Suffolk Coastal Local Plan - Final Draft

Document Section Final Draft Local Plan 12 Strategy for Communities Surrounding Ipswich Ransomes, Nacton Heath Policy SCLP12.21: Ransomes, Nacton Heath [View all comments on this section]
Comment ID 657
Respondent Bailey, Alison and John [View all comments by this respondent]
Response Date 21 Feb 2019
Do you consider that this part of the Plan meets the legal and procedural requirements? No
Do you consider this part of the Plan has met the tests of soundness? No
Do you consider this part of the Plan to be unsound because it's not:
  • Positively prepared
  • Consistent with national policy
Details of Representation

We write in response to the Consultation on the final draft of The Suffolk Coast Local Plan (the Plan) produced by SCDC. In particular, we are making representations about the lawfulness and soundness of policies SCLP 12.20 (Land at Felixstowe Road, Nacton), 12.21 Ransomes, Nacton Heath, and SCLP12.30 Innocence Farm.

We reside in Levington in the AONB. In our view, having read the relevant parts of the Plan and weighed it against the requirements for a sound policy and the requirement for SCDC to co-operate with neighbouring councils, we feel that it is wanting. The key reasons for this are outlined below.

Unlawful: Duty to co-operate: BREACH

It appears from the Plan that SCDC has failed to co-operate meaningfully on the provision of employment land with neighbouring local authorities. This is particularly evident in relation to employment land related to the Port of Felixstowe. SCDC’s ‘Cross Boundary Working’ Minutes of 6th September 2018 suggest that there would be discussion with neighbouring councils about economic evidence and plans for the Port, yet no detail is available in further Minutes outlining the results of such discussion. This suggests it was not done.

This omission thus also makes the Plan fail the test of soundness, since para 26 of the National Policy Planning Framework states that: Effective and on-going joint working between strategic policy-making authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. In particular, joint working should help to determine where additional infrastructure is necessary, and whether development needs that cannot be met wholly within a particular plan area could be met elsewhere.

Further, there is no evidence that consultation with other relevant bodies such as logistics companies further along the A14 in neighbouring authorities and into Cambridgeshire has taken place in this instance, in contrast to the full strategic review undertaken in 2008. We understand that there remain some 94 Ha of land in neighbouring districts already with planning permission for Port-related use. SCDC’s Local Plan ignores this evidence.

Overall, the SCDC Local Plan lacks proper consideration of landscape character and sensitivity to development, as for example with the proposal in SCLP 12.21 to develop part of the Suffolk Coasts and Heaths AONB at Ransomes, Nacton Heath.

These points, taken together with the lack of explanation in the Plan of why there has been no proper co-operation, renders the Plan unlawful.

Soundness: The Plan fails to meet the requirements of a sound plan

SCLP 12.20 (Land at Felixstowe Road, Nacton)

SCLP 12.21 Ransomes, Nacton Heath,

and SCLP12.30 Innocence Farm, Trimley St. Martin/Kirton

Positively prepared:

The plan does not use the area’s objectively assessed needs; the strategy is not informed by agreements with other authorities so is in breach of NPPF paragraph 26.

 Further, there is no objectively assessed need for employment land in the plan.

The Plan is not consistent with achieving sustainable development and thus is not positively prepared and conflicts with the NPPF which states, (p.5), that: Planning policies and decisions should play an active role in guiding development towards sustainable solutions, but in doing so should take local circumstances into account, to reflect the character, needs and opportunities of each area. 10. So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development.

The character of the area is not reflected in the plan nor have the needs and opportunities of the area been objectively assessed

Justified: the plan should consider reasonable alternatives. Consideration should be made of land which already has planning permission even if not east of the Orwell Bridge, and of using derelict brownfield sites or sites within the port itself. The Plan fails to do this.

Effective: To be effective, the Plan must be deliverable. It would be totally ineffective with increased traffic volumes in these three locations, (or other sites east of the Orwell Bridge) bringing flow to a standstill. Any increase of traffic flow on the section of A14 which doubles up as the A12 between the Copdock interchange and Seven Hills should be avoided if the plan is to be effective. Traffic is already congested at key times at the Seven Hills roundabout. In addition, when the Orwell Bridge is closed either as a result of strong winds or because of an accident, the congestion on that whole section of the A14/A12 is severe. This then has the knock-on effect of physical damage to villages’ verges and properties as drivers (including HGV drivers) seek alternative, often wholly inappropriate routes. This increases air pollution, noise interference and light pollution if in the hours of darkness. It has been demonstrated elsewhere that 15 x as much small particulate matter is emitted from lorries idling/turning/stopping/starting compared to when they are driving smoothly on a major arterial routeway. It is estimated that should Innocence Farm (SCLP 12.35) be developed there would be 3200 HGV vehicle movements to and from the site each day. If so, it is clear that the Air Quality Standards limits of sulphur dioxide, nitrogen, benzene, CO, lead and PM10 in ambient air would be exceeded by a very high, dangerous, unlawful level, having a detrimental effect on health, not just at that site but in the surrounding countryside and residential areas.

The Plan ignores brownfield sites and those already approved which could be developed. This is in breach of NPPF 2018 paragraph 118.

Inconsistent with NPPF:

The SCLP does not contribute to sustainability, but rather conflicts with this environmental objective and is thus inconsistent with national policy.

The three specific areas mentioned in this letter are green field sites. There are already brownfield sites with appropriate permissions. It is common knowledge that green plants photosynthesise and act as a ‘lung’ to absorb carbon dioxide and give out oxygen, as well as absorbing some of the other emissions from vehicles already using the roads. More traffic associated with other developments proposed elsewhere in the Plan would make such ‘green lungs’ even more vital.

These sites are currently high quality, productive agricultural land, growing food for human consumption. If such land is taken out of production, there will need to be more transportation to bring food to this area, an increase in imports which will necessitate more transportation, more pollution, less quality control over the products, and a never-ending cycle of further destruction.

In relation to site 12.21 Ransomes, Nacton Heath, the eastern part is sited within the AONB and thus conflicts with the NPPF. Arguing in 12.199 that because it is separated from areas of the AONB to the south by the A14 road does not improve the argument. Indeed, retaining an undisturbed habitat for wildlife, and plant life which can photosynthesise and act as a ‘lung’ to absorb carbon dioxide and give out oxygen would become more critical should traffic volumes increase. This site, as well as 12.20 and 12.30 would remove a vital ‘Habitat stepping stone’ (See SCLP 10.1: Biodiversity and Geodiversity) and ‘will have a direct or indirect adverse effect …. on locally designated sites or biodiversity’ and as such should ‘not be supported unless it can be demonstrated that the benefits of the proposal, in particular its location, outweighs the biodiversity loss’. Allowing development of this kind on the AONB conflicts both with SCDC’s stated aims and with national policy. For example, the Plan states at paragraph 10.32 that AONBs are national landscape designations afforded the highest protection for their landscape and scenic quality. Protection of the Suffolk coast and Heaths relates not only to the land within this AONB but also to its setting. In line with national policy great weight is attributed to conserving and enhancing the landscape and scenic beauty in the AONB and the conservation and enhancement of wildlife and cultural heritage are important considerations.

Returning to a consideration of all three of these sites located in the Felixstowe peninsular, the proposal to develop these sites would increase the coalescence of Felixstowe and Ipswich and damage the ‘setting’ of the AONB, conflicting with local and national policy. The map (3.36) entitled ‘Key diagram’ on p. 37 of the Final Draft Local Plan, January 2019, is misleading in the extreme since it implies that ‘East Ipswich’ is already built up or, to use the term in the diagram, ‘a major centre’. This is patently not true. Much of that area is agricultural land, woodland or heath.  Similarly, the cartographer misrepresents the size and scale of Felixstowe, giving a totally misleading view of the settlement hierarchy. A stated strategic objective of SCDC is to ‘maintain the geographical separation of Ipswich and Felixstowe’. Development of the sites referred to above would undermine this objective as well as altering the character of those two towns and the landscape between, the ‘setting’ for the AONB.

The Local Plan as a whole fails to recognise that the settlement analysis, which forms the starting point for identifying potential locations for site allocations (SCLP p.192, paragraph 12.16) cannot be complete without a study of the relationship between settlements inside and outside the administrative boundary. In contrast, The Epping Forest Settlement Hierarchy Technical Paper shows a clear grasp of central places that is not apparent in the SCDC Plan. Similarly, the North York Moors Local Plan looksat groups of villages rather than individual settlements, recognising their interdependence and relationship with one another and considering the whole group in terms of suitability for different types of development.’ Thus, to be effective, the Plan should take a more holistic view of the region.

In addition, the ‘Key diagram’ (p.37. 3.36) shows outline planning permission for 2000 new homes at Brightwell Lakes. Since outline PP has already been granted here, it makes it strengthens the case for the Local Plan being unsound/inconsistent with Policy since development of other greenfield sites between Ipswich and Felixstowe would reduce the geographical separation between these two towns and be contrary to the claim on p. 4 of the Local Plan, ‘Environmental Context’, paragraph 1.13 that ‘Suffolk Coastal’s landscape is diverse, including large areas of farmland, which support a rich biodiversity’ as continual erosion of the natural environment will necessarily reduce the diversity of landscape and of the biotic life.

National and local policies point towards the important and valuable contribution of high-quality natural environment to quality of life, quality of place and mental health. Although at 10.17 the Plan suggests implementation of Suitable Alternative Natural Greenspaces (SANGs) where huge concentration of housing development is planned, as for example at Brightwell Lakes, these are a poor substitute for the natural environment both for people and for the richness of flora and fauna.

Areas of ‘Great Landscape Value’, the setting for the AONB, would disappear if the development at either Felixstowe Road, Nacton, Ransome’s, Nacton and/or Innocence Farm were to take place. The AONB would become irreversibly damaged by noise, light pollution, particulate matter and air pollution both directly (at the eastern section of Ransome’s) and indirectly by its setting. Even with ‘mitigating effects’ such as bunds, the noise, light, vibrations, and air pollutants will be heard/seen/felt/breathed by people and wildlife alike upsetting natural rhythms. We note that SCLP 12.35 Land at Innocence Farm suggests (p.301) bunds only to the northern and eastern parts. This leaves the AONB and areas to the south and west totally exposed in this flat landscape to the lighting, noise, vibrations and pollutants. This would be wholly unacceptable and against national policy. It should be noted that lorries reversing, as they would at a logistics site, not only would emit a minimum of fifteen times the amount of pollutants but would also make a beeping noise in addition to the engine noise. Situated as it is almost equidistant from the AONB to the north/north-east and to the south/south-west both areas of the AONB as well as the adjacent settlements would be adversely affected under most meteorological conditions.

More appropriate and more in line with the stated desire for Suffolk to be ‘the Greenest County’ would be for SCDC to have a broader vision and work towards the AONB being extended to cover the swathe of land between the Rivers Deben and Orwell.

We thus invite you to conclude that the Plan as it affects land at Felixstowe Road, Nacton, Ransome’s, Nacton and Innocence Farm, is unlawful and unsound.

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