 26 Stoney Road has always been considered unsuitable by the Parish Council because of access. An opinion upheld by an inspector at a previous Local Plan appeal.

The strip of land fronting Ipswich Road and Park Road adjacent to the playing field has been included in the proposed physical limits boundary. This would consolidate the ribbon development along this narrow road. It is the open aspect and number of trees in this area that makes such gentle buffer between the countryside and the built up area of the village.

As planning applications received within the Physical Limits carry a presumption in favour of approval and as Grundisburgh has already exceeded the allocation contained in these documents Grundisburgh Parish Council considers it unreasonable to extend the physical limits other than to include Ablitts Meadow. Summary: The Parish Council were surprised and disappointed that in the document received from District Council for consultation it is still suggested that the village Physical Limits be extended. Grundisburgh has a nil housing allocation 2010 - 2027. 21 properties have already been built or have been granted planning permission since 2010 with another 24 awaiting a legal agreement S106. This suggests that Grundisburgh has already exceeded the number of new properties/people that can be assimilated into the village. The Parish Council therefore, considers it unreasonable to extend the existing physical limits boundary of the village.

Change to Plan

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Attachments: Site specific SCDC.docx

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

S - 5987 - 2762 - Kesgrave - None 5987 Support East of Ipswich Plan Area Housing Market Area Kesgrave

Respondent: Mr Neil Ward [2762] Agent: N/A

Full Text: INTRODUCTION Ipswich Speedway Ltd is freehold owner of 46 ha of land, shown edged black on the attached plan, situated between the built-up areas of Kesgrave and Rushmere St Andrew to the north, Bixley Farm to the west, Bell Lane to the east and Foxhall Road to the south. The site is occupied by Foxhall Stadium, a venue for motor sports and other events, which is operated by Speedworth International Ltd under Planning Permission P/E711 granted on 27th June 1949. Activities at the stadium have been controlled by an Operating Formula which is an informal agreement between the site operators and Suffolk Coastal District Council which has been in place for many years.

Under the 2001 Local Plan First Alteration the southern and western parts of the site are designated as a Special Landscape Area under Policy AP13; the whole of the site is indicated as woodlands under Policy AP225 and the stadium itself is subject to a restrictive policy, Policy AP226 which seeks to preclude any disturbance of the adjacent residential areas of Kesgrave and Bixley Farm.

Under the SHLAA process (site ref. 1010) the development of part of the site for housing purposes was rejected on the basis that the location was contrary to the adopted Core Strategy Settlement Hierarchy although that conclusion was based on the mistaken belief that the site lies within Foxhall Parish rather than Kesgrave Parish which has Major Centre status.

These representations are submitted on the premise that the site represents a major strategic development opportunity relating to brownfield land which, in accordance with the principles set out in the Core Strategy and national guidance, should be given priority.

STATUS Foxhall Stadium was originally constructed under the terms of Planning Permission P/E711 and has operated on the basis of that planning permission over the last 65 years. The application site for the approved development was the whole of the land owned by Ipswich Speedway Ltd i.e. 46 ha with no controlling conditions limiting the extent or nature of primary or ancillary activities on the land. Moreover, the approved plans simply indicate that the surrounding area would be utilised for car parking. Consequently, the whole site should be regarded as the curtilage of the Stadium and as such falls within the definition of previously developed (brownfield) land as defined in the National Planning Policy Framework.

It is one of the primary objectives of the NPPF (paragraph 17) that priority should be given to the development of previously developed land and this is reflected in Policy SP1 of the Core Strategy.

LOCATION The site adjoins the built-up areas of Kesgrave and Rushmere St Andrew on its northern and western boundaries and lies within Kesgrave Parish. Both Kesgrave and Rushmere are identified as being part of the Eastern Ipswich Plan Area which, for the purposes of the Core Strategy Settlements Policy under Policy SP19, constitutes a Major Centre appropriate for large scale housing allocations. Development of the site or part of it for housing purposes therefore complies with the locational requirements of the settlement policy under the Core Strategy.

NEED The Consultation Document identifies a residual need for only 65 housing sites within the Kesgrave area having regard to the requirements of the Core Strategy and current commitments. However, the Core Strategy acknowledges that at the time of its inception it was unable to influence the distribution of housing supply but that there would be an opportunity for reviewing the provisions of the Core Strategy in a review to be undertaken in 2015. That review would enable the Council to take account of:- (i) the serious shortfall in the provision of a five year housing supply for the District and the need to address the problems caused by the delay in bringing forward the Adastral Park development; (ii) the desirability of diversifying the provision housing and in providing choice in the eastern Ipswich housing market; (iii) the desirability of pursuing large-scale housing allocations at Felixstowe and the Trimleys when better locations involving brownfield land exist in closer proximity to the major area of housing demand which is Ipswich; (iv) the wider needs of the Ipswich Policy Area over the Plan period; (v) the benefits of large scale housing development at Foxhall Stadium Development of the site would make a positive contribution to addressing these issues.

STADIUM OPERATION The Council has proceeded over a number of years to regard the Stadium as a facility which can be restricted so as to minimize activity, particularly activity associated with motor sports, so as to avoid adverse environmental impacts on the nearby residential areas. This is reflected in Local Plan Policy AP226 and the promotion of the Operating Formula as a means of control. That approach, however, is flawed and is based on a misinterpretation of the current planning permission. Proper scrutiny of the planning permission indicates that it has little or no effective control over the nature and extent of activities which have been authorised to take place which, perhaps, is unsurprising given its antiquity.

There is no basis in planning or environmental law for imposing the dragonian restrictions on the use of the Stadium which are set out in the current Operating Formula. Consequently, it has to be concluded that the operation of the Stadium has been unreasonably curtailed over the years and given that the Stadium is a commercial concern with the

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benefit of a planning permission it would be unreasonable to seek to maintain such control in the future, notwithstanding the environmental implications. In those circumstances it should be recognized that there is a considerable environmental gain to be achieved by the replacement of the Stadium by a housing development scheme.

It is recognised that notwithstanding the adverse environmental impacts of the Stadium it does provide a well-supported sporting venue for many people so that if the site were to be developed it would be appropriate to consider relocation to a more appropriate alternative site.

DEVELOPMENT CONSTRAINTS Notwithstanding the above, it is recognized that there are a number of environmental and practical constraints on the development proposed. These relate to the various habitats within the site, current landscape quality, existing tree cover including part of the area covered by a Tree Preservation Order, and various footpaths. With the exception of the Tree Preservation Order, none of these constraints involve statutory designations and it is considered that none of the constraints should be regarded as necessarily significant or overriding in the balance of considerations. This would need to be confirmed, of course, by detailed survey and assessment.

Although the SHLAA bid was for an area of 4.5ha, it is considered that a minimum area of some 11ha could be developed without breaching any of the habitat constraints which apply to the site (subject to survey) and although this would need to involve re-alignment of certain footpaths this is not considered to be a constraint which would preclude development. A larger area of up to some 33ha (edged pink on the attached plan) could be developed albeit with the loss of some trees but not ones protected by the current Tree Preservation Order. Many of these trees could be removed lawfully, in any event, in order to facilitate the development originally approved. There are currently no public rights of access to any part of the site other than on the designated footpaths.

BENEFITS OF THE DEVELOPMENT Development of the site for housing would achieve the following benefits:- (i) Give real effect to the stated priority objective of developing brownfield land; (ii) Provide strategic scale development in one of the most sustainable locations in the District in accord with adopted settlement policy; (iii) Provide flexibility of housing location in the East of Ipswich Plan Area so as to increase housing supply where it's needed; (iv) Provide choice of housing location to better meet consumer demand; (v) Provide housing in a location which, by virtue of its perimeter woodland screen, which would be retained, would have no visual or landscape impact on the wider surrounding area; (vi) Remove an existing environmental nuisance in the form of the Stadium and permitted use of the site which otherwise would have the potential to significantly increase activities in the future; (vii) Provide a large scale public open space facility of Country Park scale with funding to positively manage its long term future within the residual undeveloped areas of the site.

CONCLUSIONS Development of the Stadium site would constitute the most significant Brownfield contribution to housing supply in the District and would provide a major strategic housing site in accord with the settlement hierarchy and in one of the most sustainable locations in the District.

Provision of housing of the scale proposed could be addressed in the proposed review of the Core Strategy and could help resolve problems of housing supply in other areas of the District as well as in the Eastern Ipswich Plan Area and the Ipswich Policy Area.

Development would also present the opportunity to remove a long-standing environmental blight whilst at the same time bringing into public control a significant rural public open space facility on the edge of the built-up area.

Development of the site would inevitably involve some loss of habitat and trees and would affect the local landscape but the effect on the wider landscape would be negligible. The balance of considerations outlined above strongly suggest that the very substantial and demonstrable benefits which would accrue would outweigh the adverse impacts which would arise. Summary: Development of the Stadium site would constitute the most significant Brownfield contribution to housing supply in the District and would provide a major strategic housing site in accord with the settlement hierarchy and in one of the most sustainable locations in the District. Development would also present the opportunity to remove a long-standing environmental blight whilst at the same time bringing into public control a significant rural public open space facility on the edge of the built-up area.

Change to Plan N/A

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Attachments:

S - 5987 - 2762 - Kesgrave - None 5987 Support East of Ipswich Plan Area Housing Market Area Kesgrave

P1748-site plan.pdf

C - 6126 - 2605 - Kesgrave - None 6126 Comment East of Ipswich Plan Area Housing Market Area Kesgrave

Respondent: Suffolk Wildlife Trust (Mr James Meyer) [2605] Agent: N/A

Full Text: RE: Suffolk Coastal DC Site Allocations and Area Specific Policies Local Plan Document Issues and Options Consultation

Thank you for consulting us on the above document. We have the following comments on the sites identified for allocation (or otherwise) presented in the map booklets. These comments are based on a desktop assessment of the sites in relation to the presence of areas designated for their nature conservation value, we have not screened these sites for the potential presence of protected species or the potential presence of Priority species or habitats. It is possible that sites included for allocation could support protected species and/or Priority species or habitats and we recommend that this is investigated in detail as the development plan process progresses.

East of Ipswich Area * Kesgrave Site 699 is within the Kesgrave Wood and Sinks Valley County Wildlife Site (CWS), we support the non- allocation of this site and recommend that the CWS is included as a reason for exclusion.

Framlingham Area * Badingham Site 686 is within the Badingham Meadow County Wildlife Site (CWS), we support the non-allocation of this site and recommend that the CWS is included as a reason for exclusion.

Saxmundham Area * Aldeburgh Site 768 includes the Crag Pit, Aldeburgh Site of Special Scientific Interest (SSSI), this is a geological SSSI and we recommend that further advice is sought from appropriate consultees as to whether allocation of this site could result in an adverse impact on the SSSI. * Aldeburgh Site 982 includes the Aldeburgh Brick Pit Site of Special Scientific Interest (SSSI), this is a geological SSSI and we recommend that further advice is sought from appropriate consultees as to whether allocation of this site could result in an adverse impact on the SSSI. * Middleton Site 911 is within the Minsmere Valley; Reckford Bridge to Beveriche Manor County Wildlife Site (CWS), we support the non-allocation of this site and recommend that the CWS is included as a reason for exclusion.

If you require any further information or wish to discuss any of the points raised above please do not hesitate to contact us. Summary: Kesgrave Site 699 is within the Kesgrave Wood and Sinks Valley County Wildlife Site (CWS), we support the non- allocation of this site and recommend that the CWS is included as a reason for exclusion.

Change to Plan

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Attachments:

S - 6325 - 2719 - Kesgrave - None 6325 Support East of Ipswich Plan Area Housing Market Area Kesgrave

Respondent: Persimmon Homes (Anglia) Ltd [2719] Agent: Savills (Claire Frost) [3351]

Full Text: SUFFOLK COASTAL SITE ALLOCATIONS AND AREA SPECIFIC POLICIES ISSUES & OPTIONS CONSULTATION

On behalf of our client, Persimmon Homes, Savills (UK) Limited is instructed to submit representations in relation to the Suffolk Coastal Site Allocations and Area Specific Policies (the Site Allocations Document) Issues and Options consultation.

Summary The Issues and Options Report (Table 1) suggests that the Core Strategy minimum target of 2,000 dwellings for the Eastern Ipswich Plan Area is primarily accounted for through the proposed strategic housing site identified through the Core Strategy on land adjacent to Adastral Park. However, we consider that that development will not contribute to housing supply at the delivery rates previously anticipated. As such, we are of the view that the Site Allocations Document should allocate further land for housing development elsewhere in the Eastern Ipswich Plan Area. It should be noted that the planning application for the development of land adjacent to Adastral Park, pursuant to the strategic site identified through the Core Strategy, is yet to be determined (application reference C/09/0555). Furthermore, and following our own assessment, we consider that the first dwellings at that site will not now be completed until the first part of 2019 at the earliest. This compares to the start on site of 2014 that was shown in the evidence to the Core Strategy of that scheme's promoter. Our reasoning for our own assessment of a 2019 start on site is set out in further detail below.

Assessment of housing requirements Firstly, and by way of context, it is relevant to note the comments of the Inspector in relation to the Core Strategy. In order for Adastral Park to provide the level of housing proposed within the plan period, he remarked that 'it would require a consistently high rate of development and for all matters relating to the phasing with the mineral working to occur as planned' (paragraph 97 of the Inspector's Report, dated 6 June 2013). However, as noted above, the previously anticipated rates of delivery at Adastral Park have been significantly delayed when compared against the anticipated phasing arrangements set out at the Examination and adoption of the Core Strategy. The phasing arrangements submitted on behalf of the promoter suggested that Phase 1 (200 homes) would be complete by 2016 and Phase 2A (500 homes) between 2014 and 2020. Since the outline planning application for development at Adastral Park has not yet been determined and reserved matters / conditions will subsequently require approval, it is evident that the intended rates of housing delivery will not achievable. On the assumption that the current application does not need any updating, a resolution to grant might be obtained by mid 2015, and allowing six months for completion of a Section 106 Agreement, a decision might be issued around the end of 2015. If one allows 12 months for the submission and determination of the necessary reserved matters and conditions to be discharged, 12 months for the development of the initial infrastructure and a further 12 months to build the first homes, these would not be ready for occupation until early 2019 at the very earliest. We consider this to be very much a best case scenario, and the speed at which development will come forward may also be further delayed by events such as Legal Challenge and/or the rate of mineral extraction at the site. For instance, this best case scenario assumes that a conflict with mineral policy will be accepted, as extraction from EX1 has not taken place and would consequently need to be sterilised for these timescales to be met. Furthermore, it assumes that extraction at most of EX2 (excluding the Grainger land) is completed by the end of 2015 and reclamation is completed promptly, so as to not impact on infrastructure development commencing on site. However, since the extraction has not taken place on the northernmost section of Phase 2A (within mineral phase EX2), it is evident that this sub-phase cannot come forward in its entirety until this is undertaken, which is likely to result in further delays. In addition to the above, there is no public evidence to suggest that a development partner has been selected to date for Adastral Park, which is a time consuming exercise and will influence the speed at which any Reserved Matters applications and requests to discharge conditions could be submitted. If a master developer is selected, there may then also be a need to select house builders to deliver new homes. The Inspector's Report following the Core Strategy Examination recognised this and stated that 'In subsequent DPDs and in the review of the plan, the Council would need to take a realistic view of the likely rate of development at Martlesham and identify other sites as appropriate in the light of further assessments' (paragraph 97 of the Inspector's Report, 6 June 2013). Given the above delays in bringing development forward, and in view of the Inspector's comments, we consider it is appropriate to re-evaluate the arising shortfall in delivery, and to consider how this unmet need will be delivered. The housing trajectory of the Adastral scheme promoter at the time of the Core Strategy Examination assumed the following delivery rates at the site, in advance of the early 2019 start on site that we now anticipate: 2014/2015: 112 dwellings 2015/2016: 112 dwellings 2016/2017: 113 dwellings 2017/2018: 113 dwellings 2018/2019: 170 dwellings (we estimate that 50 of these dwellings would come forward following a start on site in early 2019). The above shows that by early 2019, the housing trajectory assumed that 500 dwellings would have been delivered at Adastral Park. In reality none of these properties have been delivered or will be delivered by the start of 2019, for the reasons set out above. At this point, it is relevant to acknowledge the Inspector's recommendation that it is therefore crucial that the Council take a 'realistic view of the likely rate of development at Martlesham and identify other sites as appropriate in the light of further assessments'. Since the delivery of the first dwellings at Adastral Park have therefore been delayed by at least 4 years, this would

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require rates of completion to be even higher than the already high rate of delivery assumed through the adoption of the Core Strategy that would need to be achieved in order for the delivery of 2,000 dwellings at Adastral in the Core Strategy plan period. To rectify the shortfall at the start of the plan period, this would now require significant frontloading of delivery, which would not be achievable given that the Core Strategy assumptions were based on rates of mineral extraction and the ability of the market and house builders to deliver. It is proposed that the Site Allocations Document should allow for the changes in circumstance and allocate additional sites in the Eastern Ipswich Plan Area to make up for the shortfall that has arisen. Indeed, the rates of housing delivery that would be required at Adastral Park have already been observed by the Core Strategy to be high. As such, and as opposed to increasing delivery rates at Adastral Park further to an unattainable level, the Council must consider the allocation of additional sites within the Site Allocations Document.

Land to the East of Bell Lane, Kesgrave In view of the above, and on behalf of our client, we propose the allocation of land to the east of Bell Lane, Kesgrave for housing development, in order to ensure for the delivery of housing levels as set out within the adopted Core Strategy. The site is 15ha in area and of a sufficient size to accommodate 300 dwellings, which would address part of the shortfall identified above. The site is located directly to the south of the existing settlement boundary of Kesgrave and acts as a natural extension to the built up area. The site is approximately centred on Grid Reference E:622433 N:244570. A public right of way (PROW) is located on the northern boundary, separating the site from the residential development (some of which has been recently constructed), woodland and primary school to the north. This PROW is known as 'Sandlings Walk' and is a long distance route. Established trees and planting are located along this PROW and the track is circa.13 metres wide. A public car park is located directly to the east of Bell Lane, adjoining the north western corner of the site and provides access to Sandlings Walk. The site is within a sustainable location, directly bounding the existing built-up edge of Kesgrave and its associated services, including two primary schools, secondary school, community centre, library and a small scale food store. The nearest bus stop to the site is currently 420 metres to the north on Bell Lane. This is approximately a 10 minute walk from the site, although it is anticipated that a new bus stop would be provided closer to the site, should the development come forward. Agricultural land is primarily located to the east and south of the site. There is also the former communications centre to the south and Foxhall Court to the east. This property is surrounded by established vegetation and is not Listed. To the west of the site, on the western side of Bell Lane, is the Foxhall Stadium Wood County Wildlife Site (CWS). This local designation is separated from the site by Bell Lane, a notable transport route into and out of Kesgrave and so providing a distinct separation between the site in question and this local ecological designation. In addition to this, there is a marked difference between the habitats associated with the County Wildlife Site and the site. This limits the likelihood of species and beneficial characteristics of the ecological designation from encroaching or being associated with the site proposed for allocation. Ecological assessments forming part of any future planning application will assess this relationship in detail. No other ecological designations are located in close proximity of the site. The Mill Stream Local Nature Reserve is 0.85km to the west, whilst the Ipswich Heaths SSSI (unfavourable recovering) is approximately 1.3km to the east. Any potential relationships with such designations can be addressed as part of any future planning application by an appointed ecologist. The potential implications of additional residential development on European Designations within proximity of the site (SPAs, SACs and Ramsar sites at the Deben Estuary and the Stour and Orwell Estuary) has been assessed through the adoption of the Core Strategy. This has assessed the potential implications of the level of housing identified within the Eastern Ipswich Plan Area and has been found sound on this basis. Furthermore, both the High Court and Court of Appeal has now ruled that the Council met their legal obligations in adopting the Core Strategy and associated housing figures, including the intended 2,000 homes at Adastral Park. These decisions took into account requirements under the Habitats Directive. Since the delay in bringing forward development at Adastral Park has meant that the full 2,000 homes cannot be achieved at that site in the plan period, it is deemed appropriate and within the parameters of the Core Strategy to re-allocate this residual provision on an alternative site within the Eastern Ipswich Plan Area. The specific details and potential implications on designated sites can then be assessed at the time of a planning application, in accordance with relevant European and national legislation, including the Habitats Directive. Initial ecological surveys have been completed for the site itself and these have not identified any species on site that could preclude residential development coming forward. The surveys set out where appropriate mitigation, precautionary measures and enhancements can be included and any future scheme will incorporate such points into the design. In terms of the capacity of the surrounding landscape to accommodate residential development at the site, an initial landscape and visual appraisal has been undertaken. This identities views to and from the site as being relatively well contained. For instance, the assessment states 'views from the site extend across south, along the gently sloping ground to Foxhall Road, Brookhill Wood limits views further south. To the east, characteristic woodland also limits views beyond Bell Lane. To the north, a mature native hedgerow limits views to new residential development. Middle to long distance views are glimpsed or tunnelled to the wider landscape, however, these are largely limited due to the wooded nature of this landscape'. The assessment also identifies that the character of the landscape when approaching the site from Bell Lane is urban and built up and that there is consequently an opportunity to enhance this transition from agricultural land to urban through appropriate boundary treatment. Such design principles can be incorporated into any future planning application. This initial landscape work indicates the suitability of the site to accommodate residential development and further strengthens the suitability of the site to be brought forward for development under a formal allocation. It is intended that the site would be accessed off Bell Lane, a route which passes through Kesgrave and connects the

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A1214 to the north and Foxhall Road to the south. Any future planning application would be accompanied by a Transport Assessment and detailed access arrangements. It is currently expected that the new access would involve either a small roundabout at the junction itself or a designated turn in lane. Persimmon have a suitable agreement in place on all land along this road frontage to ensure that a safe and appropriate junction arrangement can be achieved, whilst not encroaching or adversely affecting the County Wildlife Site to the west. An initial assessment of designated heritage assets in proximity of the site has been undertaken. This has found limited designated assets in proximity. For instance, Scheduled Ancient Monuments exist to the east (Pole Hill bowl barrow and the two bowl barrows to the SW of Dobbs Corner). However, these assets are approximately 1.1km from the site and a sufficient distance to avoid adverse impacts to their views, context and setting. Any listed buildings within Kesgrave are set well within the built up area and consequently, we consider there is no potential for adverse impact upon their settings. An initial geophysical survey has been undertaken at the site to ascertain the potential for below ground heritage assets. This has found limited potential for archaeological remains. Two linear anomalies were identified in the south east of the site that would normally be interpreted as field drains. There was also a record of some relatively modern ferrous debris, which could be of WWII origin, or agricultural. The relevant evidence will form part of any future planning application, but the work undertaken to date confirms that no specific constraints that would render the site undeliverable. Finally, it can also be confirmed that the site falls within flood zone 1, is at limited risk of contamination due to its historic agricultural use and is identified as Grade 4 (poor quality) under the Agricultural Land Classification, which falls outside of the definition of best and most versatile agricultural land as set out in the National Planning Policy Framework. The above summary of potential site characteristics establishes the suitability of the site for housing development. Consequently, the site can make a beneficial contribution to the delivery of housing development to meet the housing needs of the District, as set out in the Core Strategy. As we explain above, we consider that the development of 2,000 homes at Adastral Park cannot be achieved in the plan period. The completion rates that would need to be realised as a result of the delay in bringing the Adastral Park scheme forward would not be achievable and so the allocation of land to the East of Bell Lane, Kesgrave, will in part ensure that the required levels of housing development can be achieved in the plan period. Summary: Land to the East of Bell Lane, Kesgrave:The site can make a beneficial contribution to the delivery of housing development to meet the housing needs of the District. The development of 2,000 homes at Adastral Park cannot be achieved in the plan period. The completion rates that would need to be realised as a result of the delay in bringing the Adastral Park scheme forward would not be achievable and so the allocation of land to the East of Bell Lane, Kesgrave, will in part ensure that the required levels of housing development can be achieved in the plan period.

Change to Plan N/A

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Attachments: Promap - Land East of Bell Lane Kesgrave.pdf

C - 6526 - 2581 - Kesgrave - None 6526 Comment East of Ipswich Plan Area Housing Market Area Kesgrave

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

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

1. Introduction

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

2. Air Quality and Noise Assessment

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

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

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

3. Archaeology

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

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

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

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

4. Education (including Early Years)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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growth.

5. Health and Wellbeing

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

6. Libraries

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

7. Minerals and Waste Plans

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

8. Natural Environment

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

9. Public Rights of Way

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

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

10. Surface Water Management

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

11. Transport

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

12. Waste Provision

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

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

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

13. Water Management, Flood and Coastal Defences

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

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

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

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

Appendix: Likely Archaeological Assessment Requirements

East Ipswich Plan Area

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

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

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

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

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

Framlingham

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

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

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

Saxmundham

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

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

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work.

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

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

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

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

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

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

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

Woodbridge

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

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

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

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

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

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

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

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

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

Woodbridge 900a - This site lies within an area of archaeological potential, and Neolithic pits and Iron Age features were excavated to the south (County Historic Environment Record MRM 030). The site should be subject to archaeological assessment at an appropriate stage in the design of new development to establish the impacts of past land-use, and ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Summary: 2.2 Developments adjacent to the A1214 through Kesgrave, eg. 774a and also the A1156 Felixstowe Road would all be subject to traffic noise as these routes carry significant volumes of traffic. Also locations at Ufford adjacent to the A12 to include 586, 838a and 838b and at Woodbridge for plots 937, 900a and 703. There a number of IAs along the A12 at Martlesham Heath and Woodbridge and should additional residential receptors be built adjacent to the route, these would be extended, potentially requiring this authority to fund mitigation provision.

Change to Plan

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

Attachments:

O - 5470 - 3093 - Martlesham & Martlesham Heath - None 5470 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr & Mrs J & J Burges [3093] Agent: N/A

Full Text: We received a letter from East Coast Planning Services informing us they were submitting a Planning Application on behalf of a client for 'Land immediately East of Collies, Three Stiles Lane, Martlesham.' This land falls outside the "Martlesham [Village]-Physical Limits on the S.C.D.C. Planning Web-site. It also states Ref.591 [includes 891) Land at and surrounding Collies,Three Stiles Lane. Capacity or Justification - Poor access; private road; capacity; impact on character of the area- SHLAA Status Not Suitable. We agree this land is not suitable for development and oppose any planning approval being granted .

Three Stiles Lane is privately owned land with a bridleway connecting Waldringfield Road and the A1214. The four properties located on Three Stiles Lane have legal right of access out onto this bridleway. The "land immediately east of Collies" does not have a legal right of access out onto the privately owned land with bridleway. The plot of land west of Collies recently granted Outline Planning Permission similarly has no legal right of access out onto the privately owned land with bridleway. This is evident in the letter from East Coast Planning which states 'it is unclear as to who all the owners of Three Stiles Lane are'. Does this mean these two plots are land-locked?

We understand an ecological report submitted identified a population of common lizard and grass snakes on the site. The Wildlife and Countryside Act of 1981states a condition should be placed on the Outline Planning application. The plot West of Collies was cleared in breach of this legislation. Some site clearance has taken place on the "Land immediately East of Collies". Summary: We received a letter from East Coast Planning Services informing us they were submitting a Planning Application on behalf of a client for 'Land immediately East of Collies, Three Stiles Lane, Martlesham.' This land falls outside the "Martlesham [Village]-Physical Limits on the S.C.D.C. Planning Web-site. It also states Ref.591 [includes 891) Land at and surrounding Collies,Three Stiles Lane. Capacity or Justification - Poor access; private road; capacity; impact on character of the area- SHLAA Status Not Suitable. We agree this land is not suitable for development and oppose any planning approval being granted.

Change to Plan

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

Attachments:

S - 5540 - 3131 - Martlesham & Martlesham Heath - None 5540 Support East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr Malcolm Morley [3131] Agent: N/A

Full Text: In response to the consultation on the Local Plan Issues and Options I would comment as follows:

Policy AP214 regarding the land at Ipswich Road/Sandy Lane Martlesham - I support the Council's view that this area, sitting between a Special Landscape Area and the AONB on the edge of the defined built up area of Woodbridge, should remain protected from development.

Policy SP20 - Adastral Park - I support the proposed development to the south and east of Adastral Park. I believe that it delivers a critical mass of development as part of a sustainable community with the necessary supporting transport infrastructure that will: * Upgrade existing employment floorspace and support the creation of up to 60,000 square metres of new employment floorspace; * Create approximately 2000 new jobs; * Create a residential community of up to 2000 new homes; * Deliver comprehensive new infrastructure and services to serve the new residential community, including new education and healthcare provision, public transport, shops, leisure and sports facilities and public spaces; * Provide a hotel to cater for business, visitors and tourists; * Provide an on-site energy centre to provide renewable heat and power reducing dependency on the national grid; * Utilise and improve the existing transport infrastructure including improved A12 access; and * Achieve an expansion of University presence at Adastral Park. Summary: Site 453 - Martlesham: Land at and surrounding Bridge Farm, Top Street - I support the Council's view that this land should be protected from development to prevent coalescence of Woodbridge and Martlesham and to recognise that it does not have the transport infrastructure to support it as part of a sustainable community. Any such development would be prejudicial to both Woodbridge and Martlesham and would have a significant impact on the environmental sustainability of both a Special Landscape Area and an Area of Outstanding Natural Beauty.

Change to Plan N/A

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

Attachments:

S - 5544 - 3133 - Martlesham & Martlesham Heath - None 5544 Support East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr Steve Liddell [3133] Agent: N/A

Full Text: I wish to comment on the Local Plan consultation document as follows? Policy AP214 regarding the land at Ipswich Road/Sandy Lane Martlesham - I support the Council's view that this area, sitting between a Special Landscape Area and the AONB on the edge of the defined built up area of Woodbridge, should remain protected from development. Site 453 - Martlesham: Land at and surrounding Bridge Farm, Top Street - I support the Council's view that this land should be protected from development to prevent coalescence of Woodbridge and Martlesham and to recognise that it does not have the transport infrastructure to support it as part of a sustainable community. Any such development would be prejudicial to both Woodbridge and Martlesham and would have a significant impact on the environmental sustainability of both a Special Landscape Area and an Area of Outstanding Natural Beauty. Policy SP20 - Adastral Park - I support the proposed development to the south and east of Adastral Park. I believe that it delivers a critical mass of development as part of a sustainable community and is, by far, the most appropriate way to meet housing and employment space requirements in the Woodbridge/ Kesgrave/ Martlesham area. I would be grateful if you would acknowledge receipt of my response to the consultation and ensure that I receive updates on the progress with the Local Plan and the consideration of the above. Summary: Site 453 - Martlesham: Land at and surrounding Bridge Farm, Top Street - I support the Council's view that this land should be protected from development to prevent coalescence of Woodbridge and Martlesham and to recognise that it does not have the transport infrastructure to support it as part of a sustainable community. Any such development would be prejudicial to both Woodbridge and Martlesham and would have a significant impact on the environmental sustainability of both a Special Landscape Area and an Area of Outstanding Natural Beauty.

Change to Plan N/A

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

Attachments:

S - 5545 - 3134 - Martlesham & Martlesham Heath - None 5545 Support East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mrs Paula Morley [3134] Agent: N/A

Full Text: In response to the consultation on the Local Plan Issues and Options I would comment as follows:

* Create approximately 2000 new jobs;

* Create a residential community of up to 2000 new homes;

* Deliver comprehensive new infrastructure and services to serve the new residential community, including new education and healthcare provision, public transport, shops, leisure and sports facilities and public spaces;

* Provide a hotel to cater for business, visitors and tourists;

* Provide an on-site energy centre to provide renewable heat and power reducing dependency on the national grid;

* Utilise and improve the existing transport infrastructure including improved A12 access; and

* Achieve an expansion of University presence at Adastral Park.

I would be grateful if you would acknowledge receipt of my response to the consultation and ensure that I receive updates on the progress with the Local Plan and the consideration of the above. Summary: Site 453 - Martlesham: Land at and surrounding Bridge Farm, Top Street - I support the Council's view that this land should be protected from development to prevent coalescence of Woodbridge and Martlesham and to recognise that it does not have the transport infrastructure to support it as part of a sustainable community. Any such development would be prejudicial to both Woodbridge and Martlesham and would have a significant impact on the environmental sustainability of both a Special Landscape Area and an Area of Outstanding Natural Beauty.

Change to Plan N/A

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

Attachments:

S - 5551 - 3136 - Martlesham & Martlesham Heath - None 5551 Support East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Ifftner Solutions (Mr Jim Marshall) [3136] Agent: N/A

Full Text: In response to the consultation on the Local Plan Issues and Options I would comment as follows:

Policy SP20 - Adastral Park - I support the proposed development to the south and east of Adastral Park. I believe that it delivers a critical mass of development as part of a sustainable community with the necessary supporting transport infrastructure that will: * Upgrade existing employment floorspace and support the creation of up to 60,000 square metres of new employment floorspace; * Create approximately 2000 new jobs; * Create a residential community of up to 2000 new homes; * Deliver comprehensive new infrastructure and services to serve the new residential community, including new education and healthcare provision, public transport, shops, leisure and sports facilities and public spaces; * Provide a hotel to cater for business, visitors and tourists; * Provide an on-site energy centre to provide renewable heat and power reducing dependency on the national grid; * Utilise and improve the existing transport infrastructure including improved A12 access; and * Achieve an expansion of University presence at Adastral Park. I would be grateful if you would acknowledge receipt of my response to the consultation and ensure that I receive updates on the progress with the Local Plan and the consideration of the above. Summary: Site 453 - Martlesham: Land at and surrounding Bridge Farm, Top Street - I support the Council's view that this land should be protected from development to prevent coalescence of Woodbridge and Martlesham and to recognise that it does not have the transport infrastructure to support it as part of a sustainable community. Any such development would be prejudicial to both Woodbridge and Martlesham and would have a significant impact on the environmental sustainability of both a Special Landscape Area and an Area of Outstanding Natural Beauty.

Change to Plan N/A

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

Attachments:

S - 5552 - 3137 - Martlesham & Martlesham Heath - None 5552 Support East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Ifftner Solutions (Mrs Sanchia Marshall) [3137] Agent: N/A

Full Text: In response to the consultation on the Local Plan Issues and Options I would comment as follows:

Policy SP20 - Adastral Park - I support the proposed development to the south and east of Adastral Park. I believe that it delivers a critical mass of development as part of a sustainable community with the necessary supporting transport infrastructure that will: * Upgrade existing employment floorspace and support the creation of up to 60,000 square metres of new employment floorspace; * Create approximately 2000 new jobs; * Create a residential community of up to 2000 new homes; * Deliver comprehensive new infrastructure and services to serve the new residential community, including new education and healthcare provision, public transport, shops, leisure and sports facilities and public spaces; * Provide a hotel to cater for business, visitors and tourists; * Provide an on-site energy centre to provide renewable heat and power reducing dependency on the national grid; * Utilise and improve the existing transport infrastructure including improved A12 access; and * Achieve an expansion of University presence at Adastral Park. I would be grateful if you would acknowledge receipt of my response to the consultation and ensure that I receive updates on the progress with the Local Plan and the consideration of the above. Summary: Site 453 - Martlesham: Land at and surrounding Bridge Farm, Top Street - I support the Council's view that this land should be protected from development to prevent coalescence of Woodbridge and Martlesham and to recognise that it does not have the transport infrastructure to support it as part of a sustainable community. Any such development would be prejudicial to both Woodbridge and Martlesham and would have a significant impact on the environmental sustainability of both a Special Landscape Area and an Area of Outstanding Natural Beauty.

Change to Plan N/A

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

Attachments:

C - 5615 - 3180 - Martlesham & Martlesham Heath - None 5615 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr Richard Whittle [3180] Agent: N/A

Full Text: In response to the consultation on the Local Plan Issues and Options I would comment as follows:

Change to Plan

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Attachments:

O - 5616 - 2121 - Martlesham & Martlesham Heath - None 5616 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: S. P. Harris [2121] Agent: N/A

Full Text: I am particularly concerned with the site shown as "suitable " for development at Bloomfields Farm ( 9 houses) for the following reasons;-

1. Black Tiles Lane gives access to at least 200 dwellings, Public House, P O Stores, Primary School, the Farms and the C C Learning Centre. The Lane is the only vehicular access to all of these users and in the event of an incident at or near to the junction with Main Road it would block any access to the emergency services ( as has occurred when a tree at the P H fell across the Lane and closed the road for several hours.)

2.There is often conjestion at the P O Store and elsewhere at school times.The change of ownership of the Christian Fellowship has resulted a much greater use of the building by the C C on several days of the week when the large car- park is often full to over flowing. Further developmemt would increase the present traffic problems.

3,The proposed development could threaten the mature oak on the boundary

4. Approval to the proposal could prejudice consideration of development of the remainder of the field

For the above reasons I consider that no further development should be permitted from Black Tiles Lane (until a satisfactory second vehicular is provided) and therefore the proposal should be reclassified as "unsuitable". Summary: I am particularly concerned with the site shown as "suitable " for development at Bloomfields Farm. Black Tiles Lane gives access to at least 200 dwellings, Public House, P O Stores, Primary School, the Farms and the C C Learning Centre. The Lane is the only vehicular access to all of these users and in the event of an incident at or near to the junction with Main Road it would block any access to the emergency services ( as has occurred when a tree at the P H fell across the Lane and closed the road for several hours.)

Change to Plan

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Attachments:

O - 5667 - 167 - Martlesham & Martlesham Heath - None 5667 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr David Trouse [167] Agent: N/A

Full Text: These are general comments relating to various paragraphs, diagrams, tables etc in these documents regarding the potential very large scale housing development at Adastral Park. Please allocate my comments to the appropriate part or parts of the consultation documents.

Overall I think that the proposed development of over 2000 homes is out of scale (too large) considering the surroundings. It would overwhelm the existing settlements. Such a development would impose large negative impacts on the surrounding transport infrastructure and environment - notwithstanding stated intentions to mitigate these impacts. The council seems intent on imposing this large scale development as a perceived easy solution to an assumed but unsubstantiated housing demand without adequate consideration of the alternatives eg smaller housing growth overall or more widely distributed growth across the whole SCDC area. The council states that it wants to hear local viewpoints but does not listen or ignores views inconsistent with its own. The council's plans for the Adastral Park development do not appear to justify its "where quality of life counts" strapline in so far as existing residents of the area are concerned. I have commented in detail on individual parts of these policies before in earlier consultations, those comments still stand. I would like the council to reconsider the need for and its support for a very large scale housing development at Adastral Park. Some medium scale development at Adastral Park would be acceptable as part of the district's future housing growth but it should not be anything like as large as is currently envisaged. Summary: I think that the proposed development of over 2000 homes is out of scale considering the surroundings. It would overwhelm the existing settlements. Such a development would impose large negative impacts on the surrounding transport infrastructure and environment. The council seems intent on imposing this large scale development as an easy solution to an assumed housing demand without adequate consideration of the alternatives eg smaller housing growth or more widely distributed growth across the whole SCDC area. Some medium scale development at Adastral Park would be acceptable but it should not be anything like as large as is currently envisaged.

Change to Plan

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Attachments:

S - 5675 - 3220 - Martlesham & Martlesham Heath - None 5675 Support East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr Ray Hardcastle [3220] Agent: N/A

Full Text: In response to the consultation on the Local Plan Issues and Options I would comment as follows:

Policy SP20 - Adastral Park - I support the proposed development to the south and east of Adastral Park. I believe that it delivers a critical mass of development as part of a sustainable community with the necessary supporting transport infrastructure that will: Upgrade existing employment floorspace and support the creation of up to 60,000 square metres of new employment floorspace; Create approximately 2000 new jobs; Create a residential community of up to 2000 new homes; Deliver comprehensive new infrastructure and services to serve the new residential community, including new education and healthcare provision, public transport, shops, leisure and sports facilities and public spaces; Provide a hotel to cater for business, visitors and tourists; Provide an on-site energy centre to provide renewable heat and power reducing dependency on the national grid; Utilise and improve the existing transport infrastructure including improved A12 access; and Achieve an expansion of University presence at Adastral Park. Summary: Site 453 - Martlesham: Land at and surrounding Bridge Farm, Top Street - I support the Council's view that this land should be protected from development to prevent coalescence of Woodbridge and Martlesham and to recognise that it does not have the transport infrastructure to support it as part of a sustainable community. Any such development would be prejudicial to both Woodbridge and Martlesham and would have a significant impact on the environmental sustainability of both a Special Landscape Area and an Area of Outstanding Natural Beauty.

Change to Plan N/A

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Attachments:

S - 5678 - 3222 - Martlesham & Martlesham Heath - None 5678 Support East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mrs Judith Hardcastle [3222] Agent: N/A

Full Text: In response to the consultation on the Local Plan Issues and Options I would comment as follows:

Policy SP20 - Adastral Park - I support the proposed development to the south and east of Adastral Park. I believe that it delivers a critical mass of development as part of a sustainable community with the necessary supporting transport infrastructure that will: Upgrade existing employment floorspace and support the creation of up to 60,000 square metres of new employment floorspace; Create approximately 2000 new jobs; Create a residential community of up to 2000 new homes; Deliver comprehensive new infrastructure and services to serve the new residential community, including new education and healthcare provision, public transport, shops, leisure and sports facilities and public spaces; Provide a hotel to cater for business, visitors and tourists; Provide an on-site energy centre to provide renewable heat and power reducing dependency on the national grid; Utilise and improve the existing transport infrastructure including improved A12 access; and Achieve an expansion of University presence at Adastral Park. Summary: Site 453 - Martlesham: Land at and surrounding Bridge Farm, Top Street - I support the Council's view that this land should be protected from development to prevent coalescence of Woodbridge and Martlesham and to recognise that it does not have the transport infrastructure to support it as part of a sustainable community. Any such development would be prejudicial to both Woodbridge and Martlesham and would have a significant impact on the environmental sustainability of both a Special Landscape Area and an Area of Outstanding Natural Beauty.

Change to Plan N/A

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Attachments:

O - 5721 - 3239 - Martlesham & Martlesham Heath - None 5721 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: John & Debbie Tonkin [3239] Agent: N/A

Full Text: We are writing to you to let you know our views on the proposed development at Woodbridge Town Football Club situated on Seckford Heights.

As residents of Fynn Road we feel strongly that if the development were to go ahead as per the proposed plan, we envisage a minimum of 180 cars per day driving down Fynn Road which is a minor road. These vehicles would then enter Seckford Hall Road, which is also a minor road that has cars parked there 24 hours a day, it is very difficult as it is gaining access to Old Barrack Road or turning right onto the Ipswich Road and with another estimated 180 cars trying to do the same thing it will be hugely frustrating and will cause a bottle neck at the junction of Old Barrack Road and the Ipswich Road. I believe that the Council is concerned about the pollution in and around Woodbridge and this would make it worse. I also know that the Council is trying to stop traffic coming through Woodbridge, again this would be made worse as in the frustration of everyone trying to get out of Seckford Hall Road they would, understandably, turn right onto Old Barrack Road and then divert, either through Woodbridge via Seckford Street or go down Warren Hill Road and back onto Ipswich Road from there. Another route that people will inevitably take at the bottle neck that will occur at the end of Fynn Road is that they will divert down Oxford Road to avoid the junction altogether and enable them to join Old Barrack Road. This situation will impact on air quality and the residents living close by.

We strongly feel that Fynn Road should be made a cul-de-sac and the traffic from the proposed new development should be diverted to the mini roundabout on Ipswich Road, enabling those wanting to join the A12 to do so and therefore diverting traffic away from Woodbridge Town and therefore helping with the air pollution problem, which should be your number one priority!

Altogether this development would be detrimental to all the residents who live on Seckford Heights and those living in the Oxford Road areas. These areas are quiet residential areas and would be ruined by the increase of traffic flow.

We would also question why in 2010 when a similar document to your issues and adoptions document regarded Seckford Heights land unsuitable for development due to it being "visually prominent, potential noise issues and limited highways access opportunities" - what has changed in FIVE YEARS? The issues that were raised then still remain.

We are looking to you, our Council representatives and planning officers, to enforce as strongly as you can our opinions in this matter. Summary: Site 900a: Altogether this development would be detrimental to all the residents who live on Seckford Heights and those living in the Oxford Road areas. These areas are quiet residential areas and would be ruined by the increase of traffic flow. We would also question why in 2010 when a similar document to your issues and adoptions document regarded Seckford Heights land unsuitable for development due to it being "visually prominent, potential noise issues and limited highways access opportunities" - what has changed in FIVE YEARS? The issues that were raised then still remain.

Change to Plan

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Attachments:

O - 5728 - 1890 - Martlesham & Martlesham Heath - None 5728 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr Derek Downer [1890] Agent: N/A

Full Text: I have written before to express my objections to this development. The reasons are so obvious to anyone with only half an eye could see that the site is not suitable for development it has no proper access to the main roads that are already over used. I see from an earlier attempt to develop this site that it was turned down as being "Visually Prominent" has "Potential Noise Issues" and Limited Highway Access opportunities". So what has changed? Summary: I have written before to express my objections to this development. The reasons are so obvious to anyone with only half an eye could see that the site is not suitable for development it has no proper access to the main roads that are already over used. I see from an earlier attempt to develop this site that it was turned down as being "Visually Prominent" has "Potential Noise Issues" and Limited Highway Access opportunities". So what has changed?

Change to Plan

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Attachments:

O - 5731 - 3242 - Martlesham & Martlesham Heath - None 5731 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Ken & Hazel Denne [3242] Agent: N/A

Full Text: As residents of Fynn Road, we would like to raise an objection to the building of more houses in this location. This road is very busy and noisy for much of the day, both on weekdays and at the weekend, and we have to be particularly careful when exiting our drive because of the volume and speed of the traffic in both directions, combined with the limited visibility. Any more traffic would make this much worse. Please don't do it! Summary: As residents of Fynn Road, we would like to raise an objection to the building of more houses in this location. This road is very busy and noisy for much of the day, both on weekdays and at the weekend, and we have to be particularly careful when exiting our drive because of the volume and speed of the traffic in both directions, combined with the limited visibility. Any more traffic would make this much worse. Please don't do it!

Change to Plan

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Attachments:

O - 5737 - 3246 - Martlesham & Martlesham Heath - None 5737 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Kate & Robi Fox [3246] Agent: N/A

Full Text: Re Martlesham 900a and 703

We are writing with reference to the consultation document regarding developable land at and surrounding Woodbridge Town football club. We are aware of a similar consultation document where this land was considered unsuitable in 2010, the reasons given at that time were:

1- The development would be visually prominent 2 - potential noise issues 3 - limited highway access opportunities.

We would argue that these issues remain valid and in fact due to the increase in vehicle ownership in the surrounding area ,significant extra pressure has been put on current access points.

We hope these views will be taken in to account on any decisions. Summary: Re Martlesham 900a and 703

1- The development would be visually prominent 2 - potential noise issues 3 - limited highway access opportunities.

We would argue that these issues remain valid and in fact due to the increase in vehicle ownership in the surrounding area ,significant extra pressure has been put on current access points.

Change to Plan

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Attachments:

C - 5747 - 3253 - Martlesham & Martlesham Heath - None 5747 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Dr Amy Clarke [3253] Agent: N/A

Full Text: In response to the consultation on the Local Plan Issues and Options I would comment as follows:

Change to Plan

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Attachments:

O - 5801 - 3264 - Martlesham & Martlesham Heath - None 5801 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Hugh and Kim Montague [3264] Agent: N/A

Full Text: We understand that planning permission is being sought, for up to 112 units, on land in the parish of Martlesham and surrounding Woodbridge Town FC with the site ref 900a. In 2010 an application was drawn up, proposing the development of this site. That application was refused on the basis of potential noise issues, visual prominence and limited highway access. The five years that have passed, since this decision was made, have not lessened the validity of these decisive factors, in any way. We wish to object, to this revised proposal, as we agree with the reasons for the rejection of the 2010 attempt. Further, we are well aware of SCDC's commitment to improving the health and wellbeing of the people of this area. At this time, the presence of a sporting venue (the football club) provides an exemplar for the children and youth of Seckford Heights. More importantly, there is sufficient space, beside the ground, to allow the enjoyment of participation in sport, for individuals and teams of all ages and abilities. It is surely unthinkable that this opportunity for sporting activity should be marginalized and reduced to the left over "rump" of a developer's plan. We have seen reports, in the media, that developers have become adept at including a raft of deal sweeteners, such as recreational space, affordable housing and C.I.L., with their proposal to develop. However, when permission is granted and the build starts, these promises acquire a certain fluidity regarding materialization. Please consider our objection. Summary: We understand that planning permission is being sought, for up to 112 units, on land in the parish of Martlesham and surrounding Woodbridge Town FC site ref 900a. In 2010 an application was drawn up, proposing the development of this site. That application was refused on the basis of potential noise issues, visual prominence and limited highway access. The five years that have passed, since have not lessened the validity of these decisive factors, in any way. We wish to object, to this revised proposal, as we agree with the reasons for the rejection of the 2010 attempt.

Change to Plan

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Attachments:

O - 5802 - 2849 - Martlesham & Martlesham Heath - None 5802 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Tesco Stores Limited [2849] Agent: Contour Planning Services (Mr Justin Mills) [2473]

Full Text: Site Ref. 721 should not be referred to as 'employment land', since it is in existing and committed retail use. It is no longer appropriate to maintain an 'employment land' designation on a site which is clearly not available for wider employment uses (in accordance with NPPF Para 22).

Summary: Site Ref. 721 should not be referred to as 'employment land', since it is in existing and committed retail use. It is no longer appropriate to maintain an 'employment land' designation on a site which is clearly not available for wider employment uses (in accordance with NPPF Para 22).

Change to Plan Remove Site Ref. 721 from employment land designation

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Attachments:

O - 5809 - 209 - Martlesham & Martlesham Heath - None 5809 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr David Beaumont [209] Agent: N/A

Full Text: The current SP20 is a license for the URBANISATION of the semi-rural environment of Martlesham to the detriment of its residents and the District as a whole. This will result in the OVER-DEVELOPMENT of Martlesham. The proposed modification of the A12 at Martlesham involves the destruction of 3 roundabouts, to be replaced by traffic light controlled crossroads which is an INADEQUATE solution to solve the current and future traffic congestion on the A12: traffic lights fail, roundabouts always work.

A new Sustainability Assessment is needed as Martlesham's traffic and housing has increased and NO planning applications determined until completed. Summary: The current SP20 is a license for the URBANISATION of the semi-rural environment of Martlesham to the detriment of its residents and the District as a whole. This will result in the OVER-DEVELOPMENT of Martlesham. The proposed modification of the A12 at Martlesham involves the destruction of 3 roundabouts, to be replaced by traffic light controlled crossroads which is an INADEQUATE solution to solve the current and future traffic congestion on the A12: traffic lights fail, roundabouts always work.

A new Sustainability Assessment is needed as Martlesham's traffic and housing has increased and NO planning applications determined until completed.

Change to Plan Due to recent developments at Martlesham and increased traffic flow/congestion a new INDEPENDENT Sustainability Assessment is required. No planning applications which affect these issues should be Determined until the SA is completed and considered.

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Attachments: Site Allocations Consultation Response.pdf

S - 5853 - 3295 - Martlesham & Martlesham Heath - None 5853 Support East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr Derek Rothwell [3295] Agent: N/A

Full Text: In response to the consultation on the Local Plan Issues and Options I would comment as follows:

Site 453 - Martlesham: Land at and surrounding Bridge Farm, Top Street - I support the Council's view that this land should be protected from development to prevent coalescence of Woodbridge and Martlesham and to recognise that it does not have the transport infrastructure to support it as part of a sustainable community. Any such development would be prejudicial to both Woodbridge and Martlesham and would have a significant impact on the environmental sustainability of both a Special Landscape Area and an Area of Outstanding Natural Beauty. Summary: Site 453 - Martlesham: Land at and surrounding Bridge Farm, Top Street - I support the Council's view that this land should be protected from development to prevent coalescence of Woodbridge and Martlesham and to recognise that it does not have the transport infrastructure to support it as part of a sustainable community. Any such development would be prejudicial to both Woodbridge and Martlesham and would have a significant impact on the environmental sustainability of both a Special Landscape Area and an Area of Outstanding Natural Beauty.

Change to Plan N/A

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Attachments:

O - 5854 - 3296 - Martlesham & Martlesham Heath - None 5854 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr Graeme Holder [3296] Agent: N/A

Full Text: I understand the public consultation period for the above proposal comes to a close this coming Friday 27th February.

I would wish to make known my objections to the proposal on the grounds of noise, visual impact on a market town, congestion, inappropriate/dangerous access. I would also wish to register that I believe the appropriate consultation process has not been followed and is flawed.

Would you kindly acknowledge receipt of my objections and inform me what further information is required to register these in accordance with your processes. Summary: I would wish to make known my objections to the proposal on the grounds of noise, visual impact on a market town, congestion, inappropriate/dangerous access. I would also wish to register that I believe the appropriate consultation process has not been followed and is flawed.

Change to Plan

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Attachments:

S - 5936 - 3307 - Martlesham & Martlesham Heath - None 5936 Support East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Gladman Developments (Mr Richard House) [3307] Agent: N/A

Full Text: 1. INTRODUCTION

1.1 This representation is made by Gladman Developments Limited (GDL). GDL specialises in the promotion of strategic land for residential development with associated community infrastructure and has land interests in the District. GDL has considerable experience in the development industry in a number of sectors including residential and employment development. From that experience, it understands the need for the planning system to provide local communities with the homes and jobs that they need to ensure that they have access to a decent home and employment opportunities.

1.2 GDL has considerable experience in contributing to the Development Plan formation process, having made representations on numerous local planning documents throughout the UK and having participated in many local plan public examinations. It is on the basis of that experience that its comments are made in this representation.

1.3 This submission provides GDL's representations to the Suffolk Coastal Site Allocations and Area Specific Policies Issues and Options Consultation.

2. Q.1 THE BROAD SCALE AND LOCATION OF DEVELOPMENT

2.1 The National Planning Policy Framework expresses the Government's goal to 'significantly boost the supply of housing' and how this should be reflected through the preparation of Local Plans. In this regard it sets out specific guidance that local planning authorities must take into account when identifying and meeting their objectively assessed housing needs:

"To boost significantly the supply of housing, local planning authorities should: * Use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area; * Identify and update annually a supply of specific deliverable sites sufficient to provide five years' worth of housing against their housing requirements...;" and * Identify a supply of specific, developable sites or broad locations for growth, for years 6-10, and where possible for years 11-15" (Paragraph 47)

2.2 GDL notes that the Council intends to allocate land for housing to accommodate over and above the minimum target of 5240 dwellings required in the Core Strategy in order to provide flexibility and choice for future residents, developers and other stakeholders. This is a sensible approach, however GDL considers that an over-allocation is also important for other reasons as well.

2.3 GDL would strongly support the allocation of significant additional land for housing to provide the Council with increased flexibility in achieving its housing targets. In assessing existing supply, GDL considers that extreme caution needs to be taken in respect of sites with planning permission and remaining plan allocations in realistically assessing housing land supply. It should not be assumed that all such sites will come forward for development in the next five years as some will be subject to development constraints such as infrastructure requirements, multiple ownerships and market conditions.

2.4 It is noted that the proposed housing strategy for Suffolk Coastal places heavy reliance upon the delivery of 2,000 houses on a single site at Adastral Park, Martlesham in the Eastern Ipswich Plan Area. Whilst GDL generally agrees with the concept of large scale urban extensions such as this which generally conforms to the objectives and key themes set out in the National Planning Policy Framework (NPPF), it is imperative that the local planning authority is realistic in relation to the delivery and timescales associated with these types of developments.

2.5 Research carried out by Hourigan Connelly on behalf of GDL concerning the development of strategic sites (i.e. sites of over 500 dwellings) in the UK has shown that, on average, there is a lead in time of approximately 8 years from the grant of outline planning permission to the commencement of development. (See Appendix 1). The research found that delays in sites coming forward are due principally to negotiations on Section 106 agreements, the need for major infrastructure investments and difficulties caused by sites in multiple ownerships.

2.6 The Adastral Park development has not yet received planning permission. It will include the provision of significant community infrastructure including new education and healthcare facilities, public transport, shops, leisure and sports facilities, public spaces and significant improvement of the existing transport infrastructure including improved A12 access. It is also likely that planning permission will require the subsequent preparation and consultation on a masterplan for the site together with the preparation of legal agreements relating to the provision of infrastructure and relating to environmental mitigation measures. It is highly unlikely therefore that delivery of housing on the site will commence until the later years of the of the Plan period.

2.7 The allocation of additional sites in the Site Allocations Plan will therefore be necessary to mitigate against those risks particularly sites which are immediately available for development and which can contribute to housing supply during the initial part of the Plan Period. The allocation of additional sites to accommodate at the very least a 25% increase in housing provision over and above the Core Strategy minimum requirement would be essential to ensure that

S - 5936 - 3307 - Martlesham & Martlesham Heath - None 5936 Support East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

the Council's housing objectives are realised and that a rolling 5 year supply of housing land is maintained.

2.8 GDL generally supports an approach to the distribution of housing which reflects the needs and characteristics of individual settlements. However in considering the distribution of housing growth it is important to note that a fundamental objective of NPPF is to secure a thriving rural economy "by taking a positive approach to sustainable new development"(NPPF para 28 ) The NPPF seeks to significantly boost the supply of new housing and in rural areas "housing should be located where it will enhance or maintain the vitality of rural communities"( ibid para 55 ) and market housing may be allowed where it "would facilitate the provision of significant affordable housing to meet local needs" (Ibid para 54). 4 PPG Rural Housing 50-001-20140306 2.9 There are several benefits of providing new housing in rural areas. These benefits are:

* new housing can help sustain rural communities and businesses. Planning Practice Guidance states that "A thriving rural community in a living, working countryside depends, in part, on retaining local services and community facilities such as schools, local shops, cultural venues, public houses and places of worship. Rural housing is essential to ensure viable use of these local facilities"(4 PPG Rural Housing 50-001-20140306); * The provision of family housing in rural areas would help redress the current age structure imbalance towards those aged over 65; * The amount of affordable housing in rural areas can be significantly increased by allowing new and larger sites to be developed; and * Locating housing development in settlements with good public transport links can assist in encouraging sustainable travel choices and can assist in maintaining the viability of those transport links.

3. Q.2 INDICATIVE SUGGESTED HOUSING ALLOCATION

3.1 As referred to in Paragraph 2 above, the Site Allocations and Area Specific Policies document should allocate sufficient sites to accommodate a 25% increase in the Core Strategy minimum housing requirement in order to ensure that the Plan provides a rolling 5 year supply of housing land as required by NPPF. Assuming that all houses subject to an existing planning permission or S106 agreement are actually delivered, this would result in an overall housing provision of 6,550 dwellings, the residual requirement being 3,658 dwellings. 3.2 It is suggested that this additional provision should be apportioned to the Market Towns and Key Service Centres as sustainable locations for new development.

4. Q.3 SUITABLE SITES

4.1 GDL has an interest in a sustainable and immediately available site at Woodbridge which would assist in boosting housing supply in the early years of the Plan. The site is at Dukes Park, Sandy Lane Woodbridge and referred to as site 453 in the Plan Booklet. 4.2 The site is located on the southern edge of Woodbridge to the south of Top Street and Ipswich Road. The site comprises of 12.89 hectares of agricultural land. The eastern boundary of the site is formed by properties in Duke's Park which are set back from the site. Sandy Lane and the Ipswich to Woodbridge railway line delineate the southern boundary of the site. Top Street and properties located to the north of Martlesham define the western boundary.

4.3 The development of the site would from a logical extension to the town of Woodbridge and is located close to a good range of local services and facilities. The site is well screened from the wider landscape and relates well to the town centre with easy access via Ipswich Road. It would accommodate up to 200 dwellings including affordable housing.

4.4 The site is sustainably located with good access to Woodbridge town centre and surrounding community amenities. Existing facilities in Woodbridge include a range of schools, health centres as well as range of shops restaurants and pubs. The site has excellent public transport links with bus stops within 300 metres of the site providing links to Woodbridge, Martlesham and Ipswich and there are employment area within walking distance.

4.5 The site benefits from excellent access to local leisure and recreation facilities near to the site including Woodbridge Town Football Club, Seckford Hall and Golf Club, the Suffolk Coast and Heaths Area of Outstanding Natural Beauty, long distance footpaths, woodland and public open space.

4.6 The site is in single ownership and could be quickly brought forward for development as no major infrastructure is required to facilitate development of the scale proposed.

5. Q.5 TYPE AND MIX OF HOUSING

5.1 GDL considers that the Site Allocations and Area Specific Plan should assess housing mix requirements based on the most up to date evidence base, however this should be updated annually to ensure that the housing mix in later years of the plan period remains up to date.

5.2 The Council should however take into account that ensuring viability and deliverability is a key element of the NPPF, specifically paragraph 173 which states 'To ensure viability, the costs of any requirement likely to be applied to development, such as requirements for affordable housing, standards, infrastructure contributions or other requirements

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should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable.'

5.3 GDL therefore suggests that the housing mix should be appropriately monitored on an annual basis, providing a flexible approach in line with up to date evidence. It should not be subjected to a level of constraint which may affect the viability of the proposal from being delivered and therefore should be determined on a site by site basis. Policies concerning housing mix should not in any way inhibit the ability of developers to deliver housing to meet local demand.

6. Q.6 PHYSICAL LIMIT BOUNDARIES

6.1 GDL submits that settlement boundaries should not be used as a mechanism to restrict otherwise sustainable development from coming forward. The use of settlement boundaries fails to plan positively for current and projected objectively assessed housing need.

6.2 GDL refers to NPPF which is clear that development which is sustainable should go ahead without delay. The use of settlement limits to arbitrarily restrict suitable and sustainable development from coming forward on the edge of settlements would not accord with the positive approach to growth required by NPPF. Planning Practice Guidance(PPG ID: 50-001-20140306) also advises that "all settlements can play a role in delivering sustainable development in rural areas - and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided unless their use can be supported by robust evidence".

6.3 The definition of settlement boundaries is based on the old PPS7 approach to countryside protection, which took a restrictive stance to development in the rural areas by only permitting certain types of development. There is nothing in NPPF which states that development in the open countryside should be restricted in the extensive manner which such a policy suggests, creating a 'presumption against development' in all areas beyond out of date settlement boundaries. GDL recommends that a more permissive approach to development in the open countryside is adopted in the Site Allocations and Area Specific Policies Plan.

6.4 Greenfield sites on the edge of rural settlements, but lying outside of the currently built up area, may offer opportunities for sustainable development which could help meet the housing needs of Suffolk Coastal and help achieve NPPF's objective to 'significantly boost the supply of housing' and would accord with the presumption in favour of sustainable development.

7. Q.25 ENVIRONMENT SAVED POLICIES

7.1 The Consultation Document proposes that Saved Policy AP214 should be retained and updated. Policy AP214 is a Landscape Enhancement Policy which applies to land at Ipswich Road/Sandy Lane, Martlesham (Site 453 referred to in Section 4 of this submission). The Policy states:

'The land lying between Sandy Lane and the A12, as shown on the Proposals Map, is considered to be a prominent and essential component of the Fynn Valley, lying between the Special Landscape Area to the West and the Area of Outstanding Natural Beauty. The District Council will encourage enhancement measures which improve the landscape of this area to the same quality as that to the west'.

This policy predates NPPF and is now out of date. Since the adoption of the Suffolk Coastal Local Plan NPPF has made a material change to the planning approach for local landscape designations. It states that protection of land should be commensurate with its status and appropriate weight should be given to its importance in terms of the hierarchy of international, national and local designations (Paragraph 113).

7.3 This is a local designation, which is no longer given significant weight in NPPF. Footnote 9 of paragraph 14 and Paragraph 115 of NPPF state that policies relating to sites protected under the Birds and Habitats Directive, and/or designated as SSSIs, Green Belt land, Local Green Space, an AONB, Heritage Coast or within a National Park should have the highest status of protection. The site is not affected by any designations such as these and is of limited landscape quality. Policy AP214 therefore should not be retained in the Site Allocations and Area Specific Policies Plan. Summary: GDL has an interest in a sustainable site which would assist in boosting housing supply in the early years of the Plan. The site is at Dukes Park, Sandy Lane and referred to as site 453 in the Plan Booklet. The development of the site would from a logical extension to the town of Woodbridge and is located close to a good range of local services and facilities. The site is well screened from the wider landscape and relates well to the town centre with easy access via Ipswich Road. It would accommodate up to 200 dwellings including affordable housing.

Change to Plan N/A

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Attachments: Appendix 1 SUE Study Hourigan Connelly.pdf

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Gladman Reps.pdf

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

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

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

We would like to make the following comments:

Section 3: Housing

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Section 4: The Economy

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

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

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

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

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

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

Section 5: The Environment

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

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

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

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

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

We hope that the above comments are of assistance. Please do not hesitate to contact me if you have any queries. We look forward to the next iteration of this plan. Summary: The SHLAA sites shown in Map 3 of the map booklet for Martlesham Heath (430,517, 644 and 693) are not mentioned in the accompanying table. They appear to extend beyond the site boundary of the Adastral Park site. This is significant

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as the SHLAA sites include or adjoin a number of scheduled monuments to the south and east at Spratt's Plantation and Brightwell Heath. We have commented on historic environment issues in this location in relation to the Adastral Park applications. We would welcome clarification on the SHLAA sites and the intended allocations for Martlesham (notwithstanding the potential neighbourhood plan).

Change to Plan

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

O - 6028 - 3334 - Martlesham & Martlesham Heath - None 6028 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Jan Evans [3334] Agent: N/A

Full Text: Consultation on Proposals for Housing Development in two sites within the adopted Suffolk Coastal District Local Plan Core Strategy and Development Management Policies DPD

I write to object to the housing development proposed on land off Sandy Lane/ Top Street/ Duke's Park/ lpswich Road that currently lies outside the existing physical limits of Woodbridge. I understand that in the Neighbourhood Plan Boundary Consultation currently being undertaken by Suffolk Coastal District Council, Woodbridge Town Council's application for an NP Boundary and Martlesham's proposed NP Boundary both envisage this land, referred to as Woodbridge SHLAA Site 453, will remain within Martlesham's National Plan Area. lf that remains the case then Site 453 should not be developed to satisfy the projected new housing requirements of Woodbridge. lnstead Site 453 should remain as open countryside for the purpose of conserving and enhancing the quality and local distinctiveness of landscapes and townscapes. Any development on this Site would encroach upon the green countryside separating the entities of Woodbridge and Martlesham. Site 453 is a field to the South of Dukes Park that extends down to the railway line. lt is elevated land and as such can be seen from a large area of the surrounding countryside. lt can also be seen by every passenger traveling by train from lpswich/Westerfield to Woodbridge. The Ordnance Survey Map extract in the Consultation Document clearly illustrates this: moreover the map also shows that there is no dense housing on the rail route until it enters the town of Woodbridge. Thus any development on the field would be not only an eyesore for those traveling by train but would also be the first impression of Woodbridge gained by those passengers. The name "Woodbridge" conjures images of trees and a river in the imagination and the picturesque approach through open countryside with views of the Fliver Deben and Martlesham Creek does nothing to dispel these thoughts. May it so continue. As evidence to support this I have attached photographs taken from the train of part of the field in question. the effect of a housing development here and the consequent loss of both unspoiled countryside and of the skyline would be a disaster. I attach another photograph taken overlooking the corner of the field where the proposed convenience store would be sited. this shows the embanked railway line and the huge area from which the site is visible. Considering now the practicality of establishing housing here, I would respectfully suggest that the impact of housing on Site 453 would have a significant negative effect, in particular on the transport load on the single-track Sandy Lane. However access to the site from any direction would not be ideal and this would be exacerbated during construction. Furthermore the lack of facilities other than a convenience store would necessitate additional journeys to other retail outlets, increasing fuel consumption and pollutant vehicle emissions. The quality of life of those currently living in the vicinity or overlooking the site from afar would be immeasurably worsened by replacing the green countryside and scenic views with housing development. I sincerely hope that development in this special area of countryside will not be considered acceptable or be permitted, especially as there is an area nearby, Adastral Park, that could comfortably support a larger area of housing development as it already has the required infrastructure in place - transport; diverse retail facilities; services; a range of companies providing opportunities for employment; fully serviced office accommodation to suit large, medium and small companies with high speed broadband and meeting rooms, as well as virtual office space for small and start-up businesses. By contrast Site 453 has absolutely no infrastructure such that even a convenience store is part of the overall plan. I ask the Planning Policy and Development Team to take a long-term view and decide to preserve the countryside not only for all who travel to or live in Woodbridge today but for the enjoyment of future generations. Summary: 453: I sincerely hope that development in this special area of countryside will not be considered acceptable or be permitted, especially as there is an area nearby, Adastral Park, that could comfortably support a larger area of housing development as it already has the required infrastructure in place - transport; diverse retail facilities; services; a range of companies providing opportunities for employment; fully serviced office accommodation to suit large, medium and small companies with high speed broadband and meeting rooms. By contrast Site 453 has absolutely no infrastructure such that even a convenience store is part of the overall plan.

Change to Plan

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Attachments: Consultation response annotated map.pdf Consultation response scan 26 02 2015_Redacted.pdf

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Respondent: Sue Verow [3335] Agent: N/A

Full Text: We are writing to you with our concerns about the proposed development at Woodbridge Town Football Club situated on Seckford Heights.

As residents of Fynn Road we are extremely concerned that if the development were to go ahead as per the proposed plan, it would be detrimental to our current quality of living, the vechical access would be excessive especially along Seckford Hall Road and into Fynn Road. It would impact greatly on all the residents especially those of us in Fynn Road. We already have problems getting out of our drives when the road is busy , goodness only knows what it will be like with another 150 vehicles on the road.

It is our understanding that the Council is concerned about the pollution in and around Woodbridge and this would make it worse. They are already concerned about the amount of traffic entering Woodbridge this would only make matters worse, especially along our minor roads. The vehicles trying to get out of Seckford Hall Road would turn right onto Old Barrack Road and then divert, either through Woodbridge via Seckford Street or go down Warren Hill Road and back onto Ipswich Road from there. Another route that people will inevitably take at the bottle neck that will occur at the end of Fynn Road is that they will divert down Oxford Road to avoid the junction altogether and enable them to join Old Barrack Road. This situation will impact on air quality and the residents living close by.

We also feel that this development is detrimental to all the residents who live on Seckford Heights and those living in the Oxford Road areas. These areas are quiet residential areas and would be ruined by the increase of traffic flow.

We also understand that in 2010 a similar document was raised identifying that Seckford Heights land was unsuitable for development due to it being "visually prominent, potential noise issues and limited highways access opportunities" - what has changed in FIVE YEARS? Nothing has changed!!!!

We are asking you as our Council representatives and planning officers, to listen to your local residents and put a stop to this madness. Summary: We are extremely concerned that if the development were to go ahead as per the proposed plan, it would be detrimental to our current quality of living, the vechical access would be excessive especially along Seckford Hall Road and into Fynn Road. It would impact greatly on all the residents especially those of us in Fynn Road. We understand that in 2010 a similar document was raised identifying that Seckford Heights land was unsuitable for development due to it being "visually prominent, potential noise issues and limited highways access opportunities" - what has changed in FIVE YEARS?

Change to Plan

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Attachments:

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Respondent: Mr Christopher Wagstaff [3268] Agent: N/A

Full Text: As residents of Seckford Heights, we wish to make a representation that the current proposal by Hopkins Homes for residential development of the WTFC site should not be permitted unless the site is provided with a separate vehicular access from Ipswich Road. The current Hopkins proposal is for the vehicular access to the WTFC site to be via Fynn Road from Seckford Hall Road and Old Barrack Road. The route along Fynn Rd/Seckford Hall Rd/Old Barrack Rd is already very busy at peak times and queues of traffic frequently occur on Old Barrack Rd when waiting to turn on to Ipswich Road. The additional traffic flow that will be generated by the Hopkins proposals will make vehicular access along Fynn Rd/Seckford Hall Rd/Old Barrack Rd even more difficult, so Fynn Rd should be made a cul de sac at the point where it abuts the WTFC site and the WTFC site should be given its own, separate access to Ipswich Rd. We understand fully the need for further residential development in the area but it must not be to the detriment of the existing Seckford Heights residents. A separate access for the WTFC site to Ipswich Rd will keep everyone happy albeit there may be a slight additional cost to the Hopkins of creating the new junction with Ipswich Rd. Summary: The route along Fynn Rd/Seckford Hall Rd/Old Barrack Rd is already busy at peak times and queues of traffic frequently occur on Old Barrack Rd onto Ipswich Road. Additional traffic flow generated by the Hopkins proposals will make vehicular access along Fynn Rd/Seckford Hall Rd/Old Barrack Rd even more difficult, so Fynn Rd should be made a cul de sac where it abuts the WTFC site and the WTFC site should be given its own, separate access to Ipswich Rd. We understand the need for further residential development but it must not be to the detriment of the existing residents.

Change to Plan

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Attachments:

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Respondent: Mr Anthony Flavin [3274] Agent: N/A

Full Text: I would like to express severe concerns over the proposed development SHLAA 900a. The site is not suitable for any further development due to problems with access for construction, Visual prominence on the approach to Woodbridge, Potential noise issues and severely restricted highway access.

In 2010 the land was not considered suitable for development for those reasons - and nothing has changed to address any of them.

In particular the proposed access via Fynn road is totally unsuitable for construction traffic - to the extent that it was not used during the construction of the existing Seckford Heights development. A temporary construction road was built - and built over in a managed retreat fashion. Access would therefore have to be created from Ipswich road that would raise road safety issues even on a temporary basis.

Further, with the Adastral Park development now having cleared the High Court hold up, there can be no need for the Martlesham Parish to contribute more housing on this scale locally. Summary: I would like to express severe concerns over the proposed development SHLAA 900a. The site is not suitable for any further development due to problems with access for construction, Visual prominence on the approach to Woodbridge, Potential noise issues and severely restricted highway access.

In 2010 the land was not considered suitable for development for those reasons - and nothing has changed to address any of them. In particular the proposed access via Fynn road is totally unsuitable for construction traffic - to the extent that it was not used during the construction of the existing Seckford Heights development.

Change to Plan

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Attachments:

O - 6046 - 3338 - Martlesham & Martlesham Heath - None 6046 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Rosie Bryanton [3338] Agent: N/A

Full Text: Plans to build on land at site refs: 900a (includes 703 and 895) also site 453 if there are still plans to build on this plus 693

We would like to register our objections to the above planned development.

In 2010 a similar document was drawn up for site ref 900a and this land was considered not suitable for building the following reasons:

* The site is visually prominent * There are potential noise issues * There are limited highway access opportunities

Schools are already full in this area; it is already impossible to get a doctor's appointment when you need one; roads leading to the main employments centres at Martlesham Heath and Ipswich are jam packed. A significant number of houses are currently being built in Martlesham, near the Black Tiles. Any more and the whole area will grind to a halt. It is already a struggle for ambulances to fight their way through the traffic from Ipswich Hospital to get to Woodbridge and beyond.

No more house should be built until sufficient services and satisfactory road systems are in place to support them. Summary: In 2010 a similar document was drawn up for site ref 900a and this land was considered not suitable for building the following reasons:

* The site is visually prominent * There are potential noise issues * There are limited highway access opportunities

Nothing has changed since 2010, so why is this being considered again? There simply is not the infrastructure to support more houses in the area and this is why we are also objecting to site 453 and 693. No more house should be built until sufficient services and satisfactory road systems are in place to support them.

Change to Plan

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Attachments:

C - 6066 - 3344 - Martlesham & Martlesham Heath - None 6066 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Morgan Davies [3344] Agent: N/A

Full Text: In response to the consultation on the Local Plan Issues and Options I would comment as follows:

Change to Plan

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Attachments:

C - 6067 - 3345 - Martlesham & Martlesham Heath - None 6067 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Anne Davies [3345] Agent: N/A

Full Text: In response to the consultation on the Local Plan Issues and Options I would comment as follows:

Change to Plan

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Attachments:

C - 6086 - 2839 - Martlesham & Martlesham Heath - None 6086 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: RSPB (Jacqui Miller) [2839] Agent: N/A

Full Text: Re: Suffolk Coastal District Council Site Allocations and Area Specific Policies Issues and Options Consultation Thank you for inviting the RSPB to comment on the Site Allocations and Area Specific Policies Issues and Options Consultation. We are pleased to provide the following response. Whilst we are generally supportive of the approach at this stage, we consider that more work will be required (specifically relating to Habitats Regulations Assessment, green infrastructure and ecological networks) to ensure that the final documents are fully justified and effective. Site Allocations and Area Specific Policies Issues and Options Document Q25. Do you have any thoughts on the approach set out [to Natural Environment and Coastal Change]? The Natural Environment section needs to set out how it will ensure that no adverse effects will arise to European nature conservation sites (Special Protection Areas, Special Areas of Conservation and Ramsar sites) as a result of policies within the Site Allocations DPD. This should encompass the need for Habitats Regulations Assessment (HRA) at the strategic level and later, at the level of individual projects. HRA of the Site Allocations DPD will be required as it will constitute a plan or project, as defined by the Conservation of Habitats and Species Regulations 2010 (as amended). HRA will also be required later, at the individual project level due to the greater certainty and level of detail available with regard design and number of units etc. at this stage. Such an approach would be in accordance with the Council's Development Management Policy DM27 - Biodiversity and Geodiversity, and with paras. 14 and 119 of the National Planning Policy Framework. Similarly we recommend that Para. 1.33 on HRA should be updated as above, to incorporate details as to when HRA will be expected. With reference to Table 9 Designated Nature Conservation Sites, we note that there should be five (not four) SPAs recorded within the Suffolk Coastal district. These comprise the Orwell (part of Stour and Orwell Estuaries SPA), Deben Estuary, Alde-Ore Estuary, Sandlings and Minsmere-Walberswick Heaths and Marshes). Para. 5.5 references the Deben and Orwell as the relevant SPAs/SACs/Ramsar within the district - we suggest that this is amended to reflect that there are several other European sites within the area (see comment above). Q28. Are Biodiversity Action Plan, local ecological networks, priority habitats and priority species given sufficient policy coverage? Ecological networks and green infrastructure Due to the linkages between ecological networks and green infrastructure provision, we have considered both together in our response here. The RSPB consider that work to identify potential enhancement measures for local ecological networks could build on the work carried out as part of the 2008 Haven Gateway Green Infrastructure Strategy and the 2011 Green Infrastructure Strategy for the Suffolk Coastal district. At present the district Green Infrastructure Strategy appears focused on recreational provision. Whilst important, we consider that there is also an opportunity to expand the Strategy to include biodiversity targets. This should aim to create networks of sites of biodiversity value that 'fill the gaps' between existing green space features and sites of importance for biodiversity. Joined up networks are more functional and allow species to move between sites, helping them to adapt to the likely effects of climate change. We recommend that the currently available maps of priority habitat types are supplemented by map(s) showing designated sites (including international sites, SSSIs and County Wildlife Sites). These maps of current biodiversity resource can then be used to identify those areas which could be targeted for restoration, buffering or linkage through habitat creation or restoration. While it is important to note that existing designated wildlife sites should not have their ecological function undermined through a desire to use them for any other purposes which may be detrimental to their interest features, new greenspaces should perform multiple functions. Para. 6.2 of the Issues and Options consultation document refers to Core Strategy Objective 14 relating to Green Infrastructure, which states that: Access to green space is important for people's mental and physical well-being. Green spaces also have a function to play in helping to adapt to climate change and can be used to form green corridors which can benefit and boost wildlife. In addition, the creation of new green infrastructure is required to mitigate the impact of new development, to provide alternative recreation/leisure space for existing and new residents, to help relieve pressure on the estuaries and their populations of over-wintering birds. Objective 14 makes the following commitments: A comprehensive green infrastructure network will be achieved by establishing and maintaining a network of accessible good quality play spaces, sport and recreation facilities (including allotments) based on established standards. In addition there will be a growing network of natural green spaces across the district based upon local standards to be created. We recommend that the implementation of the opportunities identified within the 2011 Green Infrastructure Strategy should be prioritised. We also suggest that the creation of a Green Infrastructure advice pack for developers would be beneficial, similar to that produced by St Edmundsbury Borough Council1. Following this example, we recommend that consideration be given to the division of the district into zones with their own ecological and community objectives and targets, based on and informed by local priorities. These should promote the masterplanning and design of green infrastructure from the outset of any housing scheme, so that it provides a coherent framework for the overall development and makes a clear contribution to local ecological networks. Any major housing scheme should have a green infrastructure strategy detailing what will be provided, where it will go, when it will be completed, sources of funding and who will carry out long-term maintenance. It is important that green infrastructure is not seen as a 'bolt on' at the end of the development process. Development schemes should also consider the ecological function of the site, through the protection and enhancement of existing features and/or the creation of new ones. Designs should be appropriate to the landscape and seek to benefit locally important species and habitats. Again, this could be informed by the green infrastructure advice pack and the targets for the locally relevant zone. Species and habitats

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Alongside the need to avoid and mitigate potential negative effects on the environment, we recommend that the Council explicitly makes a recommendation that opportunities within developments for biodiversity enhancement should be sought. This would be in accordance with Development Management Policy DM27, which states: All development proposals should: (a) protect the biodiversity and geodiversity value of land and buildings and minimise fragmentation of habitats; (b) maximise opportunities for restoration, enhancement and connection of natural habitats; and (c) incorporate beneficial biodiversity conservation features where appropriate. The NPPF (para. 109) also requires that: "The planning system should contribute and enhance the natural and local environment by:...minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Governments' commitment to halt the overall decline in biodiversity, including establishing coherent ecological networks that are more resilient to current and future pressures." The RSPB consider that there are opportunities through this document and/or supplementary documents to set standards for design and planning of housing developments to incorporate provision of biodiversity enhancements. Measures proposed could include nest boxes/bricks for swifts and bats, wildflower mixes, green roofs, hedgerow management for wildlife and maximising the wildlife potential of SuDS. These measures could also make a contribution to local ecological networks and the conservation of priority and BAP species, such as the swift, house sparrow and hedgehog. The RSPB would be pleased to provide further advice regarding such measures. Additional sources of information With regard our response to question 28 covering green infrastructure, ecological networks and priority habitats and species, we recommend that the Council also have regard to the detailed guidance contained in the following publications. 1St Edmundsbury Green Infrastructure Information Pack: A guide for developers and planners delivering green infrastructure. Available at http://www.westsuffolk.gov.uk/planning/upload/StEdmundsburyGIInformationPack.pdf

requirements in section 9.28)

section 3.15 (p101) and Table 5.1 (p131) on nestbox provision

out twelve principles of good spatial planning, illustrated by case studies

infrastructure and biodiversity See also Annex C Felixstowe Area Action Plan Issues and Options Document Should policies be written to consider proposals for development affecting protected wildlife or geodiversity sites or landscape areas or are they adequately covered by the Core Strategy? Core Strategy policies need to be 'supported by appropriate detail' (see para.6.5) within the AAP to ensure protection/consideration of national and international wildlife sites (SPA/SAC/Ramsar/SSSI) and protected and priority species is commensurate with that given to e.g. the Heritage Coast and AONB. We recommend that a specific policy emphasising the importance of biodiversity and protected sites should be included. Which sites across the Felixstowe Peninsula need to be identified to protect and enhance biodiversity and geodiversity as detailed in Core Strategy policy SP14? All designated wildlife sites should be identified. These should include non-statutory sites such as County Wildlife Sites, as well as those benefitting from statutory protection such as SSSIs and European sites (SPAs, SACs and Ramsar sites). In addition, sites supporting priority habitats and species under the Natural Environment and Rural Communities Act (2006) should be identified. It should be noted that such protection should not be limited to consideration of impacts from development directly on or adjacent to a protected site, but should include indirect impacts such as those of increased recreational pressure. We also note that, for the purposes of HRA, impacts resulting from allocations within the Felixstowe AAP should be considered in-combination with those arising from the Site Allocations and Area Specific Policies document, particularly with regard to potential impacts resulting from recreational pressure on the Deben Estuary SPA and Ramsar site and the Stour and Orwell Estuaries SPA and Ramsar site. How can the Felixstowe Peninsula AAP promote a network of green infrastructure? Please also refer to our answer to Q28 from the Site Allocations and Area Specific Policies, above. Para. 7.1 states that the Felixstowe Peninsula Area Action Plan (AAP) has the opportunity to identify site specific projects such as playing fields, green links, allotments and other facilities which are fundamental to the local communities. We note, as above, that opportunities should also be sought to enhance local ecological networks through the restoration, enhancement, buffering and linking of sites of biodiversity value. We recommend that strong links are made to the outputs of the Haven Gateway Green Infrastructure Strategy. As recommended above, this could be used to generate advice for developers regarding green infrastructure and biodiversity measures targeted at the requirements of the Felixstowe peninsula. Map booklets to accompany Issues and Options Consultation on Site Allocations and Area Specific Policies Saxmundham Housing Market Area Aldeburgh The RSPB are concerned about the proposed allocation of a total of up to 118-185 houses on sites 608 and 982. The sites are in close proximity to the Alde-Ore Estuary SPA, SAC and Ramsar site. Site 608 would provide for 69-108 houses, and is approximately 305m from Alde-Ore Estuary SPA, SAC and Ramsar site. We note that the Sustainability Appraisal (SA) acknowledges that a potentially significant effect on the estuary may result from an increase in recreational pressure and that it indicates that tracks exist linking the site to the estuary

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(although there is no official Public Right of Way (PRoW)). The SA therefore notes that mitigation such as Suitable Alternative Natural Green Space (SANG) and/or access monitoring and management is likely to be required. Site 982 would provide for 49-77 houses and is approximately 345m from the Alde-Ore Estuary SPA, SAC and Ramsar site. The SA again acknowledges that a potentially significant effect on the estuary may result from increased recreational pressure and indicates that a PRoW does exist linking this site to the estuary. The SA notes that this development of this site would also require mitigation as above and cumulative assessment with the existing planning consent on an adjacent site. We also note that the site boundary indicated incorporates Aldeburgh Brick Pits geological SSSI, which should be protected. The RSPB are concerned that, as noted in the SA, the allocation of these sites may result in increased recreational pressure on the Alde-Ore Estuary SPA. These proposals will require HRA, with particular attention given to the assessment of the impacts of these sites in-combination with each other, and with other proposed and consented projects in the area. We agree that, should the HRA demonstrate that these sites can be brought forward without adverse effects on the European sites, mitigation is likely to be required to avoid and reduce potential impacts, through signage and interpretation, and in particular through the provision of SANG. We note that the Site Allocations document indicates that site 968 is considered unsuitable due to its proximity to European sites. As site 968 is adjacent to site 982 and near site 608, we query why the rationale for the proposed allocation or rejection of these sites appears inconsistent. We also note that Appendix N of the SHLAA does not identify the proximity of European sites as a constraint for sites 982 and 608 (despite including the Heritage Coast, AONB and CWS designations as constraints). We recommend that rationales and constraints within the Site Allocations document, the SA and the SHLAA are checked to ensure they consistently note proximity to SPAs, SACs or Ramsar sites as these sites benefit from legal protection under the Conservation of Habitats and Species Regulations 2010 (as amended), which is distinct from any protection afforded to other designations. Woodbridge Housing Market Area Para. 5.6 of the Site Allocations and Area Specific Policies document notes that further assessment of cumulative impacts of small scale developments will be required. We consider that sites in the Woodbridge area should be included in such assessments (as part of the HRA of the Site Allocations), due to the potential for these sites in total to result in increases in recreational pressure on the Sandlings SPA, Deben SPA and Ramsar site, Alde-Ore Estuary SPA, SAC and Ramsar site and Staverton Parks and the Thicks SAC. As noted above with regard the Felixstowe area, these assessments will also need to consider relevant sites from other Housing Market Areas, and any other relevant proposed or consented projects. Felixstowe Housing Market Area As noted above in our comments on the Felixstowe Area Action Plan Issues and Options document, we consider that HRA of the Site Allocations should include assessments of the total allocation in the Felixstowe area in order to assess the effects of any increase in recreational pressure on the Deben SPA and Ramsar site. Again, this should include consideration of relevant sites from other Housing Market Areas and any other relevant proposed or consented projects. East Ipswich Housing Market Area As above, we consider that sites in the East Ipswich area (particularly those in Rushmere St Andrew, Kesgrave, Purdis Farm and Martlesham) should be assessed as part of the HRA of the Site Allocations, for their potential to result in increases in recreational pressure on the Sandlings SPA and Deben SPA and Ramsar site. As also noted above, these assessments will also need to consider relevant sites from other Housing Market Areas, and any other relevant proposed or consented projects, and any other relevant proposed or consented projects (such as those at Martlesham). Conclusion The RSPB recommend that HRA of the final site allocations should have a particular focus on potential impacts of increased recreational pressure on coastal, estuarine and heathland European sites. These impacts need to be assessed at the strategic level (as well as at the level of individual projects) to ensure that potential effects of the total new housing allocation (and those in-combination with other relevant plans or projects) are assessed. We recommend that potential mitigation should also be planned for at the strategic level, through the identification of areas suitable for the creation of new SANG, and of areas which may buffer or link sites of existing nature value (contributing to enhanced ecological networks). This could be pursued by building on and updating previous work from the Haven Gateway Green Infrastructure Strategy and the Green Infrastructure Strategy for the district. We trust that these comments are helpful. If you have any queries about the comments above, please do not hesitate to contact me. Summary: We consider that sites in the East Ipswich area (particularly those in Rushmere St Andrew, Kesgrave, Purdis Farm and Martlesham) should be assessed as part of the HRA of the Site Allocations, for their potential to result in increases in recreational pressure on the Sandlings SPA and Deben SPA and Ramsar site. As also noted above, these assessments will also need to consider relevant sites from other Housing Market Areas, and any other relevant proposed or consented projects, and any other relevant proposed or consented projects (such as those at Martlesham).

Change to Plan

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Attachments: RSPB response to site specific allocations consultation_Redacted.pdf

C - 6109 - 160 - Martlesham & Martlesham Heath - None 6109 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr Thomas O'Brien [160] Agent: N/A

Full Text: I am a householder living in Martlesham Heath. I must admit that I did find the consultation documentation totally confusing and crucially I couldn't really understand what it was about or what is expected from us. Also I tried using the on line consultation process but gave up after going round in internet loops. The description of the plans needs to give us more of an overview of the aims of the consultation process.

Nevertheless I have a few general comments about my locality.

1/ The development of retail stores near Next, M&S etc. is taking place in a hap hazard unsightly manner. Its not just the parking problems it brings, but doesn't bring much synergy for people living near by. What I would like to see in this retail area is:

a) A larger traffic free shopping square (bigger than the one already at Martlesham Heath centre) which would be a pleasant place to go - especially in the evenings, and would attract smaller shops and restaurants.

b) The foot way access could be improved. The existing A12 underpass to Tesco, and the footbridge near the leisure centre do not connect directly with Next and Hughes. So a footpath along the East side of the A12 would help. Of course an A12 underpass to the South of Martlesham Heath would help those walking to BT or elsewhere. (There are a number of young people who don't own cars and have to walk to either use the new retail stores or work there).

2/ On another note. I am an advocate of reinstating the public footpath along the sea wall from Martlesham Creek to Waldringfield. It would make a spectacular scenic walkway with views up and down the river, together with the chance of spotting interesting wildlife. There are grants available to complete this work under the Coastal Access Scheme. See here: https://www.gov.uk/government/collections/england-coast-path-improving-public-access-to-the-coast

This scheme is a Government backed initiative and newspaper reports have mentioned significant funds are available to complete this work. My research seems to show that Suffolk hasn't made much effort to secure this funding.

Martlesham Heath has taken a lot of growth over the years, and there are plans to build 2000 more houses behind BT. So I believe its only fair to give the growing local population access to these coastal areas in the vicinity. It would be a benefit to their health and well being. The RSPB and Suffolk Wildlife Trust are promoting the Nature and Wellbeing Act which promotes access to nature as a way of improving the health of the population. Summary: The development of retail stores near Next/M&S etc. is taking place in a haphazard manner. Its not just the parking problems it brings, but doesn't bring much synergy for people living nearby. A larger traffic free shopping square which would be a pleasant place to go-especially in the evenings, and would attract smaller shops and restaurants. The foot way access could be improved. The existing A12 underpass to Tesco, and footbridge near the leisure centre do not connect directly with Next and Hughes. An A12 underpass to the South of Martlesham Heath would help those walking to BT or elsewhere

Change to Plan

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Attachments:

C - 6124 - 2859 - Martlesham & Martlesham Heath - None 6124 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Waldringfield Parish Council (Mr David Lines) Agent: N/A [2859]

Full Text: Consultation response from Waldringfield Parish Council, 26/2/2015

Site Allocations and Area Specific Policies Local Plan Issues and Options Consultation Document

§1.16 & §1.17 "This Plan (or Neighbourhood Plan should Martlesham continue to progress with one) will need to consider need to consider the relationship between this strategic development and the surrounding area".

But Martlesham's Neighbourhood Plan specifically excludes Adastral Park (on the insistence of SCDC) so it cannot fulfil the role described above. Surely it is the intention of SCDC to produce the Martlesham, Newbourne & Waldringfield Area Action Plan (as described in the Core Strategy's policy SP20), which will do this, but the Martlesham, Newbourne & Waldringfield Area Action Plan isn't mentioned in anywhere in this document (see below). This is important as it is in contradiction to what is specifically stated in SCDC's Approved Core Strategy, for example:

"... the development [Adastral Park] will be progressed as part of the Martlesham, Newbourne and Waldringfield Area Action Plan to deliver a high quality exemplar development built to the highest environmental standards. It offers the opportunity to create a high quality legacy development in very much the same way as the Martlesham Heath village ..." (CS, July 2013, §4.15, our emphasis)

Following the EIP and the Inspector's comments, Policy SP20 was amended to read: "The Strategic approach to development in the Eastern Ipswich Plan Area can be divided into 3 sections - the area to be covered by the Martlesham, Newbourne & Waldringfield Area Action Plan; the main urban corridor of Kesgrave, Grange Farm, Martlesham and Rushmere St Andrew; and the smaller settlements and countryside which surround these core areas."

The paragraph then continues: "The strategy for the Martlesham, Newbourne & Waldringfield Area Action Plan is one:" [12 points are then described in some detail] (CS, July 2013, SP20, p70, our emphasis)

§1.19 The ignoring of the Policy commitment to the Martlesham, Newbourne & Waldringfield Area Action Plan is in stark contrast to the Felixstowe Peninsula Area Action Plan which is referred to extensively, for example:

"[the Felixstowe Peninsula Area Action Plan] will be prepared in parallel with this Plan and at every stage, consulted upon jointly to provide a consistent and comprehensive approach to the process of site selection, allocations and policy development across the District"

To prematurely proceed with any major planning applications in the area covered by the Martlesham, Newbourne & Waldringfield Area Action Plan would ignore the many reasons given (such as those quoted above) for producing the Felixstowe Peninsula Area Action Plan before determining relevant planning applications.

§3.12 Table 1 (p14): EIPA figures: CS 2010 min target = 2,320. Sub-total (completions + outstanding permissions + s106 agreements) = 623 Residual requirement = 2,000

Surely the residual requirement should be 2,320-623=1,697. This is how the other areas' residual requirements have been calculated, e.g. Market Towns: 1,520-1,024=496, Key & Local Service Centres: 1,300-1,137=163. In other words, according to SCDC's own figures, there is only a requirement for 1,697 houses at Adastral Park. Table 1 should be changed to give a Residual housing requirement 2014-2027 in the EIPA column of 1,697 (not 2,000).

§3.25 Q5. Thinking about your own community, the people who live there, the people who would want to live there but maybe can't because there is nowhere suitable - what type and mix of housing do you think is most needed to meet your community's needs? Do you have any evidence which would support your comments and which could help support this Local Plan document as it progresses? An example might be an up to date parish plan.

In Waldringfield, the main need is for smaller, 1 or 2 bedroom homes. Recent new developments in the Parish have included only 4 and 5 bedroom detached houses. The situation is further exacerbated when the existing smaller homes, former HA and privately owned properties, are sold and new owners substantially increase the size of the property. In the Waldringfield Parish Plan Survey, conducted in the summer of 2014, parishioners were asked: "If you need alternative accommodation now or within the next five years, would you want to stay in Waldringfield? If yes, what type of accommodation will you need?" The overall need was low but of the individual residents who answered "yes" to the first part, the majority wanted a 1 or 2 bedroom home to buy/rent.

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§3.34 Q7. Using the Map Booklet, for your village/town do you think the boundary line as it currently exists as shown on Map 1 needs amending? A small amendment is needed.

Q8. For your village/town do you think the changes suggested on Map 2 are sensible and would you support them? Waldringfield Parish Council is content with the minor modifications to the village envelope shown in this map.

Q9. Would you want to suggest an alternative alignment to that set out in Map 2? If yes, please provide details and reasons. No

§5.20 Q28. Are the Biodiversity Action Plan, local ecological networks, priority habitats and priority species given sufficient policy coverage? No. Insufficient attention is given to the preservation and improvement of lowland heathland, which (according to the BAP) is an important and endangered habitat. The same applies to the Deben Estuary, particularly the saltmarsh. Insufficient attention is given to the pressure on the Deben SPA caused by significant increase in visitor numbers from the proposed housing in the EIPA/IPA.

General There is no mention anywhere in the document of the proposed Martlesham, Newbourne & Waldringfield Area Action Plan. This is referred to in many places in the Core Strategy (e.g. CS July 2013, §4.08, §4.14, §4.15, §4.16, §4.18, §4.27) and a detailed description of what it will contain is given in SP20 (p70)). It was also referred to by the Planning Inspector (Report to Suffolk Coastal District Council by Mike Moore, June 2013, §42, §75 & §92) and formed a major part of Main Modification 22 to the CS, as required by the Inspector. In SP20 a 12-point strategy for the Martlesham, Newbourne & Waldringfield Area Action Plan is described (CS, July 2013, p70), and it is clearly intended that it should provide guidance for any planning decisions that come before SCDC's Planning Committee, so it is obvious that the Area Action Plan needs to be in place before any major planning applications are determined. To do otherwise would make the Area Action Plan irrelevant.

Felixstowe HMA booklet p2 Map The area marked 'East of Ipswich Plan Area' is confusing. According to the Core Strategy the EIPA contains the area covered by the Martlesham, Newbourne & Waldringfield Area Action Plan (CS, July 2013, p70), which in turn contains all of Waldringfield Parish (CS, July 2013, Map 4, p139). The logical conclusion is that Waldringfield Parish is within the EIPA, but the map shows it to be outside the EIPA, and in the Felixstowe Area. It would be helpful if these apparent inconsistencies were explained.

p5 & p6 Maps See comments on Q7 and Q8, above.

p7 (Map) & p8 (Table 1) Waldringfield Parish Council agrees that the 3 sites (554, 960 and 961) are not suitable for development, for the reasons given in the table.

Draft Sustainability Appraisals East of Ipswich Plan Area (EIPA) Housing Market Sub-Area, December 2014: This document strangely contains no references to Adastral Park, i.e. the largest allocation in the EIPA, by far. Summary: The area marked 'East of Ipswich Plan Area' is confusing. According to the Core Strategy the EIPA contains the area covered by the Martlesham, Newbourne & Waldringfield Area Action Plan (CS, July 2013, p70), which in turn contains all of Waldringfield Parish (CS, July 2013, Map 4, p139). The logical conclusion is that Waldringfield Parish is within the EIPA, but the map shows it to be outside the EIPA, and in the Felixstowe Area. It would be helpful if these apparent inconsistencies were explained.

Change to Plan

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Attachments:

S - 6169 - 2674 - Martlesham & Martlesham Heath - None 6169 Support East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Viridor (Mrs Mandeep Jutley) [2674] Agent: N/A

Full Text: I write on behalf of Viridor Waste Management, to set out representations to the Suffolk Coastal District Councils' Site Allocations and Area Specific Policies Issues and Options Consultation.

Background

Viridor is one of the UK's leading resource and waste management companies, and is part of the FTSE 250 Pennon Group pie. Viridor has freehold and lease hold interests in over 240 sites and facilities around the UK to provide a range of waste management solutions. Facilities operated and managed by Viridor include landfills, household waste recycling centres, materials recycling facilities, waste transfer facilities, and energy from waste facilities.

Foxhall Site and Planning History

Part of the Foxhall Landfill site, as outlined on the attached plan, is owned by Viridor . Part of the site is leased to Suffolk County Council, possibly until 2021. The site is located a short distance to the South-West of the Adastral Park.

The site currently benefits from planning permission for landfilling until 2019 with restoration to be completed by 2021. However, the volume of waste arriving at the site has significantly reduced over recent years. A planning application was submitted to Suffolk County Council at the end of 2014 seeking revisions to the approved restoration of the site, to deliver a lower level site with imported inert material.

There are a number of waste related operations which benefit from planning permission at the wider site, including green waste composting, waste transfer facilities and an asphalt plant. All these facilities benefit from temporary permissions which require the removal of infrastructure and restoration by March 2021, or sooner .

Suffolk Waste Core was adopted in 2011, to over the period to 2026 . The Foxhall Landfill site is identified as Site W17 with a potential to provide additional non•hazardous landfill capacity within the exiting footprint of the landfill site. However, the volumes of waste arriving at the site do not reflect the need for more capacity; this is partially due to increased recycling in line with government policy.

Employment Land Need

The Adopted Core Strategy (2013) sets out in strategic terms the Council's overall approach to future development for the period to 2027. Policy SP5 recognises that there is a need across the district to identify some 8.5 ha of new employment land. We note that the current planning application encompassing Adastral Park would deliver 6ha of new employment land, if approved. Although this would go some way to meeting the employment land need, there would still be a significant shortfall.

Within the Employment Land Availability Study 2014 it is unclear whether any of this shortfall has been met by some of the permissions granted since the adoption of the Core Strategy, or wither the extension of Ransomes Europark would achieve this. It is also unclear when in the plan period this new employment land is needed. It would be useful to have clarification on these matters.

Policy SP5 supports the retention and expansion of the Strategic Employment Areas. This includes Martlesham Heath Business Campus as a high-tech business cluster, building on BT's research and development headquarters at Adastral Park. It is clear from the Policy that the intention of this is to specifically encourage the location of other high tech information, communication and technology sector businesses in this area that would benefit from co-existence over other more general uses.

Elsewhere across the district, Policy SP5 recognises there are a number of employment areas that are significant at the district level. These are identified as General Employment Areas and the policy requires that the Site Allocations and Area Specific Policies Development Plan Document identify these. The suggestion of simply rolling forward the previously allocated site needs to be subject to a thorough review of existing land use and availability. We support the identification of additional sites as General Employment Areas.

Responses to Questions

Q12. What do you consider to be the main issues which need to be addressed to ensure the Martlesham site remains successful into the future? Q 13. Do you have a preference for any of the three suggestions listed? Or do you have an alternative suggestion which should be considered?

In order to create a successful ICT cluster, we suggest the larger site is identified as a Strategic Employment Site as proposed, with the policy wording focusing on ICT. There may be other employment uses (non-ICT) for which Martlesham is an ideal location, and therefore alternative sites should be identified, in close proximity to the Strategic Employment Site, to avoid dilution of the ICT cluster.

The Foxhall Landfill site is an ideal site for development as it has previously been developed. It is owned by Viridor, and

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can be available within the plan period. Part of the site has not been landfilled with waste and therefore does not have settlement issues. The use of the site for employment purposes would avoid the dilution of the ICT cluster vision for Adastral Park.

Q16. Are there any other sites that you would want the Council to consider as potential future employment sites to be allocated in this Local Plan document?

We request that the Foxhall Site be considered for employment purposes. Given the availability of this site within the plan period, the allocation would contribute to meeting the shortfall of employment land. Although there are sand martins known to occupy the sandy cliffs and stockpiles on the northern side of the quarry; they co• exist with the current operations at the site. We are confident that new infrastructure could similarly co-exist.

Way Forward

We welcome the opportunity to discuss this site with you further. We request to be kept informed of the progress of the Site Allocations and Area Specific Policies Document. Summary: The Foxhall Landfill site is an ideal site for development as it has previously been developed. It is owned by Viridor, and can be available within the plan period. We request that the Foxhall Site be considered for employment purposes. Given the availability of this site within the plan period, the allocation would contribute to meeting the shortfall of employment land. Although there are sand martins known to occupy the sandy cliffs and stockpiles on the northern side of the quarry; they co• exist with the current operations at the site. We are confident that new infrastructure could similarly co-exist.

Change to Plan N/A

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Attachments: Fox065 - A3 1-5000.pdf 3082_001_Redacted.pdf

C - 6173 - 483 - Martlesham & Martlesham Heath - None 6173 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

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

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

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

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

Site Allocations

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

Asset Encroachment

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

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

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

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

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

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

Sewerage Network

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

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

Surface Water and Flood Risk

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

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

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

C - 6173 - 483 - Martlesham & Martlesham Heath - None 6173 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

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

Engagement with developers

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

Anglian Water are keep to engage with Suffolk Coastal District Council on Local Plan consultations and on individual planning applications. Summary: 693: Significant off-site sewergae required to connect into CLQYSC. Pumping Stations, Sewers Crossing Site 900a: Sewers Crossing Site.

Change to Plan

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

O - 6197 - 2470 - Martlesham & Martlesham Heath - None 6197 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: No Adastral New Town (NANT) (Ms Janet Elliot) Agent: N/A [2470]

Full Text: Ref: Issues and Options Consultation - (1) Site Allocations & Area Specific Policies and (2) Felixstowe Area Action Plan

I am choosing to respond via letter/email as my comments cut across all documents within the consultation.

My major concern is that the documents/maps contain a number of errors and appear to disregard the relevant Strategic Policies of SCDC's Approved Core Strategy.

The following are extracts from the Approved Core Strategy

a) Extracts from the Approved CS specifying the definition of IPA/EIPA

Page 5 of the Approved CS states "The Ipswich Policy Area was defined under the Regional Spatial Strategy, with specific boundaries and used as a vehicle for defining various policies, notably allocations for housing growth. In that formal sense it has ceased to exist along with the RSS. However it again is a matter of fact that the major regional centre of Ipswich is a fundamental part of the context for Suffolk Coastal District, and the interrelationships of commerce, shopping, transport, housing, recreation and many other matters are inextricably linked in a single entity. Accordingly, policies in Suffolk Coastal and the adjoining Borough and Districts must remain linked and mutually supportive. That situation is fundamental to a number of issues affecting the Core Strategy and it remains fully recognised where relevant. In order to avoid confusion, the term Ipswich Policy Area is no longer used. However the less formal recognition of a similar concept within the boundaries of Suffolk Coastal District is referred to in the Core Strategy as the Eastern Ipswich Plan Area." (my emphasis)

Page 66 of the Approved CS SP19 states in the introduction to the EIPA section "EASTERN IPSWICH PLAN AREA - includes those parishes within the Ipswich Policy Area (IPA) and those identified as within the proposed Martlesham, Newbourne and Waldringfield Area Action Plan"

Page 70 of the Approved CS SP20 states "Strategic Policy SP20 Eastern Ipswich Plan Area The strategic approach to development in the Eastern Ipswich Plan Area can be divided into 3 sections - the area to be covered by the Martlesham, Newbourne & Waldringfield Area Action Plan; the main urban corridor of Kesgrave, Martlesham and Rushmere St Andrew; and the smaller settlements and countryside which surround these core areas. The strategy for the Martlesham, Newbourne & Waldringfield Area Action Plan is one:

A list of features then includes the following

ii) where the planned direction of controlled growth is eastwards of the A12 to the south and east of Adastral Park; x) that preserves and enhances environmentally sensitive locations within the Eastern Ipswich Plan Area and its surroundings; So, the above extracts from the Strategic Policies of the CS clearly define the IPA as the old definition used in the RSS which has subsequently been replaced by the larger area defined as the EIPA. In all the policies the EIPA includes the original IPA area and the area covered by the Martlesham, Newbourne & Waldringfield Area Action Plan.

It also says of course that the term IPA will no longer be used but then goes right ahead and continues to use the term as a shorthand/lazy way to describe the "urban core" section of the EIPA, but I am not commenting on the inconsistencies within the CS in this consultation response.

b) Extracts from the Approved CS specifying the role to be played by the Martlesham, Newbourne and Waldringfield Area Action Plan in progressing the development at Adastral Park.

SP19 states "4.15 the development (Adastral Park) will be progressed as part of the Martlesham, Newbourne and Waldringfield Area Action Plan to deliver a high quality exemplar development built to the highest environmental standards. It offers the opportunity to create a high quality legacy development in very much the same way as the Martlesham Heath village has become.

4.16 given the scale and potential impact of a development of this scale (both housing and employment) it will be the subject of an Area Action Plan which looks beyond just the site specific issues but takes on board the wider impact of change. The Core Strategy has been subject to Sustainability appraisal and appropriate assessment both of which consider that the broad scale and distribution of development can be successfully mitigated. However, should the more detailed appropriate assessment of the Area Action Plan conclude that part of the Strategy cannot be delivered without adverse impacts on the Deben Estuary SPA which cannot be mitigated, then the Area Action Plan will only make provision for the level and location of development for which it can be concluded that there will be no adverse effect on the integrity of the SPA, even if this level is below that in the strategic allocation."

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So, the CS makes it very clear in the Strategic Policies that the Martlesham, Newbourne and Waldringfield Area Action Plan will play a crucial part in the progressing of the Adastral Park development in terms of ensuring a "high exemplar development" and determining whether the proposed scale of the development will have an adverse effect on the Deben SPA.

These points were also recorded and taken into account by Lords Justice Richards, Underhill and Briggs in the recent ruling in the Court of Appeal -NANT v SCDC.

However, all of the above have been ignored/contradicted in the Site Allocations & Area Specific Policies, the Felixstowe Area Action Plan and the accompanying maps. 1.The Martlesham, Newbourne and Waldringfield Area Action Plan is not mentioned in any of the documents/maps. 2.The area covered by the Martlesham, Newbourne and Waldringfield Area Action Plan, so clearly included in the EIPA has been removed from the EIPA in the Allocations & Area Specific Policies documents/maps. 3.The map contained in the EIPA HMA booklet has an area outlined and labelled as EASTERN IPSWICH PLAN AREA is incorrect. It is in fact the old and defunct area previously known as the IPA. 4. The map contained in the Felixstowe HMA booklet has an area outlined and labelled as EASTERN IPSWICH PLAN AREA is incorrect. It is in fact the old and defunct area previously known as the IPA. 5. Waldringfield & Newbourne are listed in the Felixstowe HMA but are excluded, quite rightly, from the Felixstowe Area Action Plan. 6. Neither Waldringfield not Newbourne are included in any Area Action Plan. The effect of these contradictions/inconsistency between the Core Strategy and the Site Allocations & Area Specific Policies is to show a disregard by SCDC of its own policies and a complete volte face on the stated commitment to the role to be played by the Martlesham, Newbourne and Waldringfield Area Action Plan in progressing the development at Adastral Park.

The current documents need to be rewritten to reflect the Strategic Policies in the Council's Approved Core Strategy. Summary: The Martlesham, Newbourne and Waldringfield Area Action Plan is not mentioned in any of the documents/maps. The area covered by the Martlesham, Newbourne and Waldringfield Area Action Plan, so clearly included in the EIPA has been removed from the EIPA in the Allocations & Area Specific Policies documents/maps. The map contained in the EIPA HMA booklet has an area outlined and labelled as EASTERN IPSWICH PLAN AREA is incorrect. It is in fact the old and defunct area previously known as the IPA. Neither Waldringfield not Newbourne are included in any Area Action Plan.

Change to Plan

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Attachments:

O - 6203 - 3367 - Martlesham & Martlesham Heath - None 6203 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr Ian Corneby [3367] Agent: N/A

Full Text: As a resident adjacent to the above proposal I wish to raise a few concerns.

Traffic Management.

With an additional 90+ homes being built I do not believe the current proposed access is viable. With each home having at least 1 car (often 2) there will be possibly another 150 vehicles (excluding visitors) that could be using the access way.

As it is, access from Fynn Road can be difficult due to parking in Seckford Road often reducing this to one lane especially at peak times for the Duke of York Public House additional parking. Access onto Old Barrack Road and consequently Ipswich Road is equally as difficult, this additional traffic will only compound the problem.

Why could the current access route to the football club not be blocked off and then access to the site taken of the mini roundabout to the south of the site?

Noise/anti-social behaviour.

With the proposed community building and parking being so close to my property I'm concerned about possible noise, anti-social behaviour in the car park late at night and security/privacy of my property. The 5m strip of land between my garden and the football club is on my deeds and this will need to be maintained. However, I'm also concerned it could be used as a dumping ground from this community building car park.

Is it possible to move the community hall to the South of the site and bring the public open space nearer the existing housing and away from the main road?

Impact on house value

My concern here is the impact that the affordable housing will possibly have on the area. Why is it acceptable to build only family homes in the proposed Melton site and not on this plot?

Who could I talk to about this issues please? Summary: With an additional 90+ homes being built I do not believe the current proposed access is viable. With each home having at least 1 car (often 2) there will be possibly another 150 vehicles (excluding visitors) that could be using the access way.

Change to Plan

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Attachments:

O - 6224 - 3373 - Martlesham & Martlesham Heath - None 6224 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Steve & Claire Boswell [3373] Agent: N/A

Full Text: We write with regard to the areas mentioned above and the potential development of them.

We feel that these sites are unsuitable for development for a number of reasons:

1) Access to the site is not suitable for increased traffic flow as it stands, and there are very limited options for improvements to this.

2) The impact of housing to the view/impression of Woodbridge as you approach from the south would be detrimental to its reputation as an historic market town.

3) Noise and light pollution would increase

4) Services/amenities could be pushed beyond limits

5) the number and type of housing proposed is not in keeping with the current site and we have been advised that it will adversely affect our house prices.

Thank you for your consideration of this matter and the points raised above. Summary: 900a: 1) Access to the site is not suitable for increased traffic flow as it stands, and there are very limited options for improvements to this. 2) The impact of housing to the view/impression of Woodbridge as you approach from the south would be detrimental to its reputation as an historic market town. 3) Noise and light pollution would increase 4) Services/amenities could be pushed beyond limits 5) the number and type of housing proposed is not in keeping with the current site and we have been advised that it will adversely affect our house prices.

Change to Plan

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Attachments:

O - 6243 - 3376 - Martlesham & Martlesham Heath - None 6243 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr David Rich [3376] Agent: N/A

Full Text: I am a resident of Fynn Road and would not wish to see the Woodbridge Town Football Club land developed for housing. The access via Seckford Hall Road and Fynn Road is already inadequate for the amount of traffic traversing it, particularly on home match days. The potential for over one hundred more dwellings will only exacerbate this situation, add to the noise issues in this area and will also be an eyesore as people approach Woodbridge along the A12.

If it is decided to develop this area it is imperative that alternative road access arrangements should be made, either from the A12 roundabout itself or the mini roundabout on Ipswich Road. The current access will not be able to handle the increased traffic flow and an alternative access system would have to be devised to allow builders onto the land before any development could begin. Summary: 900a:The access via Seckford Hall Road and Fynn Road is already inadequate for the amount of traffic traversing it, particularly on home match days. The potential for over one hundred more dwellings will only exacerbate this situation. If it is decided to develop this area it is imperative that alternative road access should be made, either from the A12 roundabout or the mini roundabout on Ipswich Road. The current access will not be able to handle the increased traffic flow and an alternative access system would have to be devised to allow builders onto the land before development could begin.

Change to Plan

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Attachments:

C - 6246 - 3377 - Martlesham & Martlesham Heath - None 6246 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mark & Claire Richardson [3377] Agent: N/A

Full Text: In response to the consultation on the Local Plan Issues and Options we would comment as follows:

Policy AP214 regarding the land at Ipswich Road/Sandy Lane Martlesham - We support the Council's view that this area, sitting between a Special Landscape Area and the AONB on the edge of the defined built up area of Woodbridge, should remain protected from development.

Site 453 - Martlesham: Land at and surrounding Bridge Farm, Top Street - we support the Council's view that this land should be protected from development to prevent coalescence of Woodbridge and Martlesham and to recognise that it does not have the transport infrastructure to support it as part of a sustainable community. Any such development would be prejudicial to both Woodbridge and Martlesham and would have a significant impact on the environmental sustainability of both a Special Landscape Area and an Area of Outstanding Natural Beauty.

Policy SP20 - Adastral Park - we support the proposed development to the south and east of Adastral Park. We believe that it delivers a critical mass of development as part of a sustainable community with the necessary supporting transport infrastructure that will: * Upgrade existing employment floorspace and support the creation of up to 60,000 square metres of new employment floorspace; * Create approximately 2000 new jobs; * Create a residential community of up to 2000 new homes; * Deliver comprehensive new infrastructure and services to serve the new residential community, including new education and healthcare provision, public transport, shops, leisure and sports facilities and public spaces; * Provide a hotel to cater for business, visitors and tourists; * Provide an on-site energy centre to provide renewable heat and power reducing dependency on the national grid; * Utilise and improve the existing transport infrastructure including improved A12 access; and * Achieve an expansion of University presence at Adastral Park. Summary: Site 453 - Martlesham: Land at and surrounding Bridge Farm, Top Street - we support the Council's view that this land should be protected from development to prevent coalescence of Woodbridge and Martlesham and to recognise that it does not have the transport infrastructure to support it as part of a sustainable community. Any such development would be prejudicial to both Woodbridge and Martlesham and would have a significant impact on the environmental sustainability of both a Special Landscape Area and an Area of Outstanding Natural Beauty.

Change to Plan

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Attachments:

C - 6262 - 2963 - Martlesham & Martlesham Heath - None 6262 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Suffolk Coastal District Council (SCDC Agent: N/A Environmental Protection) [2963]

Full Text: LOCAL PLAN ISSUES AND OPTIONS CONSULTATION FELIXSTOWE AREA ACTION PLAN ISSUES AND OPTIONS DOCUMENT AND SITE ALLOCATIONS AND AREA SPECIFIC POLICIES ISSUES AND OPTIONS DOCUMENT

Head of Environmental Services and Port Health - Environmental Protection Comments

Thank you for your consultation regarding the above.

Further to my Memorandum dated 18th February 2015, please find comments regarding air quality matters detailed below.

Due to time constraints I have focussed on those SHLAA sites identified as 'suitable' at this time. Any other sites which come into play in the future, or any 'suitable' sites where different information comes forward, will need further input from Environmental Protection regarding air quality.

For any areas where there are a number of smaller applications (where they are under 0.25ha) the cumulative impacts on traffic flows will need to be taken into account. This also applies to any areas where there are both larger 'suitable' developments and smaller applications in proximity.

I understand that at the next stage of your process, as sites are firmed up, Planning Policy could place a formal recognition on selected individual sites to advise that anyone looking to develop them would need to produce an air quality assessment to accompany any planning application. Air quality assessments should be undertaken using current guidance produced by Environmental Protection UK (EPUK) and the Institute of Air Quality Management (IAQM). I have identified some plots at this stage which would benefit from this, mentioned in the lists below, and would be looking at this in more detail during the next round of your Consultation. I am unsure whether there is also the possibility to place other requirements on certain sites (such as need to produce a green travel plan, to provide car sharing facilities, cycle racks, bus stops etc) in order to prevent worsening of air quality within AQMAs and at any other locations which may be in danger of breaching the air quality objectives in the future should traffic flows increase? I would like to explore this further with you for the next round of Consultation.

Felixstowe Peninsula Area Action Plan

There is an AQMA declared at the Dooley Inn PH, Ferry lane, Felixstowe - close to Dock Gate 2 roundabout. This AQMA has been declared for annual mean levels of nitrogen dioxide due to emissions from and associated with the port of Felixstowe, including traffic on local roads. Any additional traffic produced in the vicinity of Dock gate 2 roundabout and Ferry Lane is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA and this should be considered when determining planning applications.

The Plan discusses a Felixstowe Logistics Park, to be developed by the Port of Felixstowe on sites within the perimeter of the Port. Any sites to be developed by the Port as part of this would need an air quality assessment to determine any impact on nitrogen dioxide levels within the declared Air Quality Management Area (AQMA) at Ferry Lane. My recommendation would be for the Port to make use of Dock Gate 1 over Dock gate 2 for access as this would keep additional traffic away from the AQMA.

Paragraph 6.9 of the Felixstowe Peninsula Area Action Plan discusses the declared AQMA at Ferry Lane, Felixstowe. It states that '... through the continued monitoring of the AQMA, the Council has the ability to ensure that Air Quality within these areas is not to the detriment of the environment or public health.' The continued monitoring of nitrogen dioxide levels within the AQMA allows us to determine what the levels are and whether they are increasing, decreasing or static, it does not in itself actually enable us to ensure that air quality is not detrimental. This is tackled by the statutory Air Quality Action Plan which has been produced for the AQMA - the aim of which is to protect Public Health only. Air quality affecting 'the environment' itself is not covered or tackled by the Local Air Quality Management process but will obviously be positively impacted upon.

Felixstowe and Trimleys * 451g - this borders the A14 and an air quality assessment would be required if this site was developed. A buffer zone alongside the A14 and Candlet Road should be considered in order to protect housing in the new development from being exposed to poor air quality. * 936 - this borders the A14 and an air quality assessment would be required if this site was developed. A buffer zone alongside the A14 and Candlet Road should be considered in order to protect housing in the new development from being exposed to poor air quality. * Sites 936, 383a, 451b, 451c, 451d, 383b, 383f, 451f and 607 within the Trimleys will need to have cumulative traffic effects considered with regard to air quality. Traffic from these sites travelling into Felixstowe using the route via High Street Trimley and not the A14 needs to be calculated and air quality impacts at the junction of High Road West and Garrison Lane will need to be determined. This junction has in recent times become more congested along the Trimley High Road West arm at peak times.

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* Un-numbered 'unsuitable site', Dock Gate 1/Haven exchange roundabout. I realise that this site is marked as 'unsuitable' anyway but I need to make a specific comment here as if this site were to have housing it could introduce receptors to an area likely to be above the Objectives and become an AQMA. This would be due to the closeness to a heavily trafficked area.

Site Allocations and Area Specific Policies

Q12 asks 'What do you consider to be the main issues which need to be addressed to ensure the Martlesham site remains successful in the future?'. This area, including the A12, has changed considerably in recent times in terms of traffic with the introduction of the retail outlets Next, Pets at Home and M&S Food. Any future decisions regarding sites in this area will need to take account of current traffic flows and provide information on air quality impacts. In recognition of the latest court decision regarding the application for the BT site at Adastral Park, previous comments submitted by the Environmental Protection Team continue to apply, and it is important that any air quality assessments undertaken historically for this application are updated accordingly.

Q29 asks 'should there be further reference to AQMAs ?' Yes I do, and I am happy to work with you to determine what exactly needs to be included. Some initial thoughts are:

* Advising that the spatial planning system has an important role to play in improving air quality and reducing exposure to air pollution, both through the development of local planning policy and the determination of individual planning applications. * Possibly reference to each of the 3 AQMAs in respect of which Towns/Parishes could impact negatively on them through traffic increases. * Declaration of an AQMA does not mean there will be a complete ban on development within or close to that area. Rather it means that greater weight must be given to the consideration of air quality impacts and their mitigation from any developments. * Information regarding the production of Action Plans for each of the AQMAs which have measures included to try and reduce the pollutant of concern. * Statement to the effect that the Area Action Plans and any Neighbourhood Plans produced should be working in conjunction with the official Action Plans for each AQMA.

East of Ipswich Housing Market Sub-Area

Martlesham * 900a and 703 - there appears to be a buffer between the A12 and the housing to the north of this site. Consideration should be given to a similar buffer on this site so that new houses are not exposed to poor air quality. An air assessment would be required if this site was developed with specific reference to impacts on the Woodbridge AQMA.

* Adastral Park - previous comments submitted by the Environmental Protection Team continue to apply. It is important, however, that any air quality assessments undertaken historically for this application are updated accordingly due to the recent changes in traffic flows in this area.

Framlingham Housing Market Sub-Area

Framlingham * As Framlingham is to produce a Neighbourhood Plan there is no detail regarding specific sites here. It will be necessary as part of that plan to ensure that there are no air quality implications from cumulative traffic related to developments in Framlingham.

Saxmundham Housing Market Sub-Area There is an AQMA declared at Long Row on the A12 in Stratford St Andrew. This AQMA has been declared for annual mean levels of nitrogen dioxide due to emissions from traffic on the A12. Any additional traffic produced from housing which would use this area of the A12 is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA and this should be considered when determining planning applications.

Stratford St Andrew * The suggested housing allocation is 0-10 but no SHLAA sites have been submitted or considered. Any sites for housing that would be exiting onto the A12 close to the declared AQMA (even if only for 1 or 2 houses) should consider air quality implications for the AQMA. This would not necessarily be in terms of numbers of vehicles but in terms of any traffic congestion they may cause in or near to the AQMA when entering/exiting onto the A12.

Saxmundham * 1006 and1009 - these sites are likely to use Church Street and its traffic lit junction with High Street, South Entrance and Chantry road. Traffic and congestion on Church Street and at this junction has increased in recent years due to the development of Waitrose, Tesco and other local retail outlets. These applications will need to have cumulative traffic effects considered and air quality impacts at the junction and on Church street will need to be determined.

Leiston

C - 6262 - 2963 - Martlesham & Martlesham Heath - None 6262 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

* As Leiston is to produce a Neighbourhood Plan there is no detail regarding specific sites here. It will be necessary as part of that plan to ensure that there are no air quality implications from cumulative traffic related to developments in Leiston as the suggested allocation is 250-500. Any development will need to specifically include air quality impacts from cumulative effects of traffic generated by the construction of Sizewell C Power station once that application has been submitted.

Woodbridge Housing Market Sub-Area There is an AQMA declared within Woodbridge at the traffic lit junction of Lime Kiln Quay Road/Thoroughfare/St John's Street/Melton Hill. This AQMA has been declared for annual mean levels of nitrogen dioxide due to emissions from traffic using the junction. Woodbridge is the nearest shopping centre for a number of nearby Parishes (including those on the Peninsula), and the most likely route for traffic travelling from those parishes to the North and North-East into the shopping area is along the B1438 and through the declared AQMA. Any additional traffic produced by these parishes is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA in Woodbridge and this should be considered when determining planning applications.

Woodbridge * There are no 'suitable' sites for housing located within Woodbridge. There are a number of 'unsuitable sites' and smaller sites (less than0.25 ha) which could send additional traffic through the declared AQMA due to their location (459, 4169, 72361 and 5722). These will therefore have a negative impact on the AQMA and this should be considered. The same would apply for any windfall sites within Woodbridge which could put additional traffic through the AQMA.

Melton * As Melton is producing a Neighbourhood Plan there is no detail regarding specific sites here. Woodbridge is the nearest shopping centre to Melton, and the most likely route for traffic travelling from Melton into the shopping area is along the B1438 and through the declared AQMA. Any additional traffic produced by Melton parish is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA in Woodbridge and this should be considered.

Rendlesham * 350 (includes 676) and 754. Traffic accessing Woodbridge, one of the nearby shopping centres for Rendlesham, will do so along the B1438 and through the declared AQMA. Any additional traffic produced by Rendlesham parish is therefore likely to have a negative impact on nitrogen dioxide levels within the declared AQMA in Woodbridge and this should be considered. Summary: 900a and 703-there appears to be a buffer between the A12 and the housing to the north of this site. Consideration should be given to a similar buffer on this site so new houses are not exposed to poor air quality. An air assessment would be required if this site was developed with specific reference to impacts on the Woodbridge AQMA.

Adastral Park-previous comments submitted by the Environmental Protection Team continue to apply. It is important that any air quality assessments undertaken historically for this application are updated accordingly due to the recent changes in traffic flows in this area.

Change to Plan

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Attachments:

C - 6303 - 3379 - Martlesham & Martlesham Heath - None 6303 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr Michael Meras [3379] Agent: N/A

Full Text: I agree with the views shown. Specially re Dukes Park. So preserving the green belt between Woodbridge and Martlesham.

Summary: I agree with the views shown. Specially re Dukes Park. So preserving the green belt between Woodbridge and Martlesham.

Change to Plan

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Attachments:

S - 6317 - 3363 - Martlesham & Martlesham Heath - None 6317 Support East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr Tim Passmore [3363] Agent: Carter Jonas LLP (Mr Richard Seamark) [3013]

Full Text: SITE ALLOCATIONS AND AREA SPECIFICS DPD: ISSUES AND OPTIONS DECEMBER 2014 CONSULTATION (SUFFOLK COASTAL DISTRICT COUNCIL)

Submission of representation in support of residential-led redevelopment of Martlesham Police Headquarters and associated land On behalf of the Police and Crime Commissioner for Suffolk February 2015

1. Overview 1.1 Carter Jonas has been instructed by the Police and Crime Commissioner for Suffolk ("PCCS") to submit a written representation in response to the Site Allocations and Area Specifics DPD: Issues and Options (December 2014) consultation ("draft Site Allocations"), as prepared by Suffolk Coastal District Council ("the Council"), in order to safeguard the residential development opportunity of land at buildings at Martlesham Police Headquarters, if required at a future date. 1.2 A site plan of the land under consideration, consisting of 9.9 hectares within the sole ownership of the PCCS as shown in red ('the Site'), is provided in Appendix 1. An additional 1.6 hectares is also within the sole ownership of the PCCS, as shown in blue, which includes a Police Investigation Centre building ("PIC") and its associated curtilage, which has been recently constructed through public/private funding. The blue line also includes an existing landscape buffer between the Site and the adjacent residential estates of Squires Lane, Peel Yard and Stable Court. 1.3 A letter from the PCCS, attached in Appendix 2, confirms that currently no formal decisions regarding the long term retention, disposal or re-development of the Site have yet been made. Certain key policing functions are likely to be retained for the foreseeable future, including the PIC building and, potentially, a response base to continue the provision of high quality emergency services in this area. Where it is necessary to relocate other support functions, the PCCS is currently in negotiations to purchase alternative accommodation. Relocation and then disposal of the relevant parts of the Site could reasonably be progressed over the next two years. 1.4 Notwithstanding this, the PCCS wish to safeguard the option of releasing the financial potential of a large proportion of the Site through residential redevelopment so that if, at a future date, a disposal strategy is pursued, there is planning policy support to the principle of redevelopment for residential purposes. 1.5 It is therefore necessary for the PCCS to participate in the draft Site Allocations process, in order to assist the Council in devising emerging planning policy that is relevant to the Site and that can respond to a relocation and disposal strategy, should the PCCS take that decision in the future. At the appropriate time during the draft Site Allocations process, the PCCS will provide to the Council:

be reinvested into supporting Policing public services. 1.6 It is acknowledged that the draft Site Allocations process will be influenced by the Core Strategy and Development Management Policies DPD (July 2013) ("Core Strategy"). Therefore, in terms of the current planning policy context, the Site lies within Martlesham Heath, which is identified within the Core Strategy as a Major Centre, given its inclusion in the Eastern Ipswich Plan Area ("EIPA"). 1.7 It is envisaged that 2,320 new homes will be created within the EIPA between 2010 and 2027. This includes the 2,000 new homes as a single allocation to the south and east of Adastral Park. An Area Action Plan will be required for this site, which will need to be the subject of a detailed Appropriate Assessment. In the event that this concludes that the scale of development cannot be delivered without adverse impacts upon the Deben Estuary Special Protection Area, which cannot be mitigated, then the Area Action Plan will only make provision for what is considered to be an appropriate level and distribution of development that avoids such adverse impacts occurring. Accordingly, it is considered necessary for the Council to make provision within the draft Site Allocations for the possibility that a lower level of development may occur within the single allocation. It is not clear whether the draft Site Allocations has identified a fallback position in the event that the single allocation for 2,000 new homes is required, and clarification is sought in this regard. 1.8 There is also recognition within the Core Strategy (paragraph 4.17) that 'longer term, it is likely that additional housing will need to be provided. The Council is committed to an early review of the plan commencing with the publication of an Issues and Options document by 2015 to take account of new census information and an updated assessment of the economic situation at that time, as well as an assessment of the infrastructure capacity, particularly the Orwell Bridge and that of the local environment. Such development will be directed to locations which best meet the assessed needs and longer term objectives at that time'. It is not clear whether the draft Site Allocations has taken account of the new census information, an updated assessment of the economic situation, or an assessment of infrastructure capacity, and clarification is sought in this regard. 1.9 Paragraph 3.9 of the draft Site Allocations states that 'the sites identified within the SHLAA (Strategic Housing Land Availability Assessment) provide the starting point for discussions on site selection. Through the Issues and Options consultation there is opportunity (within the bounds of the Core Strategy) to select those which are favoured by residents, local communities and stakeholders. Alongside these SHLAA sites there may also be alternative sites which the Council has yet to consider. Should you be aware of any further sites which you think ought to be considered then please let us know by responding to the Issues and Options Consultation'. 1.10 Whilst the Site was not submitted for consideration during the Call for Sites/SHLAA process it still remains acceptable now to promote the suitability of the Site for residential-led redevelopment. This representation therefore

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now seeks an assessment of this Site by the Council to consider its suitability, availability and achievability for residential-led redevelopment, and for the Council to undertake a Sustainability Appraisal of this Site for residential-led redevelopment so that it can then undertake an informed and meaningful assessment of the options available for the delivery of housing within its district. 1.11 It is considered that this Site, should the majority of it become available, offers high potential for delivering sustainable residential development, whether it is in the form of an allocation under any forthcoming adoption of the draft Site Allocations process, or with an appropriate policy framework in place where it could be later considered as a windfall. 1.12 The principle of residential-led redevelopment on the Site would be supported by a number of the 12 Core Planning Principles set out in the National Planning Policy Framework ("NPPF"), paragraph 17, particularly:

that it is not of high environmental value - the Site offers the opportunity for the Council to re-use land that is previously developed for residential purposes, thereby helping to reduce the reliance on greenfield development;

and deliver sufficient community and cultural facilities and services to meet local needs - the current operational use of the Site is currently under strategic review by the PCCS, and many of the existing functions may be relocated elsewhere within the district. If this disposal strategy is pursued, redevelopment of the Site for residential purposes would allow the disposal value of the Site to be optimised, thereby providing greater capital receipts to the PCCS for reinvestment into its local policing strategies. 1.13 Whilst this representation seeks to respond to the draft Site Allocations process that is being undertaken by the Council, it is also acknowledged that Martlesham Parish Council ("MPC") has made an application for the designation of a Martlesham Neighbourhood Plan Area Boundary. This is currently the subject of public consultation, through to the 9th March 2015. If the application is subsequently approved, formal representations would then be subsequently made on the PCCS's behalf to the Martlesham Neighbourhood Plan process. The PCCS has held preliminary discussions with MPC about potential relocation, disposal and redevelopment on part of the Site, and it would wish to continue engagement with MPC, at a more detailed level, if a decision is taken to pursue redevelopment.

2. Site and Context 2.1 The Site is physically contained within the village of Martlesham Heath, which developed in the late 1970s with environmental sustainability at the root of its origins. The village lies six miles to the east of Ipswich and with good communications including the A12 together with the A14 which run along the southern boundary of the village providing good access to Cambridge, the Midlands and London. Good vehicular and bus links are available to Ipswich town centre, train station, medical facilities and employment opportunities. Other nearby facilities include primary and secondary school provision and a number of recreation, leisure, retail and religious facilities. 2.2 Primarily a residential area, the village has a historical connection with innovation and hi-tech industry, research and development with the area once an aerodrome of the RAF. 2.3 Martlesham Heath Business Park and Adastral Park are both located within the village. Adastral Park is a world renowned centre for communications and information technology research supporting approximately 3,600 jobs and which in the last 20 years has supported up to 5,000 jobs on site. Adastral Park is BT's Global Research and Development Headquarters. It's also the home of 'Innovation Martlesham, a joint initiative by BT and Local Authorities to encourage ICT related companies to Co-locate, Collaborate and Innovate at the Park. 2.4 Numerous benefits exist to the local and regional economy, and it serves to complement the role of the adjoining Martlesham Heath Business Park. Martlesham Heath Business Park is located adjacent to the A12 dual carriageway in close proximity to Junction 28 of the A14. The estate, together with the adjacent retail park accommodates a variety of occupiers including DHL, Ladbrokes, Tesco and Jewson. 2.5 The proposed urban extension to Adastral Park is expected to create up to 60,000m2 of additional employment (B1) floorspace, 2,000 new homes, mixed-use local centre, education provision, hotel, and energy centre. 2.6 The Martlesham Heath Business Park, Adastral Park, and the proposed extension to Adastral Park, will collectively provide a strong strategic employment offer for the EIPA, which will result in the provision of a significant quantum of existing and new skilled jobs for the district. Furthermore, there is a food superstore and retail park within close proximity to the Site. Whilst the opportunity for alternative employment provision (to that of the existing Police operation) on the Site has not been dismissed at this stage, consideration will need to be given to whether there is market demand for further additional employment space in this location, whether there is retail capacity for additional convenience or comparison goods, whether such commercial or retail uses would be compatible with the existing surrounding residential estates, and whether the value created out of a disposal for employment and/or retail purposes would optimise capital receipts needed for the PCCS to reinvest into local policing public services. 2.7 The land use of the area surrounding the Site is considered to be predominantly residential. The residential estates off Eagle Way e.g. Squires Lane, Parkers Place lie in closest proximity to the south of the Site; Deben Avenue (accessed off A1214) is separated from the Site by a dense belt of landscaping; and a small number of semi-detached houses lie along Portal Avenue on the opposite side to the Site. The eastern boundary is characterised by the A12, and beyond this the commercial areas of Tesco and Adastral Park. 2.8 In terms of the Site itself, about 48% of the Site is built upon, with the remainder used for outdoor amenity e.g. football pitches, tennis court, established vegetation. All of these facilities are solely for the private use of the Police (and not for members of the public). 2.9 The scale of buildings within the Site range from single storey to 4 storeys (+ set back). 2.10 The Site takes its vehicular access from Portal Avenue, which then joins the A1214.

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3. Site Assessment 3.1 In terms of assessing the suitability of the Site for residential-led redevelopment, the methodology used in the Council's SHLAA (March 2014) has been used, where appropriate, as follows: Site/Broad Location Identification 3.2 The Site lies within the EIPA, which is one of the five district housing sub-markets identified by the Council. Site Size 3.3 The Site is 9.9ha, which is in excess of the minimum threshold of 0.25ha that has been applied by the Council to ensure that sites assessed have capacity for at least 5 dwellings. Site Identification 3.4 A large proportion of the Site is defined as previously developed land ('brownfield'). Suitability

Air Quality Management Area Not Applicable to Site Allotments Not Applicable to Site Areas of Outstanding Natural Beauty Not Applicable to Site Areas to be protected from development Not Applicable to Site Bat Sites Not Applicable to Site (this is not a designated 'bat site' - however a Phase 1 Habitat Survey would need to be carried out on the Site which may then recommend some species-specific surveys to be undertaken - this may include bat surveys TBC) Conservation Areas Not Applicable to Site Contaminated Land (public register) Not Applicable to Site (this is not an identified site for contamination - however, a Contaminated Land Survey would need to be carried out on the Site which may then recommend intrusive surveys, identification of pollutant linkages, removal and remediation if in the event contaminants are found) County Wildlife Site Not Applicable to Site Eastern Ipswich Plan Area Site lies within the EIPA Felixstowe Sea Frontage Not Applicable to Site Felixstowe Peninsula separation of town from Trimleys Not Applicable to Site Flood Zone 2 Not Applicable to Site Flood Zone 3 Not Applicable to Site Foxhall Road Woodlands Not Applicable to Site Heritage Coast Not Applicable to Site Historic Parks and Gardens Not Applicable to Site Listed Buildings Not Applicable to Site Minerals Consultation Area Not Applicable to Site Orchards Not Applicable to Site Protection of Open Space Not Applicable to Site - Open Space is not within public use Protection of Trees and Character Trees are present on the Site - the quality of individual/groups of trees will be assessed through an Arboricultural Survey and Impact Assessment Ramsar Sites Not Applicable to Site Regionally Important Geological Sites Not Applicable to Site Rights of Way Not Applicable to Site Roadside Nature Reserves Not Applicable to Site Schedule 9 Species Not Applicable to Site Scheduled Monuments Not Applicable to Site Sites of Special Scientific Interest Not Applicable to Site Sites of ornithological interest Not Applicable to Site Special Areas of Conservation Not Applicable to Site Special Landscape Areas Not Applicable to Site Special Protection Areas Not Applicable to Site Suffolk Wildlife Trust Consultation Area Not Applicable to Site Tree Preservation Order Not Applicable to Site

agricultural soils, and given its previously-developed status, redevelopment of the Site could assist in reducing the need to use best and most versatile agricultural soils elsewhere within the district (i.e. proposed greenfield allocations).

Availability 3.5 It is understood that the Site has no legal or ownership problems that would have the potential to jeopardise delivery of residential development. Given that a formal decision has not yet been made by the PCCS regarding relocation and disposal, at this stage it is considered that there is a reasonable likelihood that the Site could be developed within 5 years (deliverable).

Achievability 3.6 It is considered that there is a reasonable prospect that the Site will be redeveloped for housing and that this would provide the most viable and feasible form of alternative land use.

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Site Assessment Summary 3.7 It is considered that the Site has the potential to accommodate approximately 317 - 347 homes, based on a density of between 32 - 35 dwellings per hectare, which we believe is an appropriate density target for the location of the Site in the EIPA. It is considered that development could be delivered within 5 years. (See table in attached document)

4. Development Potential 4.1 The PCCS is currently in the process of reviewing the existing operations on the Martlesham Headquarters and, as a result of this review, it may decide to relocate many of its operations. In this scenario, the Site would be surplus and vacant, and the PCCS may then look to dispose of the Site in order to generate capital receipts that could be reinvested into improving local policing public services. 4.2 It is considered that this would provide an opportunity to redevelop the Site for residential use. The Site lies within a sustainable location, reflected by the fact that Martlesham Heath is categorised as a Major Centre and forms part of the EIPA. 4.3 Residential redevelopment of the Site could be supported by the presence of nearby retail (Tesco) and commercial base (e.g. Adastral Park, Martlesham Heath Business Park), which is due for further expansion. It is considered that the Council will prefer to focus commercial/retail opportunities on land to the east of the A12 rather than on the Site. The option for a new business park, leisure and/or retail park has not however been ruled out at this stage. 4.4 The surrounding area of the Site is predominantly of residential estates (especially to the south) and it is considered that additional residential development would therefore satisfy character considerations. 4.5 The Site is part-previously developed land, which will assist the Council in delivering its 12% target for housing on such land. 4.6 It is considered that the Site has a developable area of c9.9ha. Housing on surrounding estates is typically 2 storey in scale, detached/semi detached properties, with adequate private amenity and off-street parking provision. 4.7 Accordingly, a housing target of approximately 317 - 347 homes is considered appropriate (based on the opportunity for delivering homes in a sustainable location, such as a Major Centre (EIPA), a level of development that will conform the the character of the surrounding area, and the need to optimise site value so that capital receipts can be reinvested into securing the high quality policing public services in the locality). Approximately 1 in 3 new homes will need to be provided for affordable housing. 4.8 It is considered that main vehicular access would be taken from Portal Avenue, with precise position of access junction to be determined through later junction testing and transport assessment. 4.9 Feasibility and viability of development of this scale will need to be tested through detailed surveys and assessments, including infrastructure capacity, drainage, arboricultural, ecology, market appraisals etc. 4.10 A CIL contribution of £90 per sq.m is likely to be sought for redevelopment. Site specific S.106 matters may also be required, subject to later assessment.

Appendix A - Site Location Plan Appendix B - Letter from the PCCS Summary: The PCCS is currently in the process of reviewing the existing operations on the Martlesham Headquarters; as a result of this, may decide to relocate many of its operations. In this scenario, the Site would be surplus and vacant, and the PCCS may then look to dispose of the Site in order to generate capital receipts that could be reinvested into improving local policing public services. It is considered that this would provide an opportunity to redevelop the Site for residential use. The Site lies within a sustainable location, reflected by the fact that Martlesham Heath is a Major Centre

Change to Plan N/A

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

Attachments: Appendix B Letter from PCCS.pdf Response to Site Allocations and Area Specifics DPD Issues and Options D .pdf

O - 6385 - 3409 - Martlesham & Martlesham Heath - None 6385 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr Keith Manely [3409] Agent: N/A

Full Text: Proposed Development at Woodbrodge Town FC

My concerns with the current proposals for this development are:

1. Limited highway access. The only access now is via - Old Barrack Road and Seckford Hall Road. At busy periods there are problems because of traffic volume and permanent parking of resident's vehicles between Oxford Drive and Old Barrack Road in Seckford Road. The development proposed would more than double current traffic volumes. 2. Loss of amenity land and widely used community facility at WTFC club house. 3. Visual impact from Fynn Valley approach. 4. Potential noise impact Summary: Proposed Development at Woodbrodge Town FC

My concerns with the current proposals for this development are:

Change to Plan

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Attachments:

O - 6435 - 3418 - Martlesham & Martlesham Heath - None 6435 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Mr Nicholas Burden [3418] Agent: N/A

Full Text: I write to add my own objections against the proposed development of 2,000 homes between BT Adastral Park and the River Deben / Waldringfield.

As an Ipswich resident for nearly thirty years, I have seen a significant number of large developments adding traffic, reducing beautiful countryside and placing a massive strain on services. The greenfield site in question is an area of wildlife-rich countryside and outstanding natural beauty. It is also near or in a flood plain.

In addition there is a large number of brownfield sites still in the town of Ipswich.

I feel strongly that at least , the large number of homes planned for the proposed site needs to be reviewed carefully. Summary: I write to add my objections against the proposed development of 2,000 homes between BT Adastral Park and the River Deben/Waldringfield. I have seen a significant number of large developments adding traffic, reducing beautiful countryside and placing a massive strain on services. This greenfield site is an area of wildlife-rich countryside and outstanding natural beauty. It is also near or in a flood plain. In addition there is a large number of brownfield sites still in the town of Ipswich.

I feel strongly that at the large number of homes planned for the proposed site needs to be reviewed carefully.

Change to Plan

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Attachments:

O - 6485 - 3450 - Martlesham & Martlesham Heath - None 6485 Object East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

Respondent: Samuel & Maureen Simpson [3450] Agent: N/A

Full Text: Local Plan- proposed settlement classification Martlesham North Comments/objections on 766 Land at Gibraltar Farm, Martlesham

Further to my visit to your office earlier this week, and to my conversation with Mr. Mark Edgerley, I now submit in paper form our comments and objections to any possible housing development taking place on land at Gibraltar Farm.

1. Gibraltar Farm is outside of the village development boundary for Martlesham and is in the greenbelt, Greenfield site. The land slopes away dramatically from its entrance into Private Road and the incline has caused vehicle problems over the years, particularly in winter with vehicles having to be winched up the hill. 2. Private Road is as it says a private road and is only single track- shingle, rubble, soil- with no space for footpaths. 3. There are a total of eighteen properties using the most part of Private Road (from Mansard House to the A1214 road), and not only 18 vehicles but numerous sized families also using with vehicles- there is no way the road/track could sustain any further housing development. There have been problems with delivery and service vehicles blocking access for residential. Any development would seriously exacerbate the problem. 4. Gibraltar Farm was the subject of a planning application to build houses in the late 1980's (exact date not to hand) but this was refused because of various Private Road issues, including the state of the unmade private road. Since that time four new houses have been built- any more would create saturation point. 5. There are old and varied trees in the land (766) and at least one large oak probably around 200 years old- which I believe has been recorded in the 'Martlesham Tree Survey', and the area is rich in wildlife and at present the view from the Fynn Valley is not compromised. 6. An important aspect relating to Maple Durham is that the blue shaded area of 766- proposed land for housing development at Gibraltar Farm- on the website is incorrectly mapped. The track to the north of the Maple Durham hedge is included into this blue mapping, in fact completely up to our hedge. This does not belong to the owner of the land putting forward his land for future residential development, but to ourselves. It has been (and still is) used for access to and fro for the three properties to Maple Durham, Monterey Lodge and Bosmere House.

We have not been consulted by the owner of Gibraltar Farm regarding this mapping, and either have we given permission for this to happen.

The track has always been maintained by the occupiers of Maple Durham and for the past nearly 30 years by ourselves, including the grass cutting tending of flowers/shrubs and trimming of hedges.

We trust that the above factors will be taken into account when finally determining the outcome for Local Plan purposes: Your acknowledgement to this letter would be much appreciated. Thank you in anticipation. Summary: 766:Gibraltar Farm was the subject of a planning application to build houses in the 1980's but this was refused because of various issues, including the state of the unmade road. Since that time four new houses have been built- any more would create saturation point. There are eighteen properties using the most part of Private Road, and not only 18 vehicles but numerous sized families also using with vehicles-there is no way the road/track could sustain any further housing development. There have been problems with delivery and service vehicles blocking access for residential. Any development would seriously exacerbate the problem.

Change to Plan

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Attachments:

C - 6525 - 2581 - Martlesham & Martlesham Heath - None 6525 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

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

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

1. Introduction

2. Air Quality and Noise Assessment

3. Archaeology

4. Education (including Early Years)

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

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

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growth.

5. Health and Wellbeing

6. Libraries

7. Minerals and Waste Plans

8. Natural Environment

9. Public Rights of Way

10. Surface Water Management

11. Transport

12. Waste Provision

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

13. Water Management, Flood and Coastal Defences

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Appendix: Likely Archaeological Assessment Requirements

East Ipswich Plan Area

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

Framlingham

Saxmundham

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work.

Woodbridge

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

Woodbridge 900a - This site lies within an area of archaeological potential, and Neolithic pits and Iron Age features were excavated to the south (County Historic Environment Record MRM 030). The site should be subject to archaeological assessment at an appropriate stage in the design of new development to establish the impacts of past land-use, and ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Summary: There are a number of locations within Martlesham that are adjacent to the A12, which include 710, 479, 721, 644, 693, 517, 430. The bunding adjacent to the A12 at sites 517/430, provided initially to protect Martlesham Heath residents from mineral working noise, should be retained as it has been designed (it is high enough) to provide a good level of protection from road traffic noise for any new dwellings behind it.

Change to Plan

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Attachments:

C - 6527 - 2581 - Martlesham & Martlesham Heath - None 6527 Comment East of Ipswich Plan Area Housing Market Area Martlesham & Martlesham Heath

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

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

1. Introduction

2. Air Quality and Noise Assessment

3. Archaeology

4. Education (including Early Years)

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

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

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growth.

5. Health and Wellbeing

6. Libraries

7. Minerals and Waste Plans

8. Natural Environment

9. Public Rights of Way

10. Surface Water Management

11. Transport

12. Waste Provision

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

13. Water Management, Flood and Coastal Defences

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Appendix: Likely Archaeological Assessment Requirements

East Ipswich Plan Area

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

Framlingham

Saxmundham

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work.

Woodbridge

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

Woodbridge 900a - This site lies within an area of archaeological potential, and Neolithic pits and Iron Age features were excavated to the south (County Historic Environment Record MRM 030). The site should be subject to archaeological assessment at an appropriate stage in the design of new development to establish the impacts of past land-use, and ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Summary: Martlesham 900a. This site was covered under advice in 2008 for 703. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Change to Plan

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Attachments:

C - 5681 - 3225 - Purdis Farm - None 5681 Comment East of Ipswich Plan Area Housing Market Area Purdis Farm

Respondent: John & Anne Pickering [3225] Agent: N/A

Full Text: We wish to make formal comment as allowed during the period up to 27 February 2015 as set out in the above policy.

In the Map Booklet to accompany Issues and Options consultation on Site Allocations and Area Specific Policies Local Plan Document on Page 3, under the heading 'Settlements & Parishes with no maps', it states, with regard to Foxhall 'No physical Limits, no defined Area to be Protected from Development (AP28)'.

We believe that there is compelling evidence to contradict this statement with regard to 'no defined area to be protected from development' because a series of planning applications spanning at least the last 30 years have been rejected on the grounds that the applications would be contrary to the rural nature of the area due to the total absence of those community facilities normally to be found in a village. One of the rejections which was as recent as 2013, included the following sentence: 'the proposal would also set an unfortunate precedent for similar unacceptable developments, the cumulative impact of which would be to the detriment of the rural character and amenity of the countryside.'

In conclusion, we believe that Foxhall should be regarded as countryside and protected from development. Summary: We believe that Foxhall should be regarded as countryside and protected from development.

Change to Plan

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Attachments:

O - 5742 - 3251 - Purdis Farm - None 5742 Object East of Ipswich Plan Area Housing Market Area Purdis Farm

Respondent: HEM & JGR Bevan [3251] Agent: N/A

Full Text: SUFFOLK COASTAL DISTRICT LOCAL PLAN Core Strategy & Development Management Policies Consultation Process AREA OF INTEREST - HAMLET OF FOXHALL We OBJECT to the the statement 'FOXHALL IS NOT TO BE CLASSIFIED AS A PROTECTED ENVIRONMENT IN THE SITE ALLOCATION SPECIFIC POLICIES DOCUMENT' and believe that it should continue as at present reclassified as COUNTRYSIDE

Copies to SCDC Elected Representatives Cllrs Geoffrey Holdcroft, Tony Fryatt, Christine Block, Diana Ball, Chris Blundell, Stephen Buroughes, Mark Newton, Anthony Cooper Please forward to the Parish Council Elected Representatives Cllrs Oliver Morgan, Richard Jenkinson, Christopher Norrington, Lyn Jardine, Mel Bentley, Kevin Coe, Copy to SCDC Official Mr. P. Ridley East Area Planning Officer A Historic Perspective We welcome another opportunity to contribute to the debate on the future strategic ambitions of those to whom we delegate our custodianship of the district. We have lived in this Hamlet since 1976 and have tested the planning policies during that period with two applications for one dwelling on our 2.5 acre plot. The most recent 25 February 2013 (C13/0375) that was refused for the following reasons: '...... the land lies within the countryside ... the proposed new dwelling would be contrary to policy AP30 of the SCDCLP and to Policies SP1, SP19, SP29 and DM3 of the Pre Submission Core Strategy & Development management Policies Development Management Plan which provide that new housing should be integrated into physical limits boundaries of the settlements and impose severe restrictions upon such development in the countryside in the interest of agriculture, highways safety, the economy of services and rural amenity. The development is also not considered to be in accordance in the NPPF as it does not comprise 'sustainable' development. The proposal would also set an unfortunate precedent for similar unacceptable developments, the cumulative impact of which would be to the detriment of the rural character and amenity of the countryside' WE AGREE WITH THIS STATEMENT AS IT APPLIES TO DEVELOPMENT You might also be interested in the narrative given for refusal on 21 December 1984 12. 2. 19 IN THE INTEREST OF AGRICULTURE, RURAL AMENITY, ROAD SAFETY AND ECONOMY OF SERVICES, NEW HOUSING WILL BE INTEGRATED INTO TOWNS AND VILLAGES. IN RURAL AREAS, OUTSIDE THE TOWNS, MINOR CENTRES AND OTHER VILLAGES. IT IS INTENDED THAT EXISTING LAND USES WILL REMAIN FOR THE MOST PART UNDISTURBED AND, EXCEPT AS PROVIDED IN PARAGRAPHS 12.2.21 AND 12.2.13 PERMISSION WILL NOT NORMALLY BE GIVEN FOR NEW DWELLINGS. The Words 'SUSTAINABLE' and 'UNDISTURBED' need careful study rather than the 'fit all circumstances' that seems to apply in some planning applications. e.g Creating jobs in the building trade is a transitory and, in my view, short lived in small developments that must be set against the pressure caused to the infrastructure, services and transport etc. An officer of SCDC described Sustainability, recently, as 'development close to a built up area, accessible to shops, jobs, schools and health care facilities' - Only by car at FOXHALL! The Hamlet of Foxhall 1. There has been no increase in properties, in this Hamlet, for many years the changes mainly concentrating upon structural changes to existing properties. 2. There are no services, amenities, mains sewage (all houses have septic tanks or 'soak away') shops, community hall, church, public house, post office, school - that service is provided at Bucklesham Village (BV) Junior School and Secondary at Kesgrave High School. . 3. The current Bus service is poor and a bus to the Cattle Market Ipswich on Mon. Wed. Friday at 1000 hours, from the Shannon in BV, returning at 1240 hours from Ipswich. There are no services at weekends. The school buses ferry the children to BV and to Kesgrave High School unless, as is more the norm, they are ferried in parental cars. I envisage further disastrous pressures with any form of development in this Hamlet. 4. The village Junior School at BV is typical of late nineteenth and early twentieth century buildings. It is small and seems to be at maximum capacity (unchecked to verify). Any observer will note the multi car 'ferry' transport convoy of parents from 0830 to 0900 hours, 1200 hours for lunch and 1500 hours for 'pick up' at the end of the school day. The congestion on the road at the school is obvious and has increased considerably since we have lived here. 5. There has been a huge increase in activities at Trinity Park causing further pressures. 6. There are no pavements from Purdis Golf Course(PGC) to BV 7. There are no Street Lights from Purdis Lane to BV 8. Verges receive two 'flail' mowing annually and the hedges are a driving hazard The Hamlet of Foxhall is only accessible by car to these services that are some distance away. Most current households are 'two car families'. This causes increased pressures upon the Bucklesham Road(BRoad), Straight Road(SR) and Woodhouse Lane(WL) that also serve as 'rat runs' to Ipswich and Felixstowe and a 'slip road' when there are problems on the A12 and especially the A14 that seems to have increased considerably of late!! The following is an abstract from your consultative document: 'Suffolk Coastal is ranked 5th poorest out of 7 districts in Suffolk for overall access to services. The District is below the median (of Districts in Britain) for access to a bank or building society and in the bottom quartile for access to a Secondary school, doctor's surgery, post office or primary school'. The majority of the residents are retired - some would be classified as elderly. However younger families have arrived in the past few years. As an octogenarian I note and welcome the reference in the consultative document to:

O - 5742 - 3251 - Purdis Farm - None 5742 Object East of Ipswich Plan Area Housing Market Area Purdis Farm

'The focus of effort from all sectors should be to improve quality of life especially for vulnerable people including the growing population of older people' Para 4-03 pp60 Sustainable Development 'Whatever the size and location of a community too much development too soon or of the wrong type can damage the environment and local distinctiveness and thereby impact on people's quality of life'. We believe that development AT FOXHALL would cause irreplaceable damage. HAMLETS, COUNTRYSIDE AND OTHER VILLAGES (Settlement Policy SP 19 pp 62) Foxhall is no different to Brightwell some two miles distance apart. However Brightwell enjoy's a Village Hall and a Mediaeval Church minimum amenity needs for SCDC development. It is difficult to relate to the logic behind the designation of Brightwell Hamlet as COUNTRYSIDE and Foxhall Hamlet as OTHER VILLAGE that allows development at Foxhall while Brightwell is exempt despite the recent development within its boundaries. There is also the major development at ADASTRAL PARK that will be but a short distance from Brightwell. However it should also be classified as COUNTRYSIDE. PARISH COUNCIL The Parish Council for this Hamlet is the BRIGHTWELL, FOXHALL&PURDIS FARM GROUP PARISH COUNCIL. Parish Councils are local and have a greater ability to 'test the views of residents' as a first point of contact that can feed those views to and 'enrich' the other tiers of local governance. We therefore hope that PCs remain as at present. Knowledge of the Area We, who have lived here for very many years, have the necessary experience of the daily pressures upon this Hamlet, and beyond, based upon use and needs rather than upon some abstract narrative in reports that do not, necessarily, reflect what actually occurs daily and seasonally in this area e.g. no immediate access to essential services and meeting domestic needs such as shopping, access to a post office, garage facilities etc. If provided, through future developments, these must be set against the damage to the countryside. Since our 1984 application new estates have been built near Trinity Park land, multi properties added on existing sites along the BRoad, a development near the PGC (and the Club's constant traffic), the busy Bucklesham Grange Residential Home, a Caravan Park at Low House, infilling at BV that has increased traffic considerably and with deleterious consequences along the length of BRoad, SR and WL the latter two being mainly single tracks. Any further development will cause an increasing and impossible burden to further contribute to traffic along the BRoad and the grid lock that plagues Ipswich from all directions. Previous planning decisions, by SCDC and Ipswich Borough Council, have not assisted in relieving this major problem that, in my view will, only increase with the developments, at Adastral Park and the Ipswich Northern Fringe. Conclusion and Recommendations 1. We recommend that our present status, for NO DEVELOPMENT in this Hamlet, be safeguarded by classifying the Hamlet as a 'protected environment' and a COUNTRYSIDE AREA for the critical reasons cited in the foregoing. 2. Any housing provision should continue in towns, villages and non agriculture land while causing minimum disruption and pressure upon the environment, ecology, transport, infrastructure, essential services (easily accessible and capable of accommodating increases in population throughout the District)etc and, as a consequence, to the rural nature of the District and the County. 3. Parish Councils are an essential part of country life and must be retained with no interference from Neighbourhood Plans as suggested in the consultative document. We value this opportunity to contribute to the deliberations and wish team members success in their deliberations and conclusions on behalf of the electorate. Summary: We OBJECT to the the statement 'FOXHALL IS NOT TO BE CLASSIFIED AS A PROTECTED ENVIRONMENT IN THE SITE ALLOCATION SPECIFIC POLICIES DOCUMENT' and believe that it should continue as at present reclassified as COUNTRYSIDE We recommend that our present status, for NO DEVELOPMENT in this Hamlet, be safeguarded by classifying the Hamlet as a 'protected environment' and a COUNTRYSIDE AREA for the critical reasons cited in the foregoing.

Change to Plan

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Attachments:

C - 5799 - 2360 - Purdis Farm - None 5799 Comment East of Ipswich Plan Area Housing Market Area Purdis Farm

Respondent: Mr Geoff Hilton [2360] Agent: N/A

Full Text: Dear Member of the Planning Policy & Delivery Team. This response is to the Suffolk Coastal District Local Plan and the map booklet accompanying the Issues and Options consultation on the Site Allocations and Area Specific Policies, and in particular to the incorrect classification of Foxhall as an 'Other Village' settlement.

Foxhall as a Settlement in the Countryside Foxhall comprises a hamlet, clusters and solitary dwellings widely dispersed in rural surrounds without any, let alone few facilities. None of its dwellings are serviced by mains drainage and its roads and lanes are very largely without pedestrian sidewalks and are unlit. Its character is of a settlement spread within a green landscape between Purdis Farm and the A12 comprising hedgerow lined roads, agricultural land, the Suffolk Showground and footpaths giving access to woodland and the Sandlings path. Foxhall hamlet comprises 28 properties spread along a half mile stretch of Bucklesham road around the small hamlet green at the crossroad with Woodhouse Lane and Straight Road and is bounded to the south by Suffolk Showground land and Home Farm, and to the north by Home Farm. A further two dwellings are sited 0.3 mile further east along Bucklesham Road and aside from those on Felixstowe Road on the other side of Trinity Park to the hamlet, the few other dwellings are dispersed on Woodhouse Lane, Purdis Road, Monument Lane and Hall Road. The residents of Foxhall are poorly served by Public transport, this being confined to limited Bus services on Felixstowe Road to the south and a very limited (4 times daily) service along Bucklesham Road, the scheduling of which does not allow sustained 9-5 employment in Ipswich, or Woodbridge. The only businesses within its boundary affording employment, are Home Farm and the refuse disposal/recycling site to the north east at the junction of Foxhall Road and the A12. Accordingly, the correct classification of Foxhall is of a settlement within the Countryside and that's not only how the residents see it. Suffolk Coastal District Council has consistently rejected applications for building single dwellings within existing plots on the grounds 'that they would set an unfortunate precedent for similar unacceptable developments, the cumulative impact of which would be to the detriment of the rural character and amenity of the countryside.' The emphasis on 'detriment of the rural character and amenity of the countryside' has characterised all of the council's rejections of such applications within Foxhall. Moreover the applications have been refused because (and to quote) 'they would add an additional dwelling unit to the existing group which is isolated from any communal facilities. Public transport is virtually non-existent and private cars are needed to reach places of employment, school, church, shop, post office etc. or for leisure and recreational facilities. This would entail the use of Class III or unclassified roads and the area is clearly unsuitable for additional residential development...' In strongly refusing such applications the grounds above cited by Suffolk Coastal District Council are precisely those which describe a settlement in the countryside. Accordingly, the Site Allocations and Area Specific Policies of the Suffolk Coastal District Local Plan need to be revised to reflect the status of Foxhall as a settlement in the countryside. ______Context and purpose of this representation In making this response we are aware that the process for review and changes to the Settlement Hierarchy is a matter for review of the Core Strategy but it represents the view of the residents listed on the front page and undoubtedly many of those we have yet to trawl. In that respect its status is that of an initial representation but one which reflects a strongly held view of the local community. Its purpose is twofold i.e. to ensure that the Planning Policy & Delivery Team is aware of our view, and to deposit a placeholder into the consultation process. Please receive it in that light. Summary: The correct classification of Foxhall is of a settlement within the Countryside and that's not only how the residents see it. Suffolk Coastal District Council has consistently rejected applications for building single dwellings within existing plots on the grounds 'that they would set an unfortunate precedent for similar unacceptable developments, the cumulative impact of which would be to the detriment of the rural character and amenity of the countryside.'

Change to Plan

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Attachments:

C - 6130 - 2360 - Purdis Farm - None 6130 Comment East of Ipswich Plan Area Housing Market Area Purdis Farm

Respondent: Mr Geoff Hilton [2360] Agent: N/A

Full Text: Dear Member of the Planning Policy & Delivery Team.

This response is to the Suffolk Coastal District Local Plan and the map booklet accompanying the Issues and Options consultation on the Site Allocations and Area Specific Policies, and in particular to the incorrect classification of Foxhall as an 'Other Village' settlement.

Foxhall as a Settlement in the Countryside

Foxhall comprises a hamlet, clusters and solitary dwellings widely dispersed in rural surrounds without any, let alone few facilities. None of its dwellings are serviced by mains drainage and its roads and lanes are very largely without pedestrian sidewalks and are unlit. Its character is of a settlement spread within a green landscape between Purdis Farm and the A12 comprising hedgerow lined roads, agricultural land, the Suffolk Showground, woodland and footpaths giving access to woodland and the Sandlings path. Foxhall hamlet comprises 28 properties spread along a half mile stretch of Bucklesham road around the small hamlet green at the crossroad with Woodhouse Lane and Straight Road and is bounded to the south by Suffolk Showground land and Home Farm, and to the north by Home Farm. A further two dwellings are sited 0.3 mile further east along Bucklesham Road and aside from those on Felixstowe Road on the other side of Trinity Park to the hamlet, the few other dwellings are dispersed on Woodhouse Lane, Purdis Road, Monument Lane and Hall Road. The residents of Foxhall are poorly served by Public transport, this being confined to limited Bus services on Felixstowe Road to the south and a very limited (4 times daily) service along Bucklesham Road, the scheduling of which does not allow sustained 9-5 employment in Ipswich, or Woodbridge. The only businesses within its boundary affording employment, are Home Farm, other agricultural businesses and the refuse disposal/recycling site to the north east at the junction of Foxhall Road and the A12. Accordingly, the correct classification of Foxhall is of a settlement within the Countryside and that's not only how the residents see it. Suffolk Coastal District Council has consistently rejected applications for building single dwellings within existing plots on the grounds 'that they would set an unfortunate precedent for similar unacceptable developments, the cumulative impact of which would be to the detriment of the rural character and amenity of the countryside.' The emphasis on 'detriment of the rural character and amenity of the countryside' has characterised all of the council's rejections of such applications within Foxhall. Moreover the applications have been refused because (and again to quote) 'they would add an additional dwelling unit to the existing group which is isolated from any communal facilities. Public transport is virtually non-existent and private cars are needed to reach places of employment, school, church, shop, post office etc. or for leisure and recreational facilities. This would entail the use of Class III or unclassified roads and the area is clearly unsuitable for additional residential development...' In strongly refusing such applications the grounds above cited by Suffolk Coastal District Council are precisely those which describe a settlement in the countryside.

Accordingly, the Site Allocations and Area Specific Policies of the Suffolk Coastal District Local Plan need to be revised to reflect the status of Foxhall as a settlement in the countryside. ______Context and purpose of this representation In making this response we are aware that the process for review and changes to the Settlement Hierarchy is a matter for review of the Core Strategy but it represents the view of the residents listed on page 2 and undoubtedly many of those we have yet to trawl. In that respect its status is that of an initial representation but one which reflects a strongly held view of the local community. Its purpose is twofold i.e. to ensure that the Planning Policy & Delivery Team is aware of our view, and to deposit a place-holder into the consultation process. Please receive it in that light. Summary: In making this response we are aware that the process for review and changes to the Settlement Hierarchy is a matter for review of the Core Strategy but it represents the view of residents and undoubtedly many of those we have yet to trawl. In that respect its status is that of an initial representation but one which reflects a strongly held view of the local community. Its purpose is twofold; to ensure that the Planning Policy & Delivery Team is aware of our view, and to deposit a place-holder into the consultation process. Please receive it in that light.

Change to Plan

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Attachments:

S - 5955 - 3312 - Rushmere St Andrew (North) - None 5955 Support East of Ipswich Plan Area Housing Market Area Rushmere St Andrew (North)

Respondent: Summers Wykes-Sneyd (Mr Philip Summers) [3312] Agent: N/A

Full Text: Site Allocations and Area Specific Policies: Issues and Options Consultation Document Housing Allocation Representation

SHLAA Site Ref: 949 Rushmere St Andrew (Land situated to the north of Playford Lane)

The Site Bare land enclosure extending in all to some six hectares (14.8 acres) as shown edged blue on the attached plan and abutting existing residential development along the southern boundary.

The southern portion of the site (now shown shaded yellow on the attached plan) is bounded to the south by an existing development comprising semi-detached bungalows, to the east by a public byway bounded by two detached residential houses and to the west by a public footpath with mature hedgerow screening the site. The yellow shaded area relates well to the existing settlement and is suitable for the provision of single storey dwellings in a sustainable location.

Background

In November 2014 the Council published its Strategic Housing Land Availability Assessment (SHLAA) wherein this site was listed in Appendix D as being unsuitable for development with the reasons given as being "poor access; poorly related to existing settlement".

Whereas the area originally identified as comprising six hectares and potentially capable of accommodating up to 130 dwellings, subsequent appraisal of the access and layout design favours a smaller scale development deliverable within the next five years.

Development Proposal

The provision of 40 detached and semi-detached single storey dwellings (i.e. bungalows) as an extension to the adjoining settlement and accessed from Holly Lane.

Access

A Highways Assessment identifies Holly Lane as providing adequate access for the development as now proposed with the existing adopted roadways providing a metalled surface width of 5.6 metres plus additional existing footway links from the site through to the village centre.

Further, the site provides good footway links to the public transport system and public footpath network on the eastern and western boundaries (linking through to Playford and Tuddenham respectively).

Conclusion

The site offers a natural extension to the existing settlement and an opportunity to provide single storey accommodation (i.e. bungalows) in a location where there is both demand and take-up for new dwellings of this sort. The development proposal (in the form of bungalows) will have no visual impact upon the wider countryside or the existing village settlement. The site benefits from adequate access and is capable of delivery within 0-5 years.

This site should now be allocated for development.

I would be grateful if you would review the above with a view to including SHLAA Site Ref: 949 within the Site Allocations Document. Summary: The site offers a natural extension to the existing settlement and an opportunity to provide single storey accommodation in a location where there is both demand and take-up for new dwellings of this sort. The development proposal (in the form of bungalows) will have no visual impact upon the wider countryside or the existing village settlement. The site benefits from adequate access and is capable of delivery within 0-5 years.

This site should now be allocated for development.

I would be grateful if you would review the above with a view to including Site Ref:949 within the Site Allocations Document.

Change to Plan N/A

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Attachments:

S - 5955 - 3312 - Rushmere St Andrew (North) - None 5955 Support East of Ipswich Plan Area Housing Market Area Rushmere St Andrew (North)

20150225190134723_Redacted.pdf

O - 6111 - 3359 - Rushmere St Andrew (North) - None 6111 Object East of Ipswich Plan Area Housing Market Area Rushmere St Andrew (North)

Respondent: Brooke Smith Planning (Andrea Caplan) [3359] Agent: N/A

Full Text: Dear Sirs, Site Allocations and Area Specific Policies - Issues and Options Consultation Document December 2014 and Map Booklet for East Ipswich Plan Area Housing Market Sub-Areas

Brooke Smith Planning, Chartered Town Planning and Development Consultants, are instructed by WitCo, to prepare and submit representations to the above draft documents.

WitCo represents a group of charities who are the beneficiaries of the will of Mrs. Nora Baldwin, the former resident of Redecroft, The Street, Rushmere St Andrew. The charities have been left land at 155 The Street, for which consent for development is currently being pursued. The extent of the land is shown in Figure 1 below (see attached document).

Planning application DC/14/2473/OUT, for the development of the site to provide up to 14 dwellings, which was refused by Members in December 2014, is currently the subject of an appeal and is being considered by the Planning Inspectorate. In light of this we wish to make the following representation to the two documents currently being consulted on.

Site Allocations and Area Specific Policies Area Specific Policies - Issues and Options Consultation Document

It is noted that this document sets out a revised district minimum housing requirement for the period 2014-2027. For the Eastern Ipswich Plan Area the residual housing requirement is 2,000 dwellings and it is suggested that all of this requirement is proposed to be delivered through the Adastral Park development. It is understood that planning permission is yet to come forward for the Adastral scheme and that an application (ref. C/09/0555) has been before the Council for consideration since 2009. In light of the uncertainty in the delivery of the Adastral scheme, in both terms of whether consent will actually be granted or when any development may come forward, it is considered that the Council should consider other sites within the Eastern Ipswich Plan Area. As the housing requirements are quoted as being minimum figures, it is considered that the inclusion of additional small scale residential sites would not prejudice the future delivery of the Adastral scheme or the policies of the Local Plan. Our client' site, on the edge of Rushmere St Andrew, is one such site which could come forward in the short term to address the significant identified housing need in the District. As set out in the officer's report from the planning committee of 11th December 2014 (a copy of which is included with this submission), the site at 155 The Street is considered to be an acceptable one in terms of its development for housing. The application was refused by Members, contrary to officers recommendations, and it is maintained that this was due to local opposition to the scheme and not sound planning grounds.

Map Booklet for East Ipswich Plan Area Housing Market Sub-Areas

It is noted that the map booklet for the East Ipswich Housing Market Sub-Area sets out all of the SHLAA sites considered (Table 1: All SHLAA sites), including WitCo's land at 155 The Street, Rushmere St Andrew (ref. no. 916). As set out in the SHLAA table, the only reason for this site not being considered acceptable for development is stated as 'Coalescence; policy on protection of open spaces'. We would refer back to the committee report, as prepared by officers. Within this report officers, following consideration of the detailed landscape and visual impact assessment prepared by Ryder Landscape and submitted with the application (a copy of which is included with this submission), set out their views on the potential impacts of the proposed development on the gap between Ipswich and the village, and on the impacts on the character of the area.

The committee report states at paragraph 4.8 that: 'the site is immediately adjacent to the defined physical limits for Rushmere St Andrew. As such the site is considered to be sustainably located as required by the NPPF.' At paragraph 4.9-4.11 offices set out that; 'it is acknowledged that the site is subject to a policy which seeks to prevent the coalescence of Rushmere St Andrew with Ipswich and policy AP228 refers to 'visual importance of the open spaces in the vicinity of Rushmere Street and Humber Doucy Lane'. This issue is addressed in the submitted Landscape and Visual Impact Assessment (LVIA). The LVIA states that the current gap is comprised primarily of the large cereal field and three other fields to the north east of Humber Doucy Lane. It is primarily agricultural land utilised for cereal production with the field to the northwest of The Street put down to improved grassland pasture and part use as the church's overflow car park. As noted in paragraph 1.1 [of the committee report] the application site was formerly a market garden but is now unused and overgrown. The LVIA states that the application site does not contribute to the sense of openness that the rural fields present as it is separated by the high boundary hedge and no inter-visibility exists between the two areas. To the Rushmere St Andrew side of the agricultural land there are a number of sports pitches in close proximity to the application site. In respect of these the LVIA states that the application site does not contribute physically to the sense of openness that the playing fields present as it is separated by the high boundary hedge. There is very limited inter-visibility between the two areas and what does exist has to be sought out by careful visual analysis and seeking out the weakest parts of the strong boundary hedge. This inter-visibility is not evident to the casual observer. The LVIA concludes that in landscape terms the proposed development would have minor/negligible effect on the landscape.

Although the application site falls within the AP228 designation it is considered that the assessment of the proposed development within the LVIA is an accurate one. As the site is surrounded by high hedges it is considered that development on the site will not reduce the overall gap between Rushmere St Andrew and Ipswich and that the sense of

O - 6111 - 3359 - Rushmere St Andrew (North) - None 6111 Object East of Ipswich Plan Area Housing Market Area Rushmere St Andrew (North)

openness and retaining of the visual and perceptual gap between Rushmere St Andrew and Ipswich will remain unaffected by the proposed development. As such it is considered that the proposal will not have a negative impact on the aim of safeguarding gaps that make an important contribution to a particular location in their undeveloped form nor will it undermine the aim of Policy AP228. Furthermore, as the site is surrounded by high hedges, it is considered that the proposed development will not lead to the coalescence of Ipswich and Rushmere St Andrew.

This view that is shared by the Council's Arboricultural and Landscape Officer who considers that there are no strong arguments on landscape grounds to oppose the proposal. His landscape related comments are as follows:

impact limited by the retained boundary hedges.

effects.

moderate to negligible for a wide range of receptors around the site.'

In light of the above officers recommended that the scheme be granted consent for residential development. The application was subsequently refused by Members, contrary to officers recommendations, but it is maintained that this was due to local opposition to the scheme and not sound planning grounds. Accordingly, now that a detailed LVIA has been produced to consider the potential impacts on the gap between Ipswich and the village, and this has been agreed by the Council's landscape officer, the SHLAA status of the site should be updated. Following on from that, it is also maintained that the Physical Limits of Rushmere St Andrew should also be revised to include the site at 155 The Street. As can be seen from a comparison of the 'existing' and 'suggested' physical limits, figures 2 and 3, the proposed extension would be a logical rounding off of the western edge of the village.

Figure 2 - Rushmere St Andrew (North) - Existing Physical limits (Extract) (see attached document)

Should you have any queries with regards to the above please do not hesitate to contact me. I look forward to hearing from you with regards to the next stage of the Local Plan documents. Summary: Now that a detailed LVIA has been produced to consider the potential impacts on the gap between Ipswich and the village, and this has been agreed by the Council's landscape officer, the SHLAA status of the site should be updated. It is also maintained that the Physical Limits of Rushmere St Andrew should also be revised to include the site at 155 The Street. As can be seen from a comparison of the 'existing' and 'suggested' physical limits, figures 2 and 3 (see attached), the proposed extension would be a logical rounding off of the western edge of the village.

Change to Plan

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Attachments: Brooke Smith Planning Reps 27 02 15_Redacted.pdf

C - 6384 - 3408 - Rushmere St Andrew (North) - None 6384 Comment East of Ipswich Plan Area Housing Market Area Rushmere St Andrew (North)

Respondent: Mr J Pawlowski [3408] Agent: N/A

Full Text: Suffolk Coastal is mainly a coastal and rural area, and the council should insist that farmland and the country side is not concreted over to build large housing developments. Brownfield sites and empty homes should be developed first.

Any developments, for example, the proposed Martlesham BT site the council and the developers must make sure that the infrastructure is upgraded to support this. Jobs, schools, doctors and dental surgeries, sewers, water, public transport, sport and recreation facilities must be provided. Villages and small towns must not be blighted with large housing developments and must be able to cope with increased traffic and must not become rat runs.

The council should insist that developers build genuine low cost houses, so that young people can afford to buy them, so the villages and small towns do not just have second homes, and holiday homes and do not price out people trying to get onto the property ladder. Summary: Any developments, for example, the proposed Martlesham BT site the council and the developers must make sure that the infrastructure is upgraded to support this. Jobs, schools, doctors and dental surgeries, sewers, water, public transport, sport and recreation facilities must be provided. Villages and small towns must not be blighted with large housing developments and must be able to cope with increased traffic and must not become rat runs. The council should insist that developers build genuine low cost houses, so that young people can afford to buy them, not just second homes, and holiday homes.

Change to Plan

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Attachments:

C - 5477 - 3097 - Westerfield - None 5477 Comment East of Ipswich Plan Area Housing Market Area Westerfield

Respondent: Defence Infrastructure Organisation (Louise Dale) Agent: N/A [3097]

Full Text: I am writing to confirm the statutory safeguarding position of the Ministry of Defence (MOD) with respect to the above consultation documents. I can confirm that the MOD has no comments to make in relation to the Felixstowe Area Action Plan as it falls outside of any MOD published statutory safeguarding consultation zones. In respect to the Site Allocations and Area Specific Policies Issues and Options Document, I can confirm the Westerfield site in the East Ipswich plan falls within the statutory height consultation zone surrounding Wattisham Station. Therefore, any development that exceeds 91.4m in height should be referred to this office for review. However, the remaining sites identified fall outside of any MOD published statutory safeguarding consultation zones. Therefore, we have no safeguarding objections to development in these areas. I trust this adequately explains our position on this matter. Summary: In respect to the Site Allocations and Area Specific Policies Issues and Options Document, I can confirm the Westerfield site in the East Ipswich plan falls within the statutory height consultation zone surrounding Wattisham Station. Therefore, any development that exceeds 91.4m in height should be referred to this office for review.

Change to Plan

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Attachments:

C - 5998 - 3065 - Westerfield - None 5998 Comment East of Ipswich Plan Area Housing Market Area Westerfield

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

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

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

We would like to make the following comments:

Section 3: Housing

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

C - 5998 - 3065 - Westerfield - None 5998 Comment East of Ipswich Plan Area Housing Market Area Westerfield

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

C - 5998 - 3065 - Westerfield - None 5998 Comment East of Ipswich Plan Area Housing Market Area Westerfield

Section 4: The Economy

C - 5998 - 3065 - Westerfield - None 5998 Comment East of Ipswich Plan Area Housing Market Area Westerfield

Section 5: The Environment

We hope that the above comments are of assistance. Please do not hesitate to contact me if you have any queries. We look forward to the next iteration of this plan. Summary: There is scope for some further infill frontage development along the roads leading into the village. Site 939 would have no impact on the historic environment. The development indicated in front of Mill Farmhouse would result in some harm

C - 5998 - 3065 - Westerfield - None 5998 Comment East of Ipswich Plan Area Housing Market Area Westerfield

to the setting of this listed building. English Heritage is also concerned that development in depth on the east side of the road into the village (564 and 622) would harm the setting of the listed Church and adjacent listed former Rectory. The drainage ditch in site 622 may be of some historic interest and advice on this should be sought.

Change to Plan

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

S - 6104 - 3357 - Westerfield - None 6104 Support East of Ipswich Plan Area Housing Market Area Westerfield

Respondent: Artisan Planning & Property Services Ltd (Mr Max Agent: N/A Short) [3357]

Full Text: 1. Introduction and Site 622 (SHLAA 2014)

1.1 The site to which this representation relates is an area of land located off the Westerfield Road centrally located in the village of Westerfield. It is owned by a local farming family who are resident at Poplar Farm, Tuddenham. This representation is made on their behalf by Landex Ltd., their chosen development partner. 1.2 The site is also identified as site 622 as shown on the map of Westerfield SHLAA sites in the unnumbered Map Booklet of the Site Allocations and Area Specific Policies document (SAASP 2015). It is adjacent the identified existing physical limits boundary of the village and in the same position in the 'suggested' physical limits boundary in the Council's consultation document. 1.3 This representation is made on the basis that the SAASP does not make adequate allocation of land both quantitatively and qualitatively for housing purposes and rejects the subject site, site 622 by its exclusion from the suggested settlement boundary. 1.4 Site 622 was the subject of representations/response to the Council's Call for Sites exercise in 2013/2014 which forms the evidence base for the 2014 SHLAA and is recorded by the Council as 'suitable'. 1.5 The starting point for housing land supply considerations and the allocation of land for that purpose, both within the Core Strategy 2013 (CS) (which is the overarching planning document for the District, and the SAASP 2015 is the agreed scale of growth over the plan period (2010 to 2027). This is recognised at paragraph 1.11 of the SAASP 2015. 1.6 However, this gives no recognition/acknowledgement of the Inspector's findings and recommendations in his Report on the Council's 2013 CS which was found to be 'sound' but only on the basis that the Council gave an undertaking to an early review. A summary extract from the Inspector's Report of June 6, 2013 is reproduced below setting out what the Inspector expected the Council to do in such a review:-•‐‑ o Include a policy on the presumption in favour of sustainable development. o Introduce a clear commitment to an early review of the Core Strategy to address full, objectively assessed housing needs; o Clarify that the full, objectively assessed housing need for the District in the plan period at this point is 11,000 new dwellings; o Amend plan to provide for at least 7,900 new homes in the plan period

2. The Representation 2.1 For the avoidance of doubt, the Council'ʹs analysis of site 622 in the SHLAAA Assessment 2014, in terms of its sustainability characteristics and suitability for development resulting in the site being considered suitable, is endorsed by the landowners who confirm that the land is available and deliverable now. 2.2 The Council'ʹs CS 2013, in terms of housing land supply is predicated upon an allocation of land with which to provide 7900 dwellings over the plan period. There is nothing in the FPAAP 2015 to suggest that the Council has implemented one of the main recommendations of the Inspector's Report of the CS 2013 to undertake an update of its objectively assessed housing need or whether having done so, it reasserts the position it adopted in 2013 that 7900 dwellings was all that was required when at that time, the Inspector had evidence before him that suggested that the actual level of housing need was much greater and was at least 11,000 dwellings. 2.4 Notably, Issue 2 as identified by the Inspector in his Report of June 6 2013 was: - "Whether the overall level of housing provision and its distribution are justified and appropriate" 2.5 In his deliberations and in trying to address the issue identified above there are further key paragraphs within the Inspector's Report which are copied in full below. 46. However, in terms of the Framework, the scale of housing provision proposed falls substantially short of the objectively assessed need. Even if the theoretical capacity of all the sites included in the Strategic Housing Land Availability Assessment (SHLAA), existing commitments, potential brownfield opportunities, allocations carried forward from the previous Local Plan and a windfall allowance were taken into account, the provision would still fall some way short of the 11,000 dwellings required. While there is no persuasive evidence before the examination that environmental, infrastructure or other factors might restrict this amount of development if any required mitigation could not be achieved, this would have to be assessed. 53. The Council has proposed modifications intended to bring greater flexibility tothe identification of housing sites in the different settlements in the District (MM24, MM26, MM27, MM28, MM29). Taking these into account and with the main modifications that remove the ceiling on the amount of housing to be provided and clarify the approach to phasing, they would provide the necessary flexibility to assist in addressing housing needs and boosting the land supply in the initial part of the plan

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period. As such, I conclude that in this case having the CS in place at an early stage would support the achievement of sustainable development and bring forward sites to meet the housing needs of the area. An early review would be preferable to the alternative of suspension and likely withdrawal of the plan in terms of achieving the aims of the Framework taken as a whole. The main modifications that would set out the principles of the review are therefore necessary for the plan to be sound (MM3 (part), MM4 (part), MM25 (part)). 2.6 In para. 35 of the Inspectors Report the Council is reported to have responded to the Inspector that the indicative level of housing need in the District for the Plan Period at 11,000 dwellings 'was about right' In the absence of evidence to the contrary which is that of an up to date objective assessment of housing needs it is difficult to understand let alone accept why this new plan should be based upon a level of housing need which is already inadequate for the purpose. 2.7 In summary therefore, this representation takes the position that the Housing Section 3 of the SAASP 2015 Issues and Options, needs to bring clarity to the overall scale of housing growth based upon a 2015 assessment of the objectively assessed housing needs of the District and then to apply the agreed level of growth to the constituent identified spatial areas. The starting point base line figure of 7900 dwellings needed for the District in the 2013 CS and the calculations specific to the Felixstowe area are flawed and an under provision as the Council has already acknowledged in its response to the Inspector in 2013. 2.8 It is therefore inappropriate to prepare a site specific allocation document on the basis of a minimum identified need of 7900 dwellings as appears to be the case here. The appropriate starting point is the 2015 position of objectively assessed housing need which in itself will be an update of the recorded Council position before the CS Inspector of June 2013 when it agreed that the 11,000 dwellings need identified in evidence at that time was 'about right'. Summary: Site 622 was the subject of representations/response to the Council's Call for Sites exercise in 2013/2014 which forms the evidence base for the 2014 SHLAA and is recorded by the Council as 'suitable'. For the avoidance of doubt, the Council'ʹs analysis of site 622 in the SHLAAA Assessment 2014, in terms of its sustainability characteristics and suitability for development resulting in the site being considered suitable, is endorsed by the landowners who confirm that the land is available and deliverable now.

Change to Plan N/A

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Attachments:

C - 6171 - 483 - Westerfield - None 6171 Comment East of Ipswich Plan Area Housing Market Area Westerfield

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

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

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

Site Allocations

Asset Encroachment

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

Sewerage Network

Surface Water and Flood Risk

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

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

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

C - 6171 - 483 - Westerfield - None 6171 Comment East of Ipswich Plan Area Housing Market Area Westerfield

Engagement with developers

Anglian Water are keep to engage with Suffolk Coastal District Council on Local Plan consultations and on individual planning applications. Summary: 564: Cummulative impact with other sites may challenge network capacity. May require mains diversions on site.

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

C - 6172 - 483 - Westerfield - None 6172 Comment East of Ipswich Plan Area Housing Market Area Westerfield

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

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

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

Site Allocations

Asset Encroachment

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

Sewerage Network

Surface Water and Flood Risk

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

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

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

C - 6172 - 483 - Westerfield - None 6172 Comment East of Ipswich Plan Area Housing Market Area Westerfield

Engagement with developers

Anglian Water are keep to engage with Suffolk Coastal District Council on Local Plan consultations and on individual planning applications. Summary: 622: Cummulative impact with other sites may challenge network capacity. Sewers Crossing Site. May require mains diversions on site. 680: May require mains diversions on site. 702a: Cummulative impact with other sites may challenge network capacity. 702b: Cummulative impact with other sites may challenge network capacity. 939: Sewers Crossing Site. May require mains diversions on site.

Change to Plan

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

S - 6349 - 1342 - Westerfield - None 6349 Support East of Ipswich Plan Area Housing Market Area Westerfield

Respondent: The Kesgrave Covenant Ltd [1342] Agent: Phase2 Planning and Development Ltd (Ms Emma Walker) [2918]

Full Text: Strategic Housing Land Availability Assessment 2014 Site Ref: 939 (Land south of Lower Road,Westerfield}

Our clients, Kesgrave Covenants Ltd, own land which is identified within the SHLAA as being appropriate for development. We will be responding to the Council's Site Allocations and Area Specific Policies Issues and Options document in due course, but in the meantime, we thought that it would be useful to provide you with an update in relation to this site in the context of the SHLAA.

The SHLAA identifies our client's site to the south of Lower Road, Westerfield (ref: 939) as having capacity for around 18 dwellings with the potential for early delivery (years 1to 5). The plan showing the site at Appendix N of the SHLAA {enclosed for ease of reference) shows how the site is well located to the existing settlement, with existing development on three sides.

As a designated Local Service Centre, Westerfield is recognised as having a range of facilities. The village benefits from a railway station, which is 660m from the site, with the Ipswich to Lowestoft and Ipswich to Felixstowe services stopping at the station. There are also two public houses with restaurants, a church, a village hall and two commercial areas within the village. The nearest shops are located under 2km away at Fircroft Road, Ipswich and include a supermarket and a post office.

The only constraint identified in the SHLAA in relation to the site is Tree Preservation Order. It is relevant to note that the site is an open ploughed field and the existing trees are on the site boundaries only. The existing trees and hedges help to screen the site from the wider area and although trees will need to be taken into account when determining the position of access point/s they do not represent an insurmountable constraint. There are no other known constraints to development.

Our client's site is highly suitable for development. It is well located in the context of the village and its facilities and is less constrained than other sites that have been identified in the SHLAA. There are no Rights of Way crossing the site, no surface water flooding issues and there are no designations (other than the TPO) which affect the site.

In light of the above, we suggest that our client's land can make a positive contribution towards the District's housing supply. It will also provide benefits at the local level by providing additional homes, including affordable housing and the additional population will help to support the existing services within the village.

We would welcome the opportunity of discussing this site with you. Should you wish to meet to discuss this site further, please do not hesitate to contact me. In the meantime, we will be preparing our representations to the Site Allocations Consultation document. Summary: Site 939 is well located in the context of the village and its facilities and is less constrained than other sites that have been identified in the SHLAA. There are no Rights of Way crossing the site, no surface water flooding issues and there are no designations (other than the TPO) which affect the site.

We suggest that our client's land can make a positive contribution towards the District's housing supply. It will also provide benefits at the local level, providing additional homes, including affordable housing and the additional population will help to support the existing services within the village.

Change to Plan N/A

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Attachments:

C - 6358 - 1987 - Westerfield - None 6358 Comment East of Ipswich Plan Area Housing Market Area Westerfield

Respondent: Westerfield Parish Council (Mrs K A Broyd) [1987] Agent: N/A

Full Text: Suffolk Coastal District Council - Site Allocations and Area Specific Policies Issues and Options Document (December 2014)

With reference to your letter dated 12"' December enclosing copies of the above document and the accompanying Map Booklet Westerfield Parish Council have considered the content and make the following comments.

1. Overall concern of the information provided upon which views can be expressed. Information given in Table 2 of the document correctly lists Westerfield as a Local Service Centre and an indicative suggested housing allocation of 10 -20 during the years 20 I 0 - 2027. This is accepted as being similar to that anticipated by the Parish in the current Parish Plan.

The misleading aspect of this table is that the there is no reference to 6 homes that have been granted planning permission in the village in 2014 ( DC/1312673/FUL I Erection of 6no. new dwellings including Two Affordable Dwellings on land abutting settlen1ent boundary I Land Adjacent Manor Farn1 House Church Lane Weste1field Suffolk) presumably because permission was granted after 31" March 2014. In addition to not being included in this table this site does not feature in the sites to be considered for future development and is excluded from this process. The omission from this table is important in considering future sites in the village and the number of new homes that can be accommodated within the village infrastructure. If included, the suggested housing allocation would be 3 to 13 instead of 9 to 19 - a significant difference in considering other sites.

Furthermore, in February 2015 a further site has been given planning permission, subject to conditions, for 14 homes (DC/1413660/FUL Extension of existing access road and erection off fourteen new dwellings including four affordable homes: OS4300 North of, Fullers Field, Westerfield TP6 9AH). This site was not included in any of the tables for consideration in the Issues and Options document as a site already with planning permission nor as a future possible site for consideration. This clearly makes a mockery of consultation with the parishes. The Parish Council have spent time seeking to be constructive in response to both planning applications and the Local Plan documents but to no avail.

The total new homes from the two applications now approved above gives is in excess of the number considered suitable up to 2027 for Westerfield as a Local Service Centre. This takes no account of the views of the Local Parish Council that there are sites in the village better suited that should have been supported for development. The Parish Council consider that the consultation now being undertaken is inappropriate as the suggested allocation up to 2027 has been taken up by these recent permissions and that there is no point in giving consideration for more sites in this plan period.

The Parish Council had, prior to the permission subject to conditions being given to the Fullers Field Site, prepared some comments on the current consultation documents which they believed to be constructive. These comments follow, as had been agreed by the Parish Council, but should now be taken to apply to a much longer timescale that may be considered in future Local Plans for periods after 2027.

2. Physical Limits Boundaries a) The changes to the physical limits boundary for the main village envelope are accepted especially bearing in mind the development in Church Lane referred to in paragraph I . b) The suggestion for the Lower Road physical limits boundary appears sensible as it has its own identity and that Road is unsuitable for further development due to the proximity of the watercourse and unsatisfactory road conditions. c) There should be similar consideration of a third physical limits boundary around the cluster at the Railway level crossing. The boundary at this locality could include Mill Farm which is the subject of current planning applications, and also, at some time in the future, Old Station Works, if a change of use was eventually considered.

3. Sport and Play The Westerfield Parish Plan identified that there was a lack of Sports Field/Play space in the centre of the village. Westerfield Parish Council consider that such provision should he made and that the assessment of suitability of sites for housing should include the possibility of using a site near the village centre for sport and play purposes.

4. Consideration of SHLAA Sites in Westerfield a) Those sites listed as "Not suitable". The Parish Council agree with the assessments made in respect to these sites. (516a, 516b, 552 and 728) b) Those sites listed as "suitable". Parish Council comments are included in the following table:-

Site Ref. Address Ha Capacitv Parish Council comments 564 Land at Old Station works, Main Road 3.65 30 This is a brownfield site that needs developing as it has been mainly derelict for many years. Use of the entire plot for housing would cause concern over the effect that such a large number of homes would have on the limited community facilities in the village Suggest this is suitable for shared use, say up to 20 homes, with other emplovment uses. 622 Land adjacent to Old Glebe House, Westerfield Road 2.81 31 Not supported as this would remove the gap between the central part of the village and the cluster around the railway level crossing. Use of this site would create a greater feeling of ribbon development that is to be avoided. Not supported 680 Land at Mill Farm, Westerfield Road 0.25 3 This site fits in with the cluster around the railway level crossing and is

C - 6358 - 1987 - Westerfield - None 6358 Comment East of Ipswich Plan Area Housing Market Area Westerfield

suitable for development provided trees are protected. 702a Land to the south of Westerfield Hall Farm, Westerfield Road 1.14 13 Not considered suitable due to this appearing to be an extension of ribbon development and the unsuitable links to transport facilities. Footway access to the main part of the village is dangerous due to its narrow width 702b Land to the east of Westerfield Hall Farm, Westerfield Road 1.85 20 Not considered suitable due to this appearing to be an extension of ribbon development and the unsuitable links to transport facilities. Footway access to the main part of the village is dangerous due to its narrow width 702c Land to the north of White Lodge, Westerfield Road 0.27 3 Not considered suitable due to this appearing to be an extension of ribbon development and the unsuitable links to transport facilities. Footway access to the main part of the village is dangerous due to its narrow width 939 Land south of Lower Road, Westerfield 1.64 18 Not supported as this field is an important open space and provides separation between the physical limits boundaries of the village centre and Lower Road. This site would be an excellent location for Spots/Play space near the village centre.

On behalf of Westerfield Parish Council, Summary: The total new homes from the two applications now approved gives us in excess of the number considered suitable up to 2027 for Westerfield as a Local Service Centre. This takes no account of the views of the Local Parish Council that there are sites in the village better suited that should have been supported for development. The Parish Council consider that the consultation now being undertaken is inappropriate as the suggested allocation up to 2027 has been taken up by these recent permissions and that there is no point in giving consideration for more sites in this plan period.

Change to Plan

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Attachments: Comments.pdf

C - 6529 - 2581 - Westerfield - None 6529 Comment East of Ipswich Plan Area Housing Market Area Westerfield

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

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

1. Introduction

2. Air Quality and Noise Assessment

3. Archaeology

4. Education (including Early Years)

C - 6529 - 2581 - Westerfield - None 6529 Comment East of Ipswich Plan Area Housing Market Area Westerfield

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

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

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growth.

5. Health and Wellbeing

6. Libraries

7. Minerals and Waste Plans

8. Natural Environment

9. Public Rights of Way

10. Surface Water Management

11. Transport

12. Waste Provision

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

13. Water Management, Flood and Coastal Defences

C - 6529 - 2581 - Westerfield - None 6529 Comment East of Ipswich Plan Area Housing Market Area Westerfield

Appendix: Likely Archaeological Assessment Requirements

East Ipswich Plan Area

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

Framlingham

Saxmundham

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work.

Woodbridge

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

Woodbridge 900a - This site lies within an area of archaeological potential, and Neolithic pits and Iron Age features were excavated to the south (County Historic Environment Record MRM 030). The site should be subject to archaeological assessment at an appropriate stage in the design of new development to establish the impacts of past land-use, and ensure preservation in situ of significant remains, and/or appropriate investigation strategies. Summary: Westerfield 939. This site is close to the medieval core of the settlement, and within the findspot of Roman, Saxon and Iron Age objects. There is high potential for the development to impact on archaeological remains of these periods. The site should be subject to archaeological assessment at an appropriate stage in the design of new development to ensure preservation in situ of significant remains, and/or appropriate investigation strategies.

Change to Plan

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Attachments:

O - 5575 - 3157 - Witnesham (Bridge & Chapel) - None 5575 Object East of Ipswich Plan Area Housing Market Area Witnesham (Bridge & Chapel)

Respondent: Mr Tom Bennett [3157] Agent: N/A

Full Text: I am writing in support of SHLAA site ref 704b Land adjacent to Tanglewood The Street Witnesham and agree the site is not suitable for development. Whilst the reason given relates to a Highway issue I consider there are a number of other factors which render the site most unsuitable for residential development as follows:- 1. Development would be obtrusive both from a local viewpoint and from a wider area as it slopes up very steeply in a southernly direction. 2. Any development would result in extensive overlooking and loss of amenity. 3. Any widening of Tuddenham Lane along the frontage of the plot would still result in bottlenecks at either end. 4. The site is behind the existing settlement boundary and development of farm land behind existing dwellings does not reflect policies for small scale developments abutting villages. 5. Other, more suitable sites, have been allocated are being developed which meets the needs of the Indicative Housing provision. Summary: I am writing in support of SHLAA site ref 704b and agree the site is not suitable for development. Development would be obtrusive both from a local viewpoint and from a wider area. Any development would result in extensive overlooking and loss of amenity. Any widening of Tuddenham Lane along the frontage of the plot would result in bottlenecks at either end. The site is behind the existing settlement boundary and development does not reflect policies for small scale developments abutting villages. Other, more suitable sites, meet the needs of the Indicative Housing provision.

Change to Plan

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Attachments:

C - 5605 - 3175 - Witnesham (Bridge & Chapel) - None 5605 Comment East of Ipswich Plan Area Housing Market Area Witnesham (Bridge & Chapel)

Respondent: Swilland and Witnesham Parish Council (Chris Agent: N/A Rush) [3175]

Full Text: I have received the Regulation 18 - Town and Country Planning (Local Planning) Regulations 2012 Issues and Options Consultation documentation dated 12th December. I attach again the response I sent on behalf of Swilland and Witnesham Parish Council on the 8th October 2014 and although I appreciate this latest Consultation is for Public Consultation none the less it is disappointing the see that our comments and suggestions have not been included.

Site 704b is now considered not suitable which we suggested but that Site 704a still remains listed as suitable which we had suggested (see attached) might not be needed given there were more suitable non green field sites available in other areas that would provide the >40 allocation being suggested for our Parish. I again ask that Site 569 (potentially 8 dwellings) which is within Witnesham Parish Boundaries and is well related to the village is opposite the local primary school and main recreation area which includes a sports field, play area and community car park, be given further consideration. The site has previously been put forward for a planning enquiry albeit many years ago land has not been in agricultural use for some time, I am sure Land Registry would have the names of the current land owner whom I believe lives in Henley and I would be happy to provide further details if needed.

I also suggested site 866 be considered albeit a relatively small site with the potential for up to 4 dwellings perhaps a little small but none the less would provide a degree of balance to the housing allocation sites through the village given it is opposite Burwash a well-established residential area along the main arterial road through the village.

Table 2 now outlines the Residential Requirement as between 0>40. I have asked how this figure is arrived at and have previously provided the completed and not started housing schemes in the Parish to confirm our allocation is achievable without any further large scale development. The land north of Elm Cottage ( 7 houses) and Jacks Field ( Site 445) ( 6 houses) will contribute to the "identified" 0>40 requirement. In addition Site 678 ( with 13 houses) at Street Farm would be suitable for development, being a brown field site containing disused pig farm buildings.

I believe we as a Parish have been extremely cooperative in responding to requests to comment on various sites, We recognise that as a Key Service Centre we need to play our part in assisting the district with its overall housing allocation requirements. It is somewhat surprising to see so few Parishes have actually put sites forward certainly Westerfield and ourselves appear to have provided quite a few opportunities and I would hope that you will be sensitive with your site designations and reflect on our suggestions for small pockets of development rather than allowing large scale developments in what is a very rural area given the proximity of the Ipswich garden Suburb proposals alongside the proposed SHLAA sites in Westerfield. Summary: We recognise that as a Key Service Centre we need to play our part in assisting the district with its overall housing allocation requirements. It is somewhat surprising to see so few Parishes have put sites forward certainly Westerfield and ourselves appear to have provided quite a few opportunities and I would hope that you will be sensitive with your site designations and reflect on our suggestions for small pockets of development rather than allowing large scale developments in what is a rural area given the proximity of the Ipswich garden Suburb proposals alongside the proposed SHLAA sites in Westerfield.

Change to Plan

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Attachments:

C - 5649 - 3201 - Witnesham (Bridge & Chapel) - None 5649 Comment East of Ipswich Plan Area Housing Market Area Witnesham (Bridge & Chapel)

Respondent: Mr Jerry Hindle [3201] Agent: N/A

Full Text: I now give my formal response to the Issues and Options Consutation on SAASP.

I believe we should continue to support the village as a Key Service Centre and in line with this, support development meeting local needs. I note that Table 2 gives a "Residential Requiremen"of between 0>40. I have asked SCDC officers how this figure is arrived at and and they were quite open that there was no objective base for this, rather it was an officers feeling that somewhere between these figs would suit Witnesham's local needs.Strategically there is no requirement for Witnesham to have any new allocation hence the bottom end requirement of 0. On the other hand there was an officer feeling that over 40 would be excessive for the village over the plan period. I agree that the residential requirement is somewhere between these figures and recognise the need for some flexibility but feel that a figure of around 25-30 would adequately serve local needs for this plan period.

Most of the facilities relating to a KSC; - school, post office, shop,chaple, playingfield etc are at the northern end of the village ( Witnesham Chaple) and that is where ideally we ought to be encouraging development to meet local needs. I appreciate that identification of potential development sites is landowner led and that most of the sites put forward to date are in Witnesham Bridge. Moreover, the recently granted planning permission sites are at Witnesham Bridge including land north of Elm Cottage ( 7 ) and Jacks Field ( 6). I think SCDC should be seeking the identification of suitable sites in or near the Witnesham Chaple part of the village. As such I would ask SCDC to further consider the inclusion of Site 569, as being suitable for the development for >8 houses. The site is near the school, the playingfield and the Moon and Mushroom pub and I believe, is relatively well related to the village and has not been in agricultural use for the last 30 + years.

Of the sites put forward, the land north of Elm Cottage ( 7 houses) and Jacks Field ( Site 445) ( 6 houses) that have recently been given planning permissiosn will contribute to the "identified" 0>40 requirement (Or my 25-30 requirement estimation) In addition I agree with SHLAA in identifying Site 678 ( with 13 houses) at Street Farm as suitable for development. This is a Brown Field site and housing development would be preferable to the present long disused and unsightly old pig buildings. The sum of these devlopments would be an additional 26 houses which I think adequately meets Witnesham local needs and would be supplemented by the odd individual new house development and Site 569 if that is taken forward.

There is no need for the development of sites 704a and 704b. I am glad to see 704b is now considered " Not Suitable". I do not think any site devlopment access off Tuddenham (Sandy ) Lane would be accpetable. It is a very narrow lane with an already very constricted junction with the B1077 where traffic has to wait if cars are coming down the hill. Any widening of this lane to accomodate access would spoil the amenity of the lane. In addition development of this site would have a detrimental impact on the setting of the exceptional Grade Listed Red House Farm and a visual impact of developing a highly sloping site that can be seen from various vantage points around the lower village and as far a away as the Golf Course. It would also cause loss of agricultural land. I ask that Site 704a is not taken forward. I do not see any reason why its status as now being considered "Suitable" has changed from being considered "Unsuitable " in the 2010 SAASP. It is just as " Not well related to existing development" now as it was in 2010. It is a greenfield site and the development of 19-38 houses would be a spoiling over development of Witnesham Bridge and should be resisted.

I trust you will take these into account in developing the preffered options. Summary: Most of the facilities relating to a KSC;- school, post office,shop,chaple, playingfield etc are at the northern end of the village and that is where ideally we ought to be encouraging development to meet local needs. I appreciate that identification of potential development sites is landowner led and that most of the sites put forward to date are in Witnesham Bridge. Moreover, the recently granted planning permission sites are at Witnesham Bridge including land north of Elm Cottage and Jacks Field. SCDC should be seeking the identification of suitable sites in or near the Witnesham Chaple part of the village.

Change to Plan

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

Attachments:

C - 6170 - 483 - Witnesham (Bridge & Chapel) - None 6170 Comment East of Ipswich Plan Area Housing Market Area Witnesham (Bridge & Chapel)

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

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

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

Site Allocations

Asset Encroachment

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

Sewerage Network

Surface Water and Flood Risk

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

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

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

C - 6170 - 483 - Witnesham (Bridge & Chapel) - None 6170 Comment East of Ipswich Plan Area Housing Market Area Witnesham (Bridge & Chapel)

Engagement with developers

Anglian Water are keep to engage with Suffolk Coastal District Council on Local Plan consultations and on individual planning applications. Summary: 445: May required process enhancement to treat FW. Sewers Crossing Site 678: Sewers Crossing Site 704a: Some localised network enhancement may be required to receive FW

Change to Plan

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

O - 5800 - 2849 - Employment Sites EMP1 & EMP2 - None 5800 Object East of Ipswich Plan Area Housing Market Area Employment Sites EMP1 & EMP2

Respondent: Tesco Stores Limited [2849] Agent: Contour Planning Services (Mr Justin Mills) [2473]

Full Text: Policy EMP1 continues to include a significant area of land used for retailing within the Martlesham Heath Industrial Estate (including the existing Tesco store and retail warehouse site to its rear) as an 'Employment Site'. This designation does not reflect the retail use of the land, which is no longer available for 'employment' use. In this regard, the NPPF (Para 22) advises that "planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose. Land allocations should be regularly reviewed." Accordingly, existing and committed the retail sites should be removed from the 'employment' designation. Summary: It is not appropriate to include existing and committed retail sites within a designated 'Employment Site.

Change to Plan Remove existing and committed retail sites from 'Employment Site' designation.

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

Attachments:

C - 6528 - 2581 - Employment Sites EMP1 & EMP2 - None 6528 Comment East of Ipswich Plan Area Housing Market Area Employment Sites EMP1 & EMP2

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

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

1. Introduction

2. Air Quality and Noise Assessment

3. Archaeology

4. Education (including Early Years)

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

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

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growth.

5. Health and Wellbeing

6. Libraries

7. Minerals and Waste Plans

8. Natural Environment

9. Public Rights of Way

10. Surface Water Management

11. Transport

12. Waste Provision

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

13. Water Management, Flood and Coastal Defences

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Appendix: Likely Archaeological Assessment Requirements

East Ipswich Plan Area

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

Framlingham

Saxmundham

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work.

Woodbridge

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

Change to Plan

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Attachments: