Suffolk Coastal Local Plan - Final Draft

Final Draft Local Plan

1 Introduction

1.1 Suffolk Coastal is a uniquely attractive place to live and work, combining a strong economy with a natural and built environment second to none. Those advantages however present the Council with the challenge of balancing the delivery of development that continues to stimulate and support the economy and provides attractive and affordable homes for current and future generations, with the need to preserve and enhance the precious, but sometimes vulnerable environment. This Local Plan seeks to be ambitious in growing the District's economy, in particular recognising the opportunities presented by the Port of Felixstowe, the energy sector and key transportation routes, boosting the delivery of homes to contribute to addressing the national housing shortage and responding to needs for a greater mix of homes and increasing the delivery of affordable housing, whilst improving infrastructure provision.

1.2 The District Council is preparing a new Local Plan for the District which provides a vision for the communities of Suffolk Coastal up to 2036 and recognises the diversity of the area. 

002 Suffolk Coastal District

Suffolk Coastal District

Suffolk Coastal Context

1.3 Suffolk Coastal is a large District some 892 sq km/344 sq miles in area, much of which is rural in character with 48.8km of open coastline. In 2016 the mid year population was estimated at 127,836 residents with the majority of people living in the urban areas to the east of Ipswich such as Kesgrave, Martlesham and Rushmere St Andrew, the coastal resort town of Felixstowe and the market towns of Aldeburgh, Framlingham, Leiston, Saxmundham and Woodbridge. The area is a popular destination for visitors and tourists from the UK and abroad with exceptional natural, historic and built environments. There are over 100 parishes which range in population size from a handful of people to several thousand people.

Social context

1.4 People are at the heart of Suffolk Coastal and the Local Plan seeks to provide vibrant and healthy communities to meet the needs of all residents.

1.5 Suffolk Coastal has one of the oldest populations of any district in the country and this characteristic places additional requirements on the Local Plan, service providers and infrastructure provision. In 2015, 70,800 persons (approximately 57% of the population) were of working age (16-64 years of age). Over the plan period, it is anticipated that the percentage of the population who are working age will decline. An ageing population creates specific requirements for residential dwellings and care provision, although there is often a desire to remain in the existing home rather than to relocate. Adaptation and improvement to the existing housing stock may provide a solution but will not always be possible. The provision of new accommodation suitable for older people will potentially free up larger family housing which will be important alongside new dwellings. Alongside this, the affordability of housing is an issue in the District, with house prices being on average 8.95 times the average earnings[1] . This presents issues in particular for young people who wish to remain in or move to the District. This includes people growing up in the District who leave for a period of time for further education and other opportunities.

1.6 Over the plan period, the Local Plan will deliver an ambitious level of housing to meet the needs of the current population through increased provision of units targeted at meeting specific needs (including those of Gypsies, Travellers and Travelling Showpeople), the provision of affordable housing and deliver the housing needed in a timely manner through a plan led approach.

1.7 The 2011 Census showed that across the District there were 58,227 dwellings which increased to 61,157 as at the end of March 2018. Housing delivery across the District has always been positive and rates of construction have, in recent years, returned to the levels experienced before the economic downturn that started in 2008. At that time, like other parts of the country, residential completions dropped to a low level which reflected the economic conditions faced by all parts of the country. Despite the drop in delivery and subsequent upturn of completions the Council is well placed to continue to deliver significant housing opportunities for all over the plan period. In recent years the Council has taken a positive approach to the delivery of housing and, through site allocations, planning permissions already granted and a good rate of delivery, the Local Plan will deliver the dwellings required to meet the needs of the local community.

1.8 Despite the good rate of housing delivery across the District, property prices continue to be above the national and regional averages as outlined by information from the Land Registry. In 2017, the median property price in Suffolk Coastal was £274,995 compared to the median of £230,000[2] for England.

1.9 The District also faces challenges in respect of residential accommodation being taken up as second homes or units for tourism accommodation. In 2015 there were over 2,500 dwellings registered as second homes within the District. Suffolk Coastal is a popular tourist destination and this demand in some areas can deny local people the opportunity to buy or rent properties as demand raises prices to levels which are often outside of the budget of local residents. Seasonal and holiday let demand can also affect the availability of properties for longer term private rent.

1.10 Suffolk Coastal is a relatively affluent District with some areas demonstrating high levels of affluence but some parts of the District are amongst the most deprived in the country. Within Felixstowe there are pockets of deprivation, as well as rural areas in the north of the District. These locations need further attention over the plan period to ensure that issues relating to communities in deprived areas are supported and enhanced.

1. Ratio of Median House Price to Median Workplace Earnings 2017 (Office for National Statistics, 2018) [back]
2. Office for National Statistics [back]

Environmental Context

1.11 Suffolk Coastal is a District heavily influenced and characterised by the natural, built and historic landscapes. High quality and international designations covering large areas of land are found across the District which is interspersed by settlements and countryside. The coastline has also played a significant role in developing the area and will continue to do so in the future.

1.12 The District contains over 48km of open coastline as well as over 139km of estuaries. The estuaries of the Alde and Ore, Blyth, Deben and Orwell Rivers help shape the District and the communities which surround them. Estuary Plans have been prepared for the Deben Estuary and the Alde and Ore Estuary in recent years. Approximately a third of the District based around the coast and its hinterland is designated as an Area of Outstanding Natural Beauty and 11,200 hectares of the District is designated as Sites of Special Scientific Interest. In addition, Natura 2000 is a network of protected sites that represent European and International designations.

1.13 Suffolk Coastal's landscape is diverse, including large areas of farmland, which support a rich biodiversity and contain features of geodiversity. In terms of built environment, there are 36 Conservation Areas with around 2,300 listed buildings alongside a rich archaeological interest, historic parks and gardens and a military history, all of which combine to form the historic landscape.

1.14 The exceptional quality of the natural, built and historic environment makes Suffolk Coastal a very special place to live and work and a popular destination for visitors and tourists. This resulting high quality of life brings with it the responsibility of preserving this heritage as a key priority, for its own intrinsic value as well as for the health, prosperity and well-being of the residents.

1.15 East Anglia is recognised by the Environment Agency as an area of 'serious water stress'. As one of the driest parts of the country, water resources need to be carefully managed through partnership with water companies, the Environment Agency, landowners and Suffolk County Council as Lead Flood Authority.

1.16 Two Air Quality Management Areas have been declared in Suffolk Coastal, one in Woodbridge and one in Stratford St Andrew. Both of these areas are monitored by the Council as they exceed annual mean Air Quality Objectives for nitrogen dioxide. Outside of these areas the air quality is generally very good and levels of air pollutants are below national limits.

1.17 The District has a significant network of public rights of way, including nationally promoted walking trails such as the Stour and Orwell Walk, and the Sandlings Walk. Public rights of way not only act as walking and cycling links between communities, education sites and workplaces, but also contribute to the economic prosperity of the District through the tourist trade that they attract.

Economic context

1.18 The East of England is one of the fastest growing regions and Suffolk Coastal is a key contributor to this growth. The District is home to a number of key economic drivers such as the Port of Felixstowe, Sizewell Nuclear Power Station, offshore wind energy developments and BT operations at Adastral Park. These large scale employers have a local presence but contribute significantly to the national and international economies and the Local Plan seeks to support this contribution.

1.19 The East Suffolk Business Plan identifies these major employers and sectors as being of huge benefit to the District. The Local Plan will seek to ensure that the appropriate provision of land, associated infrastructure and supply chain networks are promoted over the plan period to maintain the contribution made by these key economic drivers.

1.20 The District's economy is supported by a high proportion of small and medium sized businesses which are vital to the local economy and rural communities. Economic evidence highlights the importance of these businesses across a range of sectors which provide a variety of employment opportunities. Suffolk Coastal has a higher number of businesses than compared to neighbouring authorities which shows that enterprises in the District sustain activity and generate economic prosperity.

1.21 Official Labour Market Statistics show that within Suffolk Coastal 80% of the population were economically active in 2016, which mirrors the position for the East of England and is slightly higher than the national figures. Average earnings are also generally higher than the regional and national averages although there still remains a gender pay gap within the District.

1.22 Many young people leave the area for further education and other economic and social opportunities which impacts on both the local community and business sectors in the District. The emergence of The University of Suffolk and expansion of other education providers such as Otley College present important opportunities for the District over the plan period. Improving the education and economic opportunities for young people in the District will be beneficial and reduce the growing numbers of people commuting into the area to fulfil jobs.

1.23 The District has a strong and effective relationship with the New Anglia Local Enterprise Partnership (LEP). The LEP is a partnership between local authorities and businesses to help determine local economic priorities and lead economic growth and job creation. The New Anglia LEP seeks to maximise the opportunities currently being supported as well as those areas, such as the Market Towns, where economic activity could be boosted through appropriate intervention.

1.24 The town centres across the District perform a valuable retail function and provide services and facilities for their communities and surrounding rural areas. The individual identity of each town centre is a key feature and this makes them attractive as destinations for visitors to the area. Town centres are increasingly a focus for leisure, business and social interaction as well as shopping

1.25 The tourism industry is a key contributor to the local economy. In 2017, £325million was spent as a result of tourism. The Economic Impact of Tourism Report published in 2017 estimated that across the District 6,163 jobs were generated as a result of tourism spend, which equated to 12% of total employment in the District.

1.26 People living in, working in, or visiting Suffolk Coastal rely upon the transport networks. The transport networks made up of roads, railways and cycle ways are vital to the creation of healthy communities and serve rural and urban areas of the District. The Council will continue to work in partnership with Highways England, Network Rail and Suffolk County Council to ensure appropriate transport infrastructure is delivered over the plan period.

1.27 Travel to work data from the 2011 Census shows the importance of travel by private motor vehicles in the District. Public transport services are varied across the District with most use being seen in the southern parts of the District on routes connecting Ipswich to Felixstowe, Ipswich to Woodbridge and other market towns.

1.28 Railway Lines in the District connect Felixstowe, Saxmundham, Woodbridge and some rural areas of the District with Ipswich and Lowestoft as well as on to London, Norwich and Cambridge. Rail capacity is limited and it is a challenge to reconcile demand for passenger and freight services over the plan period. Strategic improvements to the rail lines have taken place in recent years and others are anticipated to come forward in the future.

1.29 The only trunk road in the District is the A14 that connects Felixstowe with Ipswich, Cambridge and the Midlands. The A14 is an important freight route and is fundamental to the success of the Port of Felixstowe and communities surrounding Ipswich. At times the A14 can become blocked which creates major impacts for residents, visitors and businesses in the area as there is no suitable alternative route. Over the plan period managing the capacity of the A14 as well as considering alternative strategic routes will be necessary. The Council fully supports the ongoing work of Suffolk County Council in considering potential options for routes to the north of Ipswich.

1.30 The A12 provides the main route north and south through the District and is important to many communities. It is a mixture of dual carriageway and single carriageway and serves a number of settlements. Improvements to sections of the road are proposed at various locations, most notably around the villages of Farnham, Little Glemham, Marlesford and Stratford St Andrew.

1.31 Besides these A roads, various B and C class roads serve the rest of the District. Many of these local roads are single track with passing places which reflects the rural nature of the District but poses challenges in respect of the accessibility of some settlements.

Key Issues

1.32 The table below identifies a series of key issues which the Suffolk Coastal Local Plan will seek to address. These issues have been identified through the Sustainability Appraisal Scoping Report, the evidence base and public consultation responses.

Theme Suffolk Coastal Issues
Social
Population
  • Despite relative affluence of the District there is still a need to address pockets of deprivation.
  • Increasing number of young people leaving the District and a large rural population.
  • District’s population is older than the county, regional and national averages.
  • Suffolk Coastal expects to see more deaths than births (2014-2024).
 Housing
  • High house prices and high numbers of second homes.
  • Impact of ageing population on housing supply and increased demand for specialist housing.
 Health & Wellbeing
  • Improving access to opportunities for regular physical activity.
  • Ageing population with high proportion population with long-term health problems and disabilities.
  • Limited access to health provision in the rural areas.
  • Addressing fear of crime.
 Education
  • Distance to both primary and secondary schools in rural locations.
  • Ensuring the local population can access employment opportunities.
Environmental
 Water
  • High number of existing groundwater and surface water Nitrate Vulnerable Zones.
  • Number of Groundwater Source Protection Zones
  • Timely provision of new water services and infrastructure.
 Air
  • Two Air Quality Management Areas.
  • Reliance on private motor cars and lack of public transport provision.
  • Requirement for clean vehicle infrastructure to encourage uptake of new technologies.
 Material Assets (soil and water)
  • Limited availability of previously developed land.
  • Need to manage waste in accordance with the waste hierarchy.
  • Extensive areas of high quality agricultural land.
  • Need to protect and enhance sites designated for their geological interest.
 Climate change, flooding, coast and estuaries
  • Low lying areas at risk of flooding.
  • Need to ensure sustainable construction techniques and green infrastructure is employed to mitigate climate change.
  • Need to ensure appropriate response to sea level rise and coastal erosion.
  • Need to increase renewable energy provision.
  • Large areas protected for species and habitat value which come under pressure from increased recreational and tourist activity.
 Biodiversity
  • Need to extend and enhance the green infrastructure across the Ipswich Housing Market Area.
  • Need to ensure that areas of biodiversity value are protected and enhanced.
Cultural
  •  High number of heritage assets.
 Landscape
  • Delivering high quality design that respects local character.
  • Managing development while protecting significant areas of environmental protection.
  • Significant areas of AONB across the District.
Economic
 Economy
  • Competition for land for housing.
  • Promoting growth in key employment sectors.
  • Limited range of employment opportunities in rural areas.
  • Limited employment land availability with limited large business unit provision outside Felixstowe.
  • Changing nature of town and district centres.
 Transport and connectivity
  • Distances between key services and facilities in rural areas.
  • Reliance on private motor car and lack of public transport provision.
 Digital Infrastructure
  • Rural isolation and poor access to fast Broadband and reliable mobile coverage in rural areas.
  • Access to fast broadband in rural areas.

District-Wide Statistics

009 District Wide Statistics[3]

3. Data sources provided in Appendix I - Glossary and Acronyms [back]

What is the Local Plan?

1.33 The Local Plan sets out the level of growth which needs to be planned for in Suffolk Coastal and identifies where this should be located and how it should be delivered. The Plan sets out the planning policies which the Council will use to determine planning applications across Suffolk Coastal. This Local Plan will cover the period 2018-2036.

1.34 This Local Plan will replace the Core Strategy and Development Management Policies (2013), the Site Allocations and Area Specific Policies DPD (2017), the Felixstowe Peninsula Area Action Plan (2017) and the remaining 'saved' policies in the 2001 Local Plan. It will not replace the policies in 'made' Neighbourhood Plans, but some Neighbourhood Plans or parts of them may need to be reviewed to be in general conformity with this Local Plan.

1.35 Suffolk Coastal District Council has been working in partnership with Waveney District Council since 2008 and most of the services are shared across the two Councils. To build on this decade of cooperation, give greater value for money and at the same time improve service delivery, including driving and investing in growth and infrastructure projects, the two Councils agreed to create one Council. In February 2018 the Secretary of State for Housing, Communities and Local Government agreed the shared proposals to create a new single East Suffolk Council. In May 2018, Parliament made the Orders required to create East Suffolk Council which will come into existence on 1st April 2019 and the two existing councils will be formally dissolved.

1.36 This Local Plan will continue to provide the vision, strategic priorities, policies and proposals against which planning applications will be determined, for the geographic area covered by Suffolk Coastal District until such time as the new East Suffolk Council decide to review the Local Plan.

Consultation

1.37 In August 2017, the Council published a Local Plan Issues and Options document for consultation. The Issues and Options consultation document (prepared and consulted upon in conjunction with Ipswich Borough Council) highlighted a variety of issues facing the communities of Suffolk Coastal. The responses received from the Issues and Options consultation informed the First Draft Plan.

1.38 The First Draft Plan was published for public consultation in July 2018. It took the form of the final Local Plan and was informed by comments received and the evidence base which has been prepared to justify the proposals and policies.

1.39 The Final Draft Plan has been informed by the responses to the earlier consultation periods and revised evidence base. The document is being published in January 2019 to invite representations in relation to soundness. Comments received on the Final Draft Plan will be considered by the Planning Inspectorate once the document is submitted for Examination by Suffolk Coastal District Council in March 2019.

Duty to Co-operate

1.40 The Duty to Co-operate is a legal duty on all local planning authorities, county councils and public bodies to engage constructively, actively and on an ongoing basis to maximise the effectiveness of Local Plan preparation in the context of strategic cross boundary matters.

1.41 Suffolk Coastal has engaged constructively with all partners during the preparation of this Local Plan and in the preparation of neighbouring authorities' Local Plans at the relevant times. The Council's main strategic relationships are with Babergh District Council, Ipswich Borough Council and Mid Suffolk District Council along with Suffolk County Council and Waveney District Council.

1.42 The Council has worked with the neighbouring authorities of Babergh, Ipswich and Mid Suffolk to identify the boundaries of the housing market area and the functional economic areas. Collectively it is considered that the housing and economic needs of the authorities can be met within the existing administrative boundaries.

1.43 In respect of infrastructure, the Council has worked positively with infrastructure providers such as the local Clinical Commissioning Group, the NHS, Suffolk Constabulary, UK Power Networks, Essex & Suffolk Water, Anglian Water and Suffolk County Council. This engagement will be ongoing during the implementation of the Local Plan.

Neighbourhood Plans

1.44 Neighbourhood Plans are optional plans prepared by the local community which set out the detailed planning policies and proposals for their specific area. Once 'made,' they form part of the Development Plan against which planning applications are determined. Across Suffolk Coastal, a number of communities have committed to undertaking Neighbourhood Plans to guide the future of their communities. In January 2015, the Rendlesham Neighbourhood Plan was the first to be 'made' in Suffolk. Since then other communities have also 'made' their plan.

  • Framlingham - made March 2017;
  • Great Bealings - made March 2017;
  • Leiston - made March 2017;
  • Martlesham - made July 2018;
  • Melton - made January 2018;
  • Wenhaston with Mells Hamlet - made July 2018.

1.45 Over the plan period, it is expected that further Neighbourhood Plans will be 'made' and these will need to be in conformity with the policies within the Local Plan.

1.46 All the policies in the Local Plan are 'strategic policies'. This means that policies and proposals within future Neighbourhood Plans should be in general conformity with these policies. The policies do provide flexibility for Neighbourhood Plans to develop their own locally specific policies and in a number of policies there is specific reference to the types of policies that Neighbourhood Plans may choose to include. However, Neighbourhood Plans may cover other topics and provide local detail in relation to other policy areas where appropriate.

Marine Plans

1.47 The marine environment (up to the high water mark) in Suffolk Coastal is covered by the East Inshore and East Offshore Marine Plans. These plans need to be considered alongside this Local Plan for developments which are within the marine plan areas and for developments which could impact upon the marine plan areas. The Marine Plans contain policies relating to a range of marine related issues including economy, tourism and recreation and culture. The Marine Plans have been taken into account in the preparation of this Local Plan, where relevant.

1.48 To ensure that Marine Plans and Local Plans are complementary, the Council will work in partnership with the Marine Management Organisation. Partnership working will enable the right activities to take place in the right place and in the right way, thus placing sustainable development at the centre of all decisions.

Sustainability Appraisal

1.49 Sustainability Appraisal is an iterative process which must be carried out during the preparation of a Local Plan. Its purpose is to promote sustainable development by assessing the extent to which the emerging Local Plan, when considered against alternatives, will help to achieve relevant environmental, economic and social objectives. A Sustainability Appraisal has been undertaken on all the different policy and site options considered during each stage of Local Plan preparation. The Sustainability Appraisal also considers the cumulative effect of the Local Plan on sustainability objectives.

Habitats Regulations Assessment

1.50 An assessment is required under the EU Habitats Directive[4] to ensure that the Local Plan will not result in harm to the integrity of European protected sites. A Screening Assessment was undertaken to inform the First Draft Local Plan which identified those policies in the plan for which an Appropriate Assessment would be required as the plan moves forward.

1.51 To support the Final Draft Plan, the Council have undertaken a Habitats Regulation Assessment to inform the policies and site allocations within it. The assessment ensures that the legal and regulatory requirements outlined under the EU Habitats Directive are adhered to as part of the plan making process.

4. Directive 92/43/EEC [back]

East Suffolk Business Plan

1.52 In partnership with Waveney District Council, Suffolk Coastal has adopted the East Suffolk Business Plan. The Business Plan, adopted in 2015, sets out an up to date vision and priorities for the East Suffolk area. The vision for East Suffolk is to 'Maintain and sustainably improve the quality of life for everyone growing up in, living in, working in and visiting East Suffolk.' The Business Plan priorities are set out under themes of enabling communities, economic growth and financial self-sufficiency alongside a number of specific planned actions.

1.53 The vision, objectives and strategic priorities of this Local Plan reflect the vision and priorities of the East Suffolk Business Plan.

1.54 On 1st April 2019, East Suffolk Council will be created and the existing Councils of Suffolk Coastal District and Waveney District will be dissolved. The East Suffolk Business Plan will provide the corporate vision for the new Council until it is updated.

Monitoring and Delivery

1.55 Central to the plan making system is the issue of deliverability. In order to be effective Local Plans must be deliverable. The success of the Local Plan will be dependent on the continual engagement and partnership working between the Council, developers, infrastructure providers and other interested stakeholders, including the public as well as Town and Parish Councils. Communities undertaking Neighbourhood Plans will also have a crucial role in expanding upon and adding to the Local Plan policies and proposals to address detailed local circumstances.

1.56 The policies and proposals of the Local Plan will be delivered primarily through planning applications over the plan period. Neighbourhood Plans also have a key role to play in the delivery of the Local Plan policies.

1.57 Sustainability Appraisal, incorporating Strategic Environmental Assessment, has been carried out as part of the production of the Local Plan. A requirement of Sustainability Appraisal is to monitor the likely significant effects of the plan. A monitoring framework with indicators has been developed through the Sustainability Appraisal as a basis for monitoring the significant effects.

1.58 The Council reports on monitoring and delivery annually in its Authority Monitoring Report. In some instances it may be appropriate to alter the indicators being reported, either due to a change in information available or to reflect specific issues that emerge.

1.59 The Policy Delivery Framework in Appendix A and the Monitoring Framework in Appendix C sets out the targets and indicators that are proposed to be used to track the progress of the plan and the policies within it.