Letter to SCDC Scrutiny Committee from Waldringfield PC

11th August 2010

Mr R Beswarick-Asser
Scrutiny Business Manager
Suffolk Coastal District Council

Dear Mr Beswarick-Asser,

I am writing on behalf of Waldringfield Parish Council concerning your invitation to comment on the workings of the Planning Department of Suffolk Coastal District Council. This invitation said:

“You are therefore invited to express your own thoughts to the working party.  How you do this is up to you. The working party has no particular axe to grind, and nor has the main committee for that matter.  The main thing at this stage is to discover any areas that may give concern (if any) so as to provide solid guidance for the main scrutiny.”

Our primary concern was (and still is) the way in which the overall strategy and planning policies have been developed.  We responded to your invitation with 9 pages of comment, 8 of which were devoted to the way in which the Local Development Framework (LDF) was produced, in particular to the way in which key decision were made. No indication was given to us that this topic was not to be included in your remit, in fact the quote above implied that we were free to cover any topic we wished.

However, it has come to our attention (via a somewhat roundabout route) that the LDF is outside the scope of your deliberations, and that this has actually been the case since August 2009. Why weren’t Parish Councils told about this restriction when we were invited to send our comments? Waldringfield Parish Councillors put a great deal of effort into writing, editing and agreeing our response, and we are sure that councillors in other parishes did too. Parish Councillors have more important things to do than waste their time writing comments that will be ignored because the topic has, unbeknown to them, been excluded.

The reason for the exclusion of the LDF, apparently, was that it wasn’t recognised at the time that the LDF was contentious. We find this difficult to accept, for the following reasons:

  • Ever since the decision to locate all the housing allocation for the IPA into a single area to the east of the A12 at Martlesham was taken in July 2008, it had been obvious that the LDF would be contentious. The controversial nature of the decisions in the Felixstowe area were similarly obvious. This was confirmed by the overwhelming opposition to the strategy in the consultation responses (Preferred Options Consultation, Dec. 2008), and the fact that the LDF Task Group were forced, against their wishes, to re-consult following their doubling of the housing numbers for the IPA.
  • August 2009 is a whole year ago. Surely the decision not to include the LDF wasn’t set in stone. There seems no good reason why it couldn’t have been included when responses from Parish Councils referring to it were first received.
  • Whether or not the LDF was contentious is not the point. The development of strategy and planning policies is a major activity of the Planning Department, arguably the most important activity, since everything else depends on it. Any scrutiny of the Planning Department that omits such an important function is bound to be flawed, since it can provide only part of the overall picture.

We believe the Scrutiny Committee and its Working Group are well intentioned, but (whilst we hope that this is not the case) we suspect that the LDF has been excluded from the Scrutiny Committee’s remit for reasons that have more to do with the internal politics at SCDC than a genuine desire to improve the functioning of all areas of the Planning Department. As for the other issues concerning the Planning Department, we hope that the Scrutiny Committee will investigate these with vigour, independence and impartiality.

Whatever the real reasons for omitting the LDF, it seems unlikely that the decision will be changed, so we have to reconcile ourselves to this fact. However the problems haven’t gone away. One of the main complaints coming from our parishioners against the LDF Task Group was that they ignored what local people were telling them. This feeling of being ignored needs to be addressed – what better way of doing this than having a full scale ‘drains up’ investigation of the way the LDF was produced? Answers are urgently needed to questions such as:

  • Why were key decision made without any supporting evidence?
  • Why were the responses to the public’s consultation comments so inadequate (or more often completely absent)?
  • Why did LDF Task Group meetings so often lack open-minded, objective discussion, with not even the appearance of impartiality?
  • Why was so little attention paid to the various alternatives to the chosen strategy?

An investigation into the production of the LDF would enable the Planning Department to learn the lessons, so that the many mistakes that have been made already don’t get repeated. We urge you to instigate such an investigation as a matter of urgency.

Yours sincerely

Mrs Jean Potter

Clerk to the Parish Council


Scrutiny Committee

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