Suffolk Coastal Local Plan - Final Draft

Document Section Final Draft Local Plan 12 Strategy for Communities Surrounding Ipswich Land at Felixstowe Road, Nacton Policy SCLP12.20: Land at Felixstowe Road [View all comments on this section]
Comment ID 1230
Respondent The Churchmanor Estates Compan… [View all comments by this respondent]
Agent MRPP (Robeson, Martin)
Response Date 25 Feb 2019
Do you consider that this part of the Plan meets the legal and procedural requirements? Yes
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
  • Justified
  • Effective
Details of Representation

We support the principle of this land being allocated but have reservations/objections to parts of the Policy text.

The site was advanced by our client for review by the Council and its expert advisors on the basis of the site providing for the identified needs for a “Business and/or non Port-related Distribution Park”. Indeed, this description is carried forward into the Council’s Strategic Housing Employment Land Availability Assessment where it has Site Reference 1151. On the basis of those uses or mix of uses, the Council’s consultants Lichfield’s are reported (under Suitability Conclusions) to have advised it to be “an excellent location adjacent to the A14, a short drive from Europa Park and with limited constraints that could not be dealt with through mitigation and appropriate design”. This review also confirmed the site as “suitable, available and achievable”. We concur with this analysis.

Whilst the Policy suggests that the site could be targeted at “business and professional services sectors” on the basis of the Economic Sector Needs Assessment highlighting a need across the District for land for those sectors, neither the Plan nor its evidence base specifically provides a market or strategic planning justification for a limitation otherwise.

Rather there is cogent evidence to support the proposition for a broader (and more flexible) Business and Distribution Park in that there is a significant identified requirement for general and smaller scale B8 distribution space set out in the Economic Sector Needs Assessment for the Suffolk Coastal area, ie to accommodate 24,380sqm of such space (Table 3.6). That figure excludes the 6,940sqm attributed to larger scale, lower density distribution uses which might not be the kind of activity that the Council seeks to accommodate here. However, there is a very substantial requirement for smaller scale B8 distribution space which can logically, attractively and beneficially be accommodated satisfactorily on the site. Indeed, since the July 2018 Draft Plan, the Council has added supporting text into the current Final Plan which explains, “it is vitally important that the Local Plan can appropriately meet the current needs of the logistics sector and have the flexibility to meet future needs (our emphasis). The text provides an important non Port-related example in explaining that “in recent years the changing nature of customer demands, such as online shopping and next day delivery expectation, requires new technology and patterns of distribution to meet the needs of these sectors operating across the District” (4.14).

The reasoned justification to the Policy appears to accept this trend (and the evidence put in response to the Draft Plan) with it accepting (12.194) that “small scale storage and distribution (B8 use) can be appropriate”.

Whilst the Council’s text then seeks to limit the “functional differentiation” between the uses, this can, to the extent necessary, be secured by having appropriate environmental and design criteria within the Policy rather than drafting the Policy’s land use function to exclude B8 use.

Large business parks benefit (in employment and functional terms) from their accommodating a range of complimentary uses on site. These should relate to those that can “functionally relate to the site and the area” rather than the narrower wording, ie “whose primary purposes(s) is to provide a service to business and employees operating in that location”. The current wording would be too restrictive and likely to frustrate market interest from providing desirable facilities. Indeed, the reasoned justification suggests that “such use may include cafes, hotels and childcare nurseries but others may also be acceptable” (12.194). Such examples justify Policy language of “functionality relate to the site and the area”.

We are aware of Highway’s England’s acceptance that further improvements can be facilitated at the A12/A14 junction.

There are, in addition, considerable efficiencies created by locating development as envisaged by the Policy immediately adjoining road infrastructure where its improvement is then the heart of that system, (compared with development located away from such improvements where other parts of the network are then also likely to require improvements but which might not be practicable or viable).

Please set out what change(s) you consider necessary to make the Local Plan legally compliant or sound

The Policy text to SCLP12.20 should be redrafted to

  1. Initially explain the broader range of usage i.e a Business and Distribution Park B1-B8.
  2. Set out that “complimentary uses should be functionally related to the site and the area, ie cafes, hotels and child care nurseries would also be acceptable”.
  3. Set out the environmental, design, highways, water supply, heritage etc, criteria that will guide decision making on planning applications.

Those criteria could be taken from the existing policy text, thus:

  1. High quality contemporary design appropriate to the site’s location in the setting of the AONB, in terms of scale, massing, materials and lighting.
  2. High standards of sustainable construction.
  3. Access to the site required from Felixstowe Road.
  4. The access arrangements to demonstrate no severe impact on the A12 and A14 and the local road network.
  5. Opportunities to enhance the capacity of the Seven Hills junction and access to the Crematorium to be explored.
  6. Appropriate provision for parking, walking and cycling.
  7. Opportunities to enhance and link to the existing Public Rights of Way network encouraged.
  8. A demonstration of the adequacy Water Recycling Centre capacity or that capacity can be made available.
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
If you wish to participate in the public examination, please outline why you consider it to be necessary:

This allocation is a fundamental component of the Plan’s future economic strategy.

Being kept informed
  • Yes, I would like to be kept informed