Suffolk Coastal Local Plan - Final Draft

Document Section Final Draft Local Plan 12 Strategy for Communities Surrounding Ipswich Land at Humber Doucy Lane, Rushmere St Andrew Policy SCLP12.24: Land at Humber Doucy Lane [View all comments on this section]
Comment ID 1301
Respondent Save Our Country Spaces (Robin… [View all comments by this respondent]
Response Date 25 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
Details of Representation

THE FOLLOWING ISSUES NEED TO BE FULLY ASSESSED & ADEQUATELY ADDRESSED IN ORDER FOR THE CORE STRATEGY REVIEW TO BE ‘SOUND’.

NB SOCS wish to give oral evidence at Inspection.

WE SUGGEST THE PLANS ARE UNSOUND AND DO NOT COMPLY WITH THE NATIONAL PLANNING POLICY FRAMEWORK (NPPF)

The “Climate Change” agenda is insufficiently addressed. Proposals are contrary to;
NPPF 10. Meeting the challenge of climate change, flooding and coastal change.

It appears that environmental, social and economic effects of the plan(s) are inadequately and inaccurately assessed against Habitats Regulations Assessments and the Sustainability Appraisals (SAs)

“Serious adverse effects” have not been properly identified, as required under compliance with the NPPF (Achieving Sustainable Development NPPF 6-17) for either the CS or development and control purposes.

This situation is likely to render any planning application almost impossible to determine properly and therefore, we say, render the major IGS planning applications problematic. It also potentially renders stakeholder responses to planning applications a problem.

NPPF-11 Conserving and enhancing the natural environment is not adequately taken into account.

TAKING FULL ACCOUNT OF CUMULATIVE AND COMPOUND EFFECTS

The SEA Directive requires that the assessment include identification of cumulative and synergistic effects including those produced by other neighbouring local authorities. The SA does not appear to take account of the cumulative effect of CSs Plans of neighbouring authorities with regard to housing, employment and especially transport/traffic and increased air pollution and traffic congestion.

THE FOLLOWING SPECIFIC ISSUES NEED TO BE FULLY ASSESSED & ADEQUATELY ADDRESSED IN ORDER FOR THE CORE STRATEGY REVIEW TO BE ‘SOUND’.

Growth, must be measured against the potential for serious adverse effects and serious adverse impacts, which included adverse impacts on the Quality of Life and Public Health.
The potential to secure a “sustainable future” for the existing local population, future populations and future generations is an imperative not demonstrated by the plan(s).

1. DRAINAGE, Surface Water Drainage ; APPEARS NON-COMPLIANT and may not work.
2. FLOODING LIKELIHOOD may increase at Westerfield.
3. SEWAGE PROPOSALS INADEQUATE & likely to add to existing problems ( eg recently at Rushmere)
4. TRAFFIC PROPOSALS AND ADVERSE IMPACTS ON EXISTING RESIDENTS- no solutions
5. AIR POLLUTION and impact on our children's health inadequate Air Pollution Action Planning
6. ADVERSE PRESSURES ON HOSPITALS, SCHOOLS & ACCESS TO GPs and SOCIAL CARE
7. ADVERSE EFFECTS OF ROAD WIDENING and REMOVAL OF TREES & VERGES
8. LOSS OF HIGH GRADE LOCAL FOOD GROWING LAND
9. REMOVAL OF TREES, HEDGEROWS, HABITATS
10. COUNTRY PARK – DELIVERY APPEARS UNLIKELY UNTIL 2025 or later
11. Where is the NEED FOR THESE houses and flats bearing in mind the LACK OF NEW LOCAL JOBS

The national planning policy framework TESTS oF SOUNDNESS
suggests that a local planning authority should submit a plan for examination which it considers is sound, namely that it is:

Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence.

Effective – the plan should be deliverable over its period and based on effective joint working on cross- boundary strategic priorities.

Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

TAKING FULL ACCOUNT OF CUMULATIVE AND COMPOUND EFFECTS OF THE SCDC & IPSWICH DRAFT
Save Our Country Space, (SOCS) suggest this plan fails both Soundness and legal compliance, specifically on Environmental Health IMPACTs from likely congestion and attendant Air Quality and Pollution.

Ipswich is failing to address air pollution and it’s A Q Action Plan is inadequate. These SCDC proposals will exacerbate this critical problem.

(See map attached)

General Comment

As a residents of both Tuddenham, North Ipswich and Westerfield, SOCS are appalled at the cavalier way Suffolk Coastal District Council Planning and Development Control have disregarded SCDC Strategic Planning and their Local Plan Polices over recent years. SOCS have have no confidence in their competence., nor should the Planning Inspector.

SCDC have repeatedly failed their Community Involvement Policies. They consult then disregard and take no account of the public & resident concerns.

Failure to adhere to their CURENT Local Planning Policy means it is a free for all Planning by Appeal process which is totally out of control.

Their dysfunctional decision making and poor communications, even internally, have forced the community to take legal actions in the wider public interest. (see below)

Growing frustration at Suffolk Coastal’s ‘undemocratic’ planning system leads to calls for judicial review”

PUBLISHED: 20:38 15 April 2018 | UPDATED: 09:11 16 April 2018’

https://www.eadt.co.uk/news/framlingham-residents-challenge-suffolk-coastal-s-undemocratic-planning-system-1-5477176?fbclid=IwAR2OZbd7Jwk6lLOM_wPHuVVqwq3cyk_48Lly-  CpP5tVQWIy3yKKNjab7SH0

In effect SCDC have capitulated to landowner developer pressure, abdicating their responsibilities and obligations to their population and that of the Ipswich Policy Area.

SOCS are stakeholders and SCDC failed to advise of of this consultation failing the Statement of Community involvement.

Our recent parish council meeting had the same findings;

http://tuddenhamstmartin.onesuffolk.net/assets/Minutes/TPC-Minutes-190129-Unapproved-DRAFT-final.pdf

Policy SCLP 12.24 Land at Humber Doucy Lane

It was agreed to make representations on the basis of both Soundness & Legality –

• It does not comply with the Suffolk Coastal District Council Statement of Community Involvements as the Parish Council had not previously been consulted regarding this site (it was not mentioned in First Draft of the Local Plan).
• It fails the test of Soundness as it has not been Positively Prepared in that it does not meet the needs of Tuddenham St Martin as evidenced in the Village Review 2016 (communicated to the District Council Planning Dept. in various meetings),and in that development of this site would hasten the encroachment of Ipswich towards Tuddenham.
• The Ipswich Borough CouncilLocal Plan Draft had been received recently via email (including details of the proposed development of this site) and the Parish Council would fully discuss this at the next meeting prior to replying by the deadline date of 25 th March 2019.

Specific Comments on SCLP12.24

The public notices issued by IBC and SCDC are in the wrong locations for this area and are there is therefore a potential breach of the planning law and Local Plan process.

This area has already gone through due process and is at odds with the adopted approach of organic growth around Local Service Centre’s, and not a propose a large development on this site and in this area.

The Parish of Tuddenham is ‘village’, a NOT a Local Service Centre (LSC) which is deemed necessary and required to take this growth and development. Rushmere village is a LSC but does not have facilities and therefore fails the criteria for a LSC.

The area in question SCLP12.24 is part of the designated Green Rim and Green Corridor for Ipswich under current plan. It should remain so as there is a deficit of Green space in North and East Ipswich historically already identified in IBC Biodiversity and Open Space Policy Document.

This proposal is unsound as it takes no account of the established Biodiversity and Open Space BC Policy.

Policy CS16 Green Infrastructure, Sport and Recreation

The proposed allocation of land for housing at the northern end of Humber Doucy Lane and Tuddenham Road is in breach of Policy CS16 e.g. in relation to the protection and enhancement of green corridors.
 
Heritage and archeology

The area in question is of great historic importance with list buildings of Westerfield House and Allen Farm. The hedgerows are ancient and suggested to be thousands of years old. The area borders and overlooks the Fynn Valley County Wildlife site, footpaths and ancient green lane.

These proposals, along with IBC lead to a substantial and unacceptable loss of amenity which is unacceptable. These proposals, along with IBC lead to a substantial and unacceptable adverse impact on the local biodiversity, green infrastructure and local heritage.

These development proposals by both SCDC and IBC
• will adversely impact on the sensitivity of the Fynn Valley and the need to address light Pollution and ancient heritage.
• Post Brexit food security will be an issue with the need to protect “Best and Most Versatile” Grade 2 farming Land.
• This area proposal will lead to the coalescence of Westerfield, Tuddenham and Ipswich.
• The delays and continuing viability issues of the Ipswich Garden Suburb persist which will impact on this proposal too. Therefore, this land area proposal is both unnecessary and premature.
• The road infrastructure is characterised as ‘rat runs’ unclassified roads or narrow roads with passing places.
• There is no mention of the Felixstowe Freight line planned increase and the adverse impact this will have on passenger rail services and transport mitigation.

The Plan go against the following Suffolk Coastal District Council Core Strategy and Development Management Development Plan policies;

• SP1 Sustainable Development (Suffolk Coastal District Local Plan Core Strategy and
• Development Management Policies adopted July 2013)
• SP1A Presumption in Favour of Sustainable Development (Suffolk Coastal District Local Plan
• Core Strategy and Development Management Policies adopted July 2013)
• SP16 Sport and Play (Suffolk Coastal District Local Plan Core Strategy and Development
• Management Policies adopted July 2013)
• SP19 Settlement Policy (Suffolk Coastal District Local Plan Core Strategy and Development
• Management Policies adopted July 2013)
• SP29 The Countryside (Suffolk Coastal District Local Plan Core Strategy and Development
• Management Policies adopted July 2013)
• DM3 Housing in the Countryside (Suffolk Coastal District Local Plan Core Strategy and
• Development Management Policies adopted July 2013)
• DM4 Housing in Clusters in the Countryside (Suffolk Coastal District Local Plan Core Strategy
• and Development Management Policies adopted July 2013)
• DM23 Residential Amenity (Suffolk Coastal District Local Plan Core Strategy and Development
• Management Policies adopted July 2013)
• SP15 Landscape and Townscape
• DM21 – Aesthetics

Like the North Fringe Protection Group, we also share their concerns, outlined here.

We challenge the need for future development after 2031 in north-east Ipswich at the northern end of Humber Doucy Lane and Tuddenham Road:

1. The Settlement Sensitivity Assessment Volume 1: Landscape Fringes of Ipswich July 2018 Section 4.3 Land Northeast of Ipswich IP2 (Suffolk Coastal) recognises the sensitivity
of the open land between the edge of suburban Ipswich and the villages of Westerfield and Rushmere and that the area forms an important corridor of land. It states that “opportunities lie in the strengthening of landscape structure, softening of the urban edge and reinforcement and creation of corridors which penetrate the urban area”. It concludes that that the area is “sensitive to development” and “care will be needed to ensure rural countryside beyond the Ipswich administration area continues to function as a green rim to the town”. These comments will clearly also apply to the open land within the Ipswich boundary. Even more so as the land is nearest the edge of suburban Ipswich and there is substantially less open land within the Ipswich boundary than Suffolk Coastal. We also note that this report was produced before the Ipswich draft CS proposal. Therefore, it does not consider the impacts of building on the open countryside within the Ipswich boundary, which will increase the sensitivity of the Land Northeast of Ipswich IP2 as described in this report. In our view, this land is too important and sensitive to be built on, especially as it will result in the need for an additional primary school, which has additional traffic implications.

2. We do not believe that the full proposed expansion of the town centre retail development is required or sustainable and that this land could be better used for new homes. Town centre homes are likely to have a far lower impact on traffic congestion and air quality than on the outskirts of Ipswich. We believe that there are opportunities to convert some of the existing excess town centre retail property into new homes. This approach should be used instead of building on at the northern end of Humber Doucy Lane and Tuddenham Road, which will add to traffic congestion into the town centre and along Valley/Rd/Colchester Rd etc.

3. Traffic modelling shows that traffic from the development will further increase traffic at junctions that are already over-capacity without any road infrastructure projects proposed to rectify this forecast over-capacity.

4. The allocation of this land for housing is in breach of Policy CS16 regarding the protection and enhancement of green corridors and the CS “Green Rim”.

5. The allocation of this land for housing is in breach of the current CS. POLICY DM8: The Natural Environment POLICY DM10: Green Corridors. It is also counter to the principles of POLICY DM11: Countryside and should remain classified as part of the Green Rim.

6. The allocation of this land for housing is in breach of the current CS in relation to the corresponding Policies and Diagram 3 The Ipswich Core Diagram where it is designated as Green Rim. IBC has not provided enough evidence to justify this change of classification from countryside.

7. The North East Character Study recognises the benefits of this site as “a rural buffer” as open fields/countryside to urban Ipswich. Given the lack of such land in Ipswich, it is too important to be lost.

Regardless, there should be no development of this land until the completion of the IGS. This needs to be made clear in the CS. The Sustainability Appraisal needs to fully assess the implications on building on this site and whether delivering more homes in the town centre instead of retail expansion might be a more sustainable option.

IPSWICH LOCAL PLAN REVIEW 2018 - 2036 INTERIM SUSTAINABILITY APPRAISAL REPORT Strategic Environmental Assessment and Sustainability Appraisal JANUARY 2019

In our opinion it is too early to comment on the Sustainability Appraisal (SA) Report for several reasons, including:

  • No SA of IBCs decision not to comply with Sections 6.22 and 6.23 of guidance from Environmental Protection UK (EPUK) and the Institute of Air Quality Management (IAQM) for air quality assessments of the IGS proposed developments regarding construction traffic and assessment of the early years of the development.
  • No SA of IBC’s non-adherence to Government Guidelines for IBC’s Air Quality Action Plan and the lack of a target to reduce air pollution in the AQAP and in the CS itself.
  • No traffic modelling assessment without TUOC for the IGS development and whether the delivery of the IGS is sustainable.
  • No sewage infrastructure plan/proposals for the IGS and ISPA and SA of the environmental
    impacts of delivering new sewage infrastructure required for Ipswich, including emissions and impact of traffic congestion arising from the required construction works.
  • No air quality modelling/assessment of the CS for road traffic.
  • No air quality or noise assessment in relation to rail transport. This is a major gap in the evidence base that risks rendering the CS unsound. AQ assessments are required for;
    • the Ipswich Chord and Freight yard, where diesels regularly sit idling emitting pollution clouds,
    • additional freight to and from Port of Felixstowe,
    • and additional freight in relation to the construction of Sizewell C
  • The apparent lack of a full appraisal of the impacts on building on land at Humber Doucy Lane in the north east.

An updated SA is required to consider all these issues and consulted upon accordingly for the CS to be properly examined and progressed accordingly. We reserve the right to comment on the SA as it is developed.

Attachments
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
  • Not Applicable / No Answer