SCDC have updated two documents which form part of the Local Development framework (LDF). They are:
- Appropriate Assessment (AA). This is written by Landscape Partnership on behalf of SCDC, and assesses the LDF Core Strategy and the policies it contains, to see how it impacts nearby environmentally sensitive sites, referred to as ‘Natura 2000’ sites, or sometimes ‘European’ sites.
- Sustainability Appraisal (SA). This tests the sustainability of the policies in the LDF Core Strategy against 23 sustainability objectives, spanning environmental, social and economic factors. It is written by the Business Development Unit at SCC.
Both documents are required by law. They are both out for public consultation, which ends on 14th October 2011. The actual documents can be found on SCDC’s website:
How to respond to the consultations
It is best if members of the public respond in their own words, rather than copy/pasting generic response arguments. However, these documents are long and in places obscure, so to make it easier NANT have prepared a short list of the main points that concern us. More detail of the changes to the AA and SA can be found in the NANT documents ‘Changes to AA’ and ‘Changes to SA’.
The final deadline for the receipt of any consultation responses is 4.45pm on 14th October 2011.
Please click here for more detail on responding.
You can submit your comments using SCDC’s online consultation system at http://suffolkcoastal.jdi-consult.net/ldf/ , or you can formally respond in the traditional way by post or email.
Along with your comments, SCDC ask you to include a brief summary of each point you wish to make (up to 100 words per point).
Comments submitted by post should be addressed to:
Development & Policy
Suffolk Coastal District Council
Council Offices, Melton Hill, Woodbridge, Suffolk IP12 1AU
or by email to firstname.lastname@example.org.
If you have any queries about this consultation, the Core Strategy or Local Development Framework in general, SCDC suggest you contact their Planning Policy team on 01394 444761 or email email@example.com.
Suggestions for responses to the AA
§5 Methods of assessing European site visitor increases from an increased human population
It is admitted (in §5.1 and §5.3) that there is limited data available regarding the number of visitors to European sites. Despite this lack of data, important and wide-ranging conclusions are drawn about visitor numbers and the impact of the proposed housing on these sites. This is little more than guesswork. A proper scientifically rigorous survey should be carried out of visitor numbers to the Deben Estuary and how these affect wildlife.
In §5.3.7 to §5.3.13, and particularly in Table 3, an attempt is made to estimated the increase in population due to the proposed housing. To do this it uses the ‘number of new people per new dwelling’, which in Suffolk Coastal is supposed to be 1.57. This figure (1.57) comes from the Oxford Economics Study, which SCDC rejected, and it has never been explained.
The reason for the low figure of 1.57 is that there is an unstated, hidden assumption that many (roughly 1/3) of the future residents of the new housing will move out of existing housing in the area, and so will not be adding to the number of extra people living near the sensitive European Sites. This is totally unrealistic. And why is this dubious assumption not explained and properly justified?
The same criticism can be applied to the figures for Felixstowe, Walton and the Trimleys.
The actual increase in the number of people visiting the sites is not given, because the current number of visitors is unknown (because of the lack of a proper survey – see above).
In §5.6 the impact of the extra people is discussed. No changes have been made to the ridiculous claims that people are unlikely to walk further than 1km or drive further than 8km. These are based on a 2006 Dorset study. The appropriateness of using this data out of context has been questioned by Waldringfield PC, Natural England and others, but their criticisms have been ignored – none of the 4 points below have been addressed. The 1km figure is invalid because:
- the Deben Estuary is a completely different habitat from the areas studied in Dorset, which are lowland heathland
- the pattern of housing in the surrounding areas is different, indeed some of the Dorset sites are completely surrounded by urban or suburban housing.
- the Dorset heathland sites lack any features comparable to the River Deben, with its sailing opportunities, river walks, beach and popular riverside pub.
- the Dorset study is 5 years out of date and has been superseded by later studies in the same area, which partially contradict it.
The 1km cut-off figure makes no sense in the context of the Deben Estuary, and it is very likely that many people will walk far further than 1km to reach an attractive area like the River Deben. This was confirmed by a study made by NANT, which showed that people walked an average of 3.8km to the Deben Estuary.
§6.2 Policy SP2. Housing numbers
“Given the limit to available parking the increase in visitors walking along the estuary might be less than that predicted.” (§6.2.35) Too much emphasis has been placed on the “limit to available parking” – this only applies at peak times, most of the year there is plenty of space.
“Estuary-side footpaths north and south of Waldringfield are eroded and impassable … This limits the walking routes available from Waldringfield.” Whilst this is true, many people walk these paths and simply turn back when they reach the breach in the river wall.
The summary of initial conclusions is unchanged. In particular, it still says: “It is therefore concluded that there would be no adverse affect upon the integrity of the respective European sites.“ (§6.2.45). This contains two caveats: provided that “strategic housing proposals are greater than 1km from the Deben Estuary” and there are “improvements in accessibility to greenspace provision”. The 1km figure is flawed (see above), and the greenspace is unlikely to materialise (see blow).
No change has been made to the conclusions on mitigation (§7.4): “It is ascertained that, with the proposed mitigation, Policy SP2 and related housing policies will have no adverse effect upon the integrity of any European site.” This of course depends on the mitigation being implemented and available at the start of house building. However, no mention is made of the fact that no actual mitigation site has been found, SCC have ceased funding country parks, and no timetable has been proposed for the creation of this hypothetical green space.
§9.2 Further work needed
Having acknowledged that the data is poor, the AA makes the highly dubious claim that: “further work is not immediately required for this Appropriate Assessment or the Core Strategies and Policies to progress.” (§9.2.3) So a major decision has been based on admittedly poor data, and no attempt will be made to get better data before the decision is formally adopted, when it will be too late to change, even if the new data contradicts the policy.
Suggestions for responses to the SA
§3.4 Who was consulted, when and how
Tables 3.2 and 3.3 include SCDC’s responses to consultation comments on the SA (Dec. 2008) and Reviewed Core Strategy SA (Nov 2010). Many of SCDC’s responses are inadequate, and many draw the dubious conclusion: “No change to SA required”. There are too many problems with these responses to list them here.
§6.5 Policy appraisal results
SP20 - This policy is described as “marginally more sustainable”, because of: “the creation of a countryside park on the Foxhall tip by the end of the plan period”. The reference to the Foxhall Tip is contradicted in the last paragraph, in which it is stated that designated areas will need to be safeguarded “by providing open space as part of the housing development at the beginning of the development” and it is pointed out that “Foxhall Country Park is unlikely to be developed within the plan period”. Since no proposals have been made for any countryside parks at the beginning of development, the policy could not have become more sustainable.
It is suggested that an “Area Action Plan will need to safeguard the designated areas” and this will “consider the congestion and traffic impacts for popular recreational destinations in the area (e.g. Waldringfield)” The Area Action Plan is unlikely to solve these problems, and by the time it is produced it will be too late – the decision to build 2,000 houses at Martlesham will already have been adopted.
“The SA has highlighted that paths shown on OS maps are not currently available for walks along the estuary north and south of Waldringfield, providing protection of bird habitats from disturbance”. It is nonsense to suggest that people won’t walk these paths – they will (and do) simply turn back when they reach the breach in the river wall.
Brief mention is made of the potential impact of increased boating activities on the River Deben (§1.2, §6.6 and §6.7), however the problem isn’t taken nearly seriously enough – it has simply been dumped on the Area Action Plan to sort out (see above). Large boats, and particularly motor boats, have a powerful disturbing affect on feeding birds, and they are a major cause of erosion of the fragile saltmarsh ecosystem. This point has been made several times by NANT and Waldringfield PC and has been consistently ignored.
SP21 – It is absurd that the score for SP21 (Felixstowe) remains unchanged at 14.5, despite the number of new houses allocated there having increased by 44%, from 1,000 to 1,440. Under SP2 it says “The slight [44% is ‘slight’??] increase in Felixstowe and the Trimleys is proportional to the size of the existing development.”
§6.9 Uncertainties and risks
Section expanded. “There is uncertainty as to when a country park could be delivered at Foxhall tip”. This is true, but there is no uncertainty that it won’t be there at the start of house building! Despite this ‘uncertainty’ the assertion is still being made that 2,000 houses at Martlesham will have an insignificant impact on the nearby European sites. This entirely dependent on mitigation appearing at the start of house building, and this looks extremely unlikely to happen.