Room 123 16 Grays Orchard Coastal District Council Kirton Melton Hill Suffolk Woodbridge IP10 0RE Suffolk IP12 1AU

18th October

Dear Mrs. Feeney,

I write on behalf of Kirton and Parish Council (“KFPC”) of which I am Deputy Chairman.

Please accept this letter as a request on behalf of our Parish Council for the Inspector to reconsider the provisional view he has expressed as to the characterisation and significance of the Suffolk Coastal District Council’s (“SCDC’s”) Main Modification 41 (MM41). We would be grateful if you would also treat this letter as a submission to, and the basis for discussion at, the Local Employment hearing. In considering the points made in this letter I would ask you to bear in mind that KFPC does not have the benefit of professional planning advice or specialist legal advice.

On the 3rd and 26th September SCDC wrote to you recommending changes to its Core Strategy, including MM41. On 5th September I wrote to you asking for a clarification of the reason for the proposed change by which the words “or in accordance with SP5” were added to policy DM11. On the same day you requested Mrs. Hanslip to respond on behalf of SCDC. On the 19th I reminded Mrs. Hanslip that no response has been received. I received a reply on the 20th September, which stated that “In brief policy DM11 as written conflicted with policy SP5 in that insufficient land is available for port related uses. Additional sites will need to be identified in due course whether this is within or outside of the district (Core Strategy paragraph 3.68).” MM41 reads as follows: ‘Amend first paragraph: “Proposals for warehouses and storage depots (Class B8 uses under the Use Class Order), including for container compounds and handling areas, will be restricted to areas identified in the Local Development Framework (LDF) as being suitable for the use, such as General Employment Areas or in accordance with SP5. Outside of these areas, such uses will not be permitted…”

It appears to us that this amendment, whilst briefly expressed, is of very considerable significance indeed. The effect of the proposed change is that the Core Strategy is now restrictive in Employment Land policy for all companies/industries, except for Port use, where it appears to provide no policy protection for any land of any status. This constitutes a major strategic change, especially given that the scale of demand is said to be for 115 Ha in 2023 ( Port Logistics Study, Final Report For Suffolk Coastal District Council – October 2008; available in the Core Documents Library).

As you will be aware, there is a proposal for a development at Innocence Farm in the Felixstowe peninsula to meet this suggested demand. The proposed change to the Core Strategy appears to cater for that development. The scale of the proposals was reiterated by the Port in an article in a local newspaper published on 30th June this year, a copy of which I enclose with this letter. To put the proposal into context, this development would cover a greater area than that proposed for

1 Adastral Park (see http://www.adastralvision.com) and would be of arguably greater impact, being industrial, rather than housing.

It would be our submission that MM41 cannot properly be regarded as simply enabling future sites to be identified for port use. It is instead creating what, in terms of size and impact on green field land, amounts to a blank cheque in the Strategic Policy for regionally and strategically significant developments.

I understand that the Inspection phase on which you are presently engaged requires that the process adopted by SCDC has been transparent, democratic and fair. In the case of MM41 and DM11 the process followed is none of those things.

Much of the submissions made by KFPC to SCDC and the Inspector during the consultations were founded on the formulation of DM11 as submitted to the Secretary of State. This change by SCDC was made at the last possible moment in the process and in terms that are frankly obscure to anyone but a specialist planner.

It is difficult to understand why SCDC have delayed until now to make this change. As will be obvious, its timing causes us enormous prejudice. There appear to have been no relevant submissions in the several consultations on the documents during the past eighteen months. I can find no relevant submission in the ‘Hearings Submission’ document list on your website. Nor can I find any relevant submission in the March 2012 review of the pre-submission document by SCDC. The most recent submissions which would appear to request this change is the submission by Bidwells (the property consultants retained by Trinity College, the owners of the land in question) in November 2010, re-iterated in a submission in January 2011 (website reference Representation 2650 on Reviewed Core Strategy & Development Management Policies by Bidwells). SCDC therefore had eighteen months, and several iterations of the document, in which to consider these submissions and make the change prior to its submission to the Secretary of State. It did not do so until the 3rd September, giving unacceptable time after publication of their modification on the website and your deadline of 11th September for modified responses.

SCDC have told us that they have been having discussions with the Port and with Bidwells. It appears at least possible, therefore, that the change has emerged from those discussions, rather than from the open consultation, submission and hearing process. If that is right, or even if there is the appearance that that may be right, then we would argue that the process not been democratic, fair, transparent or timely.

As a Parish Council only five miles from Felixstowe docks, we fully appreciate the importance of the port and transport business for employment, and acknowledge that container and warehouse facilities are needed.

Given that the MM41 change is to enable so large a development, we would argue that this is a strategic change, and one that requires examination of the evidence base for the demand and for the potential solutions. That would include examining alternatives, in particular whether existing port facilities or brown field land would fulfil the need, rather than this change which would put all green field land within the policy for port related development.

2 The proposed development of this 115 Ha site for this purpose would constitute a ribbon development filling in one third of the length of the remaining green field land separating and Felixstowe along the A14. This would be a precedent for similar developments, which could result in the formation of an Ipswich/Felixstowe conurbation. This is surely a matter going to the Core Strategy’s soundness, and consultation including Felixstowe Town Council, Ipswich Borough Council and many authorities ought to be required. The proposal raises questions going to the protection of AONB, quality of life of residents and traffic capacity of the A14.

I have checked Planning Policy Statement 12 for the relevance of our concerns for the Core Strategy. Examples of their relevance would appear to include the following: the approach of the Core Strategy to employment land, and MM41 in particular, does not address (i) reasonable alternatives (4.36), the impact on property values or cultural values (4.37); (ii)it has not involved or enabled community participation in the strategy relating to demand or solutions (4.37); (iii) the need or solutions been not updated for four years (4.37); (iv) the Council has not initiated a strategic survey of realistic alternative sites (4.38); (v) the Council has not demonstrated how the A14 infrastructure can cope (4.45); and (vi) the Council has not addressed the environmental issues (4.45).

Regarding (4.38)SCDC have used a single study, now four years old, as the evidence of need (“Felixstowe Port Logistics Study, Final Report For Suffolk Coastal District Council – October 2008”) . The same study also included identification and analysis of other potential sites in 2008. But although the Core Strategy uses this study to determine need, it appears to ignore information on the identification and assessment of sites. Furthermore there is no information on the basis on which sites will be assessed. The Felixstowe Port Logistics Study appears to highlight in its recommendations that its information is not sufficient for the Core Strategy; quoting from “7.3 Recommendations and Next Steps”, “This study should be used to inform the preparation of Development Plan Documents (DPD) produced by local planning authorities within the local development framework (LDF) planning process and provide part of the evidence base to support land allocations and potential sites that would be suitable to support the sustainable expansion of the Port of Felixstowe and related port uses. It is one input to the process, as set out in PPS12, but is not likely to be sufficient on its own nor is it intended to replace the consideration of other evidence provided to the LDF processes which will be taken forward by the respective Local Authorities.” (my underlining)

An alternative site in Stowmarket has been proposed by the Ipswich Policy Area Board (an appendix in the letter to you from Hilary Hanslip 20th June 2012). However there appears to be no published evidence of a process for systematically identifying and processing sites. Given the strategic significance of site selection, this should have been addressed in the Core Strategy.

A further issue of transparency, democracy and fairness relates to the process of site selection in relation to Innocence Farm as compared to that of Adastral Park. Adastral Park is a well understood proposal for a site for housing development. It is of a size and impact that makes it a strategic site allocation issue, and accordingly one dealt with in the Core Strategy. Given its size and nature, the proposal for Innocence Farm would have a greater impact on the region than the Adastral Park. The possible development of Innocence Farm is well known in SCDC, by the Port, by the landowner and by their agents. It is regularly addressed in minutes of meetings including those of SCDC, the Port and the landowner, and is referred to in the previously mentioned submissions to the Core Strategy.

3 Although we would not regard a newspaper quote as definitive, it is very concerning that the newspaper article of the 30th June states that “So it’s no surprise that the top site on everyone’s list - except the residents who live close by …is Innocence Farm”, when neither the need has been analysed or the solutions addressed in the main Core Strategy document. Whilst Adastral Park has received considerable strategic site specific attention in the Core Strategy, Innocence Farm has not.

A group of Felixstowe Peninsula Parish Councils have joined together and have already initiated joint actions against this proposal. The time constraints imposed by this late proposed change have not permitted time to obtain formal approval of this letter by those Parish Councils; however I can assure you that discussions have given strong support of the concerns in the letter, and further joint campaign is planned.

Our primary submission is that MM41 should be rejected. The means by which it has been formulated and advanced has not been transparent, democratic or fair. It constitutes a Major issue, in terms of Soundness and Legal Compliance. If it were not rejected then in our submission the process should be extended to assess Innocence Farm as a strategic site allocation issue.

I have included below a pamphlet giving the background to our concerns regarding the Innocence Farm site.

Yours sincerely,

Jack Cade Deputy Chairman of Kirton and Falkenham Parish Council

Tel. 07802 937154 e-mail: [email protected]

4 What should the next actions be? Felixstowe Peninsula; Under Threat

 We fully appreciate the importance of the port and transport business From Excessive Development for employment, and acknowledge that container and warehouse facilities are needed. We are fortunate to live in such a pleasant environment:

 Decision makers should not be swayed by media communications by  The land adjoining the Deben and Orwell rivers are listed as Trinity College’s agent; it is no surprise that they have identified their Areas of Outstanding Natural Beauty (AONB) own agricultural land as the most suitable for industrial use given that  In addition to Felixstowe, the AONBs, the countryside and the that will increase its value massively. river banks are beautiful places to visit  It is imperative that our District and County Councils take a strategic  We have a good selection of local shops in Felixstowe, the view, rather than simply responding to applications for development of Trimleys and Walton green fields by owners of land between Felixstowe and Ipswich.  We have a range of major local employers including the port, What are the alternatives to Innocence Farm? transport companies and BT.

 Very large areas within the current port perimeter are concreted over But this balance is under threat from proposed but currently unused. inappropriate development.  Suffolk Coastal District Council has identified other suitable sites which

are either existing industrial sites or have been allocated for industrial development. Innocence Farm  A recent meeting between Mid Suffolk District Council, Suffolk Coastal District Council, Ipswich Borough Council, Babergh District Council, and Suffolk County Council identified a site outside of the Felixstowe Peninsula as a site to be supported for Felixstowe Port container handling expansion.

 The provision of container storage and warehousing sites which lie to the west of Orwell Bridge would mitigate A14 traffic congestion problems; development on the Felixstowe peninsular would aggravate them.

5

What would the impact of these developments be?

Our environment is under significant risk from the threat of  The proposed development at Innocence Farm would be a major development contribution to industrial ribbon development along the A14 and would urbanise nearly a third of the remaining green field  Trinity College, part of Cambridge University, owns a significant amount separation between Felixstowe and Ipswich. It would create a of land on the peninsula. It is proposing to build extensive housing, precedent for further development which could result in an retail facilities and a major industrial site on the peninsula. Ipswich/Felixstowe conurbation, removing the distinction between  Trinity College is suggesting the construction of a substantial industrial the two towns. site on green field agricultural land at Innocence Farm. Innocence Farm  Extra industrial development and housing would create additional lies between Trimley and Kirton; the size of the proposed development pressure on the road infrastructure of the peninsula. The A14 is would dwarf Ransomes Europark. (The proposed site is marked in red already very busy, and the Orwell bridge traffic exceeds its capacity and indicated by an arrow on the map below.) at peak periods. When closed due to problems the traffic then  Suffolk Coastal District Council is proposing to allow a further 1,760 blocks up Ipswich. The proposed developments would make that houses to be built on the Felixstowe peninsula. worse, and increase the frequency with which the road is blocked, preventing reliable travel to and from the peninsula.  Damage to our widely enjoyed natural environment and wildlife

 24 hour operation of warehousing, container and lorry movements, together with a proposed new rail terminal, would mean round the clock noise disturbance and light pollution to our local communities.

 Once the agricultural land is gone it's gone forever

This issue of the pamphlet has been produced by the elected Parish Council of Kirton & Falkenham.

We are working on behalf of all those who believe that what remains of our countryside should be protected for our children and grandchildren.

6th October 2012 6

7

8

9