Help with your objection letter

We only have until January 23rd to respond to the LDF consultation. The strategy is still for 2,000 houses to the south and east of Adastral Park – in other words the BT site. It is vital that we get the maximum number of people responding to the LDF to ensure that the councillors appreciate the amount of opposition to the plan and the strength of feeling in our community.

Responses are due by Sunday 23rd of this month either by email development.policy@suffolkcoastal.gov.uk or  post to:-

FREEPOST RYLA-BTTE-CKTE,
Development Policy,
Suffolk Coastal District Council, Council Offices,
Melton Hill,Woodbridge
IP12 1AU

You may wish to send us a copy of your response and, if you request it, for us to publish with address removed it on our Residents’ Page. There are other options:-

    • Suffolk Coastal’s online consultation system. Some people have had difficulty with this.
    • Suffolk Coastal’s consultation form, which few people seem to have received (online version is here) they do mention the question of Where the homes should go but only invite you to specify how many are needed in the district. It is doubtful if many members of the public have a view on how many homes the District needs but many of us have a view on where homes are needed or not.and send the form in the consultation leaflet to the freepost address. If you use the form the only sensible answer on the leaflet seems to be “None of the above”

Here are some views from NANT that you may wish to use to inform your response…..

·         THE LOCALISM AGENDA

It is clearly evident that significant objections by a considerable number of residents have been submitted to the Council.  These appear to have had little influence on the Council’s strategy for the East Ipswich Plan Area.  The views of local people have seemingly had no perceivable impact.  We believe that the current methodology used by the Council to achieve community engagement is deeply flawed when considered against the Coalition’s objectives.  Whilst it must be recognised that the Localism Bill has not yet gone through Parliament it clearly must be considered by Local Planning Authorities when they are preparing their Local Development Documents.  SCDC have made no changes to their community involvement processes in response to the Localism Bill, which places great emphasis on ‘community engagement’.

·         GROWTH OF THE EAST IPSWICH PLAN AREA

In February 2008, five potential locations of strategic housing growth within the East Ipswich Plan Area were identified.  It is not our role at this stage to assess the specific merits of the other four strategic options for housing within the area East of Ipswich.  However, it is important to express concern that these sites were not properly assessed at the appropriate stage and to ask why they have been discounted.  We say that the reasonable alternatives identified within the Preferred Issues & Options Consultation Document have not been properly considered.

When the Council chose to significantly amend the number of homes to be allocated within the Ipswich Policy Area, an updated sustainability appraisal of all of the options was again required to enable a full reappraisal of the consequences, this did not take place.

Under the previous government SCDC said they regretted their inability to spread housing more evenly across the district.  They are free to now do this, but the housing distribution has become more uneven, not less. Why?

The figure of 2,000 houses in the East Ipswich Plan Area is not based on a need for houses in the locality.  It is based on the amount of money SCDC can extract from BT to pay for infrastructure (i.e. to compensate for the damage the development will do), and on the discredited ‘we are putting houses next to jobs’ argument. This argument is flawed because the people who get the jobs (if they materialise) will almost certainly be an entirely different group of people from those who will live in the new houses.

·         HABITAT AND ENVIRONMENT

The boundary of the development site at Adastral Park is within metres of the AONB which includes the Deben Estuary SPA/SSI and Ramset sites.  This means that this site will have particularly negative impacts on this internationally protected area.  RAMSAR status is the highest international designation for a wetland habitat.  Newbourne Springs Nature Reserve, a nationally recognised Site of Special Scientific Interest, lies within 1km of the proposed development area.  The mitigation measures state that the new open areas of the development will be “linked by existing rights of way with further green space” which can only mean the environmentally sensitive sites.  We are not satisfied that the mitigation measures suggested in the Appropriate Assessment are sufficient to compensate for the recognised negative impact on these nationally and internationally important sites.

·         HOUSING NUMBERS

The Government is very clear in its view that the number of new homes to be provided should be determined at the local level and be specific to the need within each area.  It emphasises that ‘local’ in this context means more than just the Local Planning Authority – it means local community groups, concerned citizens, Parish Councils, etc.  However, in dealing with “Housing Numbers”, paragraphs 3.21 to 3.33 inclusive of the Reviewed Core Strategy set out a methodology which fails to include any reference for the need of input from the community to be taken into account in the assessment.  We reiterate our point that the Council’s methodology and engagement with “the public” has plainly not taken place correctly or meaningfully.

It is far from clear how SCDC arrived at the figure of 446 houses per year. This is described as a housing ‘requirement’, but is in fact based on the estimated housing supply. No attempt has been made to calculate the actual need for houses in a ‘bottom up’ way, i.e. starting with villages, parishes and towns, and working up to district level.

·         TRANSPORT

The Reviewed Core Strategy Document, November 2010 states, “The Orwell Bridge is identified as being of particular concern.  The current usage by 60,000 vehicles per day brings it close to capacity at peak periods.  This is predicted to rise to 76,000 by 2021”.  There is no attempt to suggest what measures can be introduced to increase the capacity of the Orwell Bridge, bearing in mind that neither carriageway has a hard shoulder.  There will be gridlock. The Reviewed Core Strategy refers to the A14 Newmarket to Felixstowe Corridor Study but fails to point out that that study predicts that the bridge will exceed its maximum capacity as early as 2014.  By 2021, during the morning peak, “over 30% of the demand in the peak hour will not actually be able to flow through the link because of congestion” (this study does not take account of the extra 3,400 houses proposed for Martlesham and Felixstowe).  Instead, the Reviewed Core Strategy ducks the issue, and makes the complacent statement: “the Council will work with adjoining authorities and the highway agencies to consider the options in respect of improving capacity and flow.”

·         INFRASTRUCTURE PROVISION

Roger Tym & Partners prepared the “Ipswich Eastern Fringe Infrastructure Study” in September 2009.  Clearly this document needs to be updated to take account of the Government Spending Review.  The council should ensure that an updated assessment is carried out so that the infrastructure requirements are reassessed in light of the Government Spending Review.

·         “CONSULTATION” HANDOUT

At the end of November 2010 the council released a press statement promising that every household and business in the district would receive a handout inviting “comments on the reviewed core strategy” to be returned by January 23rd 2011.  As of January 13th, very few people in the areas around Felixstowe, Trimley, Waldringfield, Martlesham etc. etc. have received one.  This attempt to ‘reach out’ to more people may have been well intentioned, but it has proved to be an utter failure.

The handout is available via the website but it appears to be misleading.

Why are people being asked about housing numbers for the whole district rather than their local area (which would make more sense)?

No explanation is given for how the figure of 446 houses per year is arrived at.

The handout implies that ‘larger developments’ are needed – this is not the case.

The ‘Need for more homes’ diagram is very misleading, and is biased towards the conclusion that more houses are needed – factors pointing in the opposite direction are missing.

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