Suffolk Coastal Local Plan - Final Draft

Document Section Final Draft Local Plan 12 Strategy for Communities Surrounding Ipswich Brightwell Lakes Policy SCLP12.19: Brightwell Lakes [View all comments on this section]
Comment ID 1213
Respondent Landform Martlesham Ltd (Sir/Madam) [View all comments by this respondent]
Agent Barton Willmore (Hanson, Edward)
Response Date 22 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:
  • Justified
  • Effective
  • Consistent with national policy
Details of Representation


1.1 Barton Willmore is instructed on behalf of Landform Martlesham Ltd (Landform) to prepare representations in respect of the Final Draft Local Plan (FDLP) for Suffolk Coastal District Council (SCDC). The Regulation 19 FDLP will cover the period 2018-2036.

1.2 Landform controls a 17.5ha site lying to the east of Felixstowe Road and the south of Three Stiles Lane in Martlesham, located approximately 9.3km to the east of Ipswich Town Centre and 3.5km southwest of Woodbridge. Landform is promoting the site for a mix of residential C2 and C3 uses (including a proportion of Self Build and Custom Build).

1.3 Landform has previously made representations to the Site Allocations and Area Specific Policies Document dated 31 May 2016, the Call for Sites dated 31 October
2016, the Issues and Options Local Plan dated 27 October 2017 and most recently to the First Draft Local Plan dated 13 September 2018.

1.4 To assist SCDC with the next stage of the Local Plan, we set out our response to the FDLP in Chapter 3. Landform considers the FDLP only meets in part the objectives of the National Planning Policy Framework (NPPF), and we raise concerns with three matters, namely:

1. Accommodation of Full Objectively Assessed Housing Need (OAHN),
2. Failure to provide an adequate level of housing and in Martlesham in
particular, and;
3. Failure to provide accommodation of specialist housing (Use Class C2 and age
restricted C3).


2.1 The revised National Planning Policy Framework (NPPF) was adopted by Central Government on 24th July 2018. Paragraph 35 of the NPPF relates to the examination of local plans and sets out the tests of soundness which will be used to assess whether a plan should be adopted. Plans are considered ‘sound’ if they are:

“ (a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development ;
(b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
(c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than defer red, as evidenced by the statement of common ground; and
(d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework ” .

Soundness Summary

2.2 With the above guidance in mind our representations consider the following soundness tests.
2.3 Under ‘justified’ we consider if the FDLP meets full OAHN and allocates the correct level of housing sites
2.4 Under ‘effectiveness’ we consider if the FDLP places too much reliance on strategic sites with a history of under delivery.

2.5 Under ‘consistent’ we examine whether the FDLP complies with national planning policy guidance.



3.1 In September 2018 Landform identified the following issues with the First Draft Local Plan (Regulation 18). The FDLP does not appear to have addressed these
1. Failure to meet full OAHN by 14% (76 dpa), and;
2. Failure to provide an adequate level of housing in Martlesham.

Key Issues

3.2 The Key Issues for the district are set out in Section 1 of the FDLP. In respect of housing, paragraph 1.32 highlights two key issues. Firstly, the high house prices and high numbers of second homes. Secondly, the impact of an ageing population on housing supply and increased demand for specialist housing.
3.3 The overall Vision for the district is set out in Section 3. At paragraph 3.18 (Boosting the Supply of Housing), the following issues are identified:

  • Increasing choice in the housing available;
  • Meeting the housing needs of all sectors of the population, including the growing elderly population; and,
  • Delivering more affordable housing.

Objectively Assessed Housing Need

3.4 In our Regulation 18 Local Plan representations we identified that the housing targets for Suffolk Coastal District should be increased, in order to accord with the Standard Method required by the National Planning Policy Framework (NPPF) (July 2018). The Regulation 18 Local Plan proposed 545 dpa /10,900 dwellings over the plan period (2016-2036).

3.5 The Standard Method has now informed the housing targets and increased it to 582 dpa / 10,476 dwellings. However, when correctly applying the Standard Method, the increase should result in an OAHN of 621 dpa (see Appendix 1), which equates to 12,420 dwellings over the plan period. The FDLP target therefore represents a shortfall of 39 dpa or 780 dwellings over the plan period. Consequently, additional sites, in sustainable locations, need to be identified to meet the shortfall and this exercise must be undertaken in advance of next stage of the Plan in order that it meets the test of soundness. NPPF requires the housing requirement arising from the application of the Standard Methodology to be considered a minimum.

Spatial distribution of residual housing requirement

3.6 Existing planning permissions account for 6,998 dwellings out of the FOAN figure of 10,476 leaving a requirement of 3,478 dwellings. Of these 11% are proposed in ‘Communities surrounding Ipswich’ (Paragraph 3.39 – Table 3.3) such as Martlesham Village.

Housing Delivery Test

3.7 The 2018 NPPF Housing Delivery Test is applicable to the Plan and we emphasise the requirements of Paragraph 7. The Test, which is to be applied on an annual rolling basis across the plan period, looks to the previous three-year housing delivery compared to the housing delivery target. Failure to meet the delivery target (in this context meaning less than 95%) means the local authority will be required to put in place an action plan; at less than 85% authorities will need to identify a 20% buffer and at less than 25% delivery there will be a presumption in favour of sustainable development. The most effective mechanism for the Council is to ensure that it has identified sites that are genuinely deliverable at the rate required and to build in some level of flexibility in supply to allow for the inevitable delays in delivery that occurs, particularly on larger sites.

3.8 A strategic development site (Draft Policy SCLP12.19) is identified at Brightwell Lakes (formerly Adastral Park) and outline planning permission (ref. DC/17/1435/OUT) was approved in April 2018 for 2,000 dwellings, employment, local centres, education, green infrastructure, community uses and associated infrastructure. Since outline planning permission was granted, two separate reserved matters applications have been submitted to SCDC to allow delivery of the Site Entrance and Boulevard (ref. DC/18/2774/ARM) and Green Infrastructure (ref. DC/18/2775/ARM). An application for the discharge of conditions pursuant to the outline permission has also been submitted. While these applications were registered in July 2018, a decision has yet to be issued by SCDC.

3.9 It is noted that the housing delivery trajectory set out in the Planning Statement (Table 23.1) attached to the outline planning application indicates that, in accordance with Policy SP1A of the Core Strategy, it is expected that annual occupations will be 150 dwellings per annum in the years 19/20 and 20/21 and 125 dwellings in 21/22. It is anticipated that a steady occupation rate of 160 dwellings per annum will be achieved from 22/23 to 30/31.

3.10 It is proposed that years 16/17, 17/18 and the early part of 18/19 “would involve the establishment of various consents including outline planning permission,
infrastructure details, Highway Act consents and Reserved Matters for the early phases”.

3.11 This delivery rate would appear to be optimistic and based on our considerable experience across similar sites on a National basis is unlikely to be achieved, and yet an even more optimistic delivery trajectory is put forward in the Council’s Housing Land Supply Statement 2018. It states:

“Of all the sites in the district, the largest single source of housing supply is at the land south and east of BT Adastral Park…The landowner has responded to our request for information about expected completions confirming that they intend to deliver homes from year 2019/20 with an
expectation that it will deliver up to 260 homes per year in following years. The Council has approved measures through phasing, conditions and trigger points to open up more of the site in the first phase. Based on the rapid progress on infrastructure the Council is confident completions will commence in the 2nd year of this assessment period. The Council will closely monitor completions on this site and expects future assessments to show completions at the rate put forward by the landowner. However, for this first years of the site’s development (up to 2022/23), a conservative approach has been incorporated, based on the first phases completing at a rate of up to 150 homes per year”.

3.12 While the Council states that it is confident in the trajectory provided by the Applicant, with the first round of reserved matters still to be approved, and no subsequent reserved matters submitted for the proposed dwellings, there is clearly already slippage in the proposed delivery rates, even when a conservative approach is taken in the first phases. It is also worth considering that this site has faced delays in the past having been allocated as long ago as the 2013 Core Strategy.

3.13 In the context of the Housing Delivery Test, the Council will need to be certain that this site and other strategic allocations are deliverable in the timeframes outlined. Furthermore, and as a direct result of the prolonged delay at Adastral Park, the Council must apply a 20% buffer when calculating five-year housing supply.

Settlement Hierarchy

Martlesham- A Key Location for Future Growth

3.14 Martlesham has a population of 5,478 (2011 census) and is classified as a ‘Large Village’ (Policy SDCLP3.2) falling within the Eastern Ipswich Plan Area (EIPA). Given its proximity to Ipswich, a major centre of employment, as well as the strategic allocation at Brightwell Lakes, it should be identified as a key location for future

3.15 Martlesham is located on the main strategic road network and, as such, the village offers excellent connections to the major urban centres of both Ipswich and
Woodbridge, with a regular bus service operating between the two settlements. Notwithstanding its proximity to these larger settlements, the village also benefits
from a good range of day to day services, including two public houses and Beacon Hill Primary School. There are further facilities located a short distance away in
Martlesham Heath, including a GP surgery and a Tesco superstore which adjoin Adastral Park, a major regional employment area. All are within an extended walking
distance and within easy cycle range utilising a National Cycle Route that passes in front of the Site.

3.16 The ease of access to local jobs, together with the range of existing services and facilities on offer within the village makes Martlesham one of the Suffolk Coastal’s most sustainable locations. As such, it is logical and appropriate that Martlesham should form a key component of Suffolk Coastal’s spatial strategy.

New Housing in Large Villages

3.17 Paragraph 3.46 (Table 3.4) of the FDLP sets out a ‘Summary of approach to Large Villages’. New housing will be located in ‘New housing allocations (Section 12)’ and ‘New housing development and infill within Settlement Boundaries (SCLP5.1)’. Section 12 contains Area Specific Strategies. Policy SCLP12.1: Neighbourhood Plans states that ‘Where Neighbourhood Plans seek to plan for housing growth, they will be expected to plan for the indicative minimum housing requirements’ . In the case of Martlesham this is just 20 dwellings plus Policy SCLP12.25 (Suffolk Police HQ, Portal Avenue).

3.18 As set out in our previous representation, Landform consider a total allocation of 20 dwellings is wholly inappropriate and, given this is a designated Large Village with key services. We believe there is need and capacity to accommodate further dwellings over the Plan Period to ensure the Full OAHN is met.

Sheltered and extra care housing

3.19 Landform supports draft Policy SCLP5.8 which recognises the importance of providing sheltered and extra-care housing across the District. In addition, the policy states that sheltered and extra care housing will be supported where the scheme incorporates a mix of tenures and sizes to meet identified need.

3.20 The Strategic Housing Market Assessment for Ipswich and Waveney Housing Market Areas (SHMA) (2017) includes an assessment of the needs for specialist
accommodation (sheltered housing, enhanced sheltered housing and extra care housing) and identifies a need for a total of 1,287 units by 2036. The SHMA also
identifies a need for a further 1,118 spaces in Registered Care (nursing and residential care homes) over the plan period. However, the SHMA explains that ‘traditional forms of provision will not always match modern demands and it is considered that some of this need will be met through the provision of housing, and therefore it is important that the mix of housing helps to address these needs. Provision for sheltered and extra care housing and registered care will be secured through larger residential allocations where feasible, as part of a mix of housing types.’

3.21 Whilst some allocated housing sites specifically require provision of sheltered and/or extra care housing no specific numbers are apportioned to these sites. It is therefore not possible to understand how, and on which sites, the identified need will be met. The following draft allocations include provision of homes for ‘older people’ but C2 use is only specified on the site at Rose Hill in Saxmundham. This is a 3ha site, planned for mixed use, and can only accommodate a small number of the total C2 identified need. Therefore, there is a need to identify further sites for C2 use.

  • Policy SCLP12.3: North Felixstowe Garden Neighbourhood - Up to 2,000 dwellings providing a mix of dwelling types, sizes and tenures including
    housing to meet the specialised housing needs of older, younger and vulnerable people and self-build plots, and provision of affordable housing.
  • Policy SCLP12.5: Land at Brackenbury Sports Centre - Approximately 80 dwellings including housing for older people.
  • Policy SCLP12.27: Land rear of Rose Hill, Saxmundham Road, Aldeburgh - 3ha of land for a mixed development comprising a care home and open market
    housing for approximately 10 units
  • Policy SCLP12.29: South Saxmundham Garden Neighbourhood - Approximately 800 dwellings of a range of types, sizes and tenures including housing to meet the needs of older people and younger and vulnerable people, and provision of self build plots.
  • Policy SCLP12.44: Land south of Forge Close between Main Road and Ayden, Benhall - approximately 50 dwellings including provision of properties that
    would be suitable for older persons.
  • Policy SCLP12.50: Land off Laxfield Road, Dennington - approximately 50 dwellings including provision of dwellings designed to meet the needs of the
    older population.
  • Policy SCLP12.51: Land to the south of Eyke CoE Primary School and East of The Street, Eyke - approximately 65 dwellings including provision of a mix of
    housing including housing designed to meet the needs of older people.
  • Policy SCLP12.52: Land to the West of Chapel Road, Grundisburgh – approximately 70 dwellings including provision of a mix of housing including
    housing including types designed to meet the needs of older.
  • Policy SCLP12.59: Land adjacent to Swiss Farm, Otley - approximately 60 dwellings including provision of housing that would meet the needs of older
  • Policy SCLP12.61: Land between High Street and Chapel Lane, Pettistree (adjoining Wickham Market) - approximately 150 dwellings including a mix of
    dwelling types including housing to meet the needs of older people and provision of self build plots on a developed area of approximately 4ha within
    the site.
  • Policy SCLP12.66: Land adjacent to Reeve Lodge, High Road, Trimley St Martin - approximately 150 dwellings including housing for older people and the
    provision of self-build plots.
  • Policy SCLP12.69: Land west of the B1125, Westleton - approximately 20 dwellings including dwellings to meet the needs of older people.

3.22 The draft policy allows for some of the sheltered and extra care need to be met through windfall sites. However, these sites by their nature tend to be smaller sites without the potential to deliver a modern format care village, which requires sites of circa 3ha to 4ha (8 to 10 acres) and Landform believes additional sites should be identified now.

3.23 The Plan must also be clear in terms of the split between C2 and C3 housing. Whilst not explicit, it appears that C2 accommodation is not included within the overall district housing target, but C3 sheltered housing is. The SHMA proposes two sheltered and extra care housing targets but does not provide a use class breakdown. Whilst is assumed that 1,118 spaces in registered care falls within C2, the 1,287 sheltered and extra care dwellings will presumably include both C2 and C3. Further clarification is required otherwise it will not be possible to adequately plan for these uses.

Self-Build and Custom Build Housing

3.24 Draft Policy SCLP5.9 supports the provision of self-build and custom build plots and requires large developments (100 dwellings or more) to provide 5% provision of serviced plots for sale to self-builders or custom builders.

3.25 Landform agrees that such housing can make an important contribution to housing supply and draft Policy SCLP5.9 is therefore supported.

Test of Soundness 1: Is the Document ‘Justified’? & Test of Soundness 2: Is the Document ‘Effective’?

3.26 Whilst the FDLP has been informed on the basis of supporting evidence, it still does not meet the full OAHN and does not allocate sufficient sites to be sound. There is a significant shortfall in the amount of sites needed to meet the identified C2 need and of the appropriate size to meet the requirements of a modern format care facility. Furthermore, the FDLP relies on a strategic site (Policy SCLP12.19) that has a history of under delivery and no clear certainly of coming forward in the timescales outlined.

3.27 As drafted the FDLP is neither fully justified or effective and it requires amendment in order to meet the test of soundness.


4.1 Landform control some 17.5ha of land to the east of Felixstowe Road and the south of Three Stiles Lane, Martlesham.

4.2 Landform is promoting the site for a mix of residential C2 and C3 uses (including a proportion of Self Build and Custom Build). A Masterplan is included at Appendix 3 and provides for approximately 275 dwellings, including both open market and affordable units. Based on our technical work to date and following initial discussions with Suffolk County Council’s Highways Department, it is proposed that the development is accessed via two points of access off Felixstowe Road.

Access and Sustainability

4.3 The site is well related to Martlesham village with frontage to Felixstowe Road and Three Stiles Lane, giving easy access to the facilities in Martlesham and Martlesham Heath, the A12, Ipswich and Woodbridge. Tesco and the Adastral Park employment area are within extended walking and cycling distance from the site.
Within the Issues and Options representation (October 2017), Landform set out proposals for vehicles, pedestrians and cyclists in more detail.

Landscape Framework

4.4 The initial technical work prepared in support of the proposals has demonstrated that the site is largely free from environmental constraints and abnormal infrastructure requirements.

4.5 We reiterate that the potential development of the site is a logical extension to the settlement both in landscape and visual terms. The location of the AONB to the
eastern boundary can be mitigated through a landscape led design approach along with detailed design consideration at future stages. Careful consideration will also be given to views from the residential edge and the existing public right of way to the north of the site.


4.6 The accompanying technical studies and illustrative masterplan demonstrate that the proposal is deliverable and is capable of providing much-needed market and affordable housing, whilst also delivering new community infrastructure and recreational opportunities. The Site is fully deliverable and can therefore make a
meaningful contribution to SCDC’s housing need over first five years of the new plan.

If your representation is seeking a change, do you consider it necessary to participate in the public examination?
  • Yes, I wish to participate at the oral examination
Being kept informed
  • Yes, I would like to be kept informed