SOCS interim response to Crest Planning Application 16/00608/OUT

SOCS are awaiting the decision on the revised Core Strategy from the Planning Inspector. 
This is material to any comments on the Crest application.

Our interim response is as follows;

 

Save Our Country Spaces (SOCS) September 2016

SOCS, a residents’ member of the Community Steering Panel 2012- present time; representing the views of over 1000 local resident objectors over the period of these planning proposals and related consultations on North Fringe/IGS.

SOCS wish their response to 16/00608/OUT be recorded as an Unreserved Objection.

NB - SOCS key points and concerns are upheld by all the local Parish Councils and Daniel Poulter, MP for the Central Suffolk area as well as other statutory stakeholders.

Our view is very much aligned with North Fringe Protection Group detailed response and SOCS will reiterate their detailed analysis as an Appendix.

SOCS suggest this application premature, unsustainable and not in accordance with the current (2011) Local Plan governing current Development Management policy.

The revised CS (to be determined) is unlikely to change our view about the inherent unsustainability of the application proposal; SOCS suggest, an opinion, via the concerns and objections, unanimously expressed by all the following local Parish Councils and MP for the Central Suffolk area.

There is a real possibility that the outline application, if permitted by IBC, may be challengeable by Judicial Review under the Aarhus Convention of Environment Justice.

The CREST Environmental Impact Assessment (EIA), together with Construction Methodology & Phasing, are currently unacceptable.

SOCS reserve the right to add further comments regarding the EIA when it is further scrutinised and when the comments from the major statutory stakeholders, such as Suffolk County Council become availableand the issue of the Inspector’s Decision on the review of the Core Strategy,

SOCS have also been awaiting to appraise comments to the proposal from SCC and SCDC, neither which appear on website at present.

• SOCS have a lack of confidence in deliver-ability, viability and a lack of confidence overall in achieving the necessary agreements and achieving compliance with the infrastructure delivery plan and infrastructure table requirements – (there are additionally concerns over the required for compliance between all other landowners and other organisations such as Anglia Water)
• SOCS suggest Section 106 agreements are likely to run into problems over viability and possible future Government interventions; we have suggested consideration of Grampian Conditions (also discussed at the recent PINS). Any CIL arrangements are unlike to provide any positive impact.
• SOCS feel that local need for this current proposed expansion is not demonstrated at present, and see little likelihood of that situation changing for foreseeable future.
• SOCS have grave concerns and insufficient confidence in Crest’s local track record in delivery of proposals which adhere to original application concepts. In particular, the example at  Bramley Hill, Ipswich IP4 2AE and the Mid Suffolk development at Cedar’s Park, which have not inspired confidence in the local public’s and elected members' view, as good examples of urban design and expansion.

The following Issues we feel conflict with the NPPF tests on sustainability legislation and have been challenged through the courts creating new case law;

1. likely Air Pollution adverse impacts

2. likely  traffic delay and congestion adverse impacts

3. We object to this effective triggering of site "multi starts", deemed "unsustainable” in previous SA SEA Scoping Reports commissioned by IBC from Suffolk county Council.¹

4. Cumulative and compound impacts of this planning application are inadequately identified, surveyed or subject to adequate mitigation proposals in conjunction with other proposals, awaiting determination and those already determined. (These include proposals in both IBC and other LA administrative areas, particularly SCDC Eastern Ipswich Fringe). These need to be considered by CREST. Local village Neighbourhood Plans² have not been factored in under “Duty to Cooperate”.

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1 Multiple Starts- The suggestions of “multiple starts” is complete at odds with the adopted CS and has been identified to be totally unsustainable.

The "Sustainability Appraisal (incorporating Strategic Environmental Assessment) of Submission Core Strategy and Policies (As amended following the IBC Core Strategy Examination May/July 2011) For Ipswich Borough Council Update July 2011"

http://www.ipswich.gov.uk/downloads/SA_report__inc._appendices__July_2011_Final.pdf

States that multiple starts should not be allowed in paragraphs 1.1 and 5.

Therefore our argument is that the CS has a requirement for developments to be sustainable.

Multiple starts have been identified as unsustainable therefore will be in breach of the Core Strategy.

The 2006 Scoping Report for the SA outlined that potential adverse impacts must not only be identified but also monitored (over time) but also emerging impacts must be capable of being mitigated where necessary.

2 https://andrewlainton.wordpress.com/2016/09/15/javid-says-neighbourhood-plans-should-be-upheld-even-when-out-of-date/ Arun Recovered Appeal It will be successfully JRd as in conflict with the recent Woodcock Holdings case.

The Secretary of State considers that neighbourhood plans, once made part of the development plan, should be upheld as an effective means to shape and direct development in the neighbourhood planning area in question. Consequently, in view of Framework paragraphs 198 and 185, and his guidance on neighbourhood planning that this is the case even in the absence of a 5 year housing land supply, the Secretary of State places very substantial negative weight on the conflict between the proposal and policy BB1.

4. Design and Access proposals and mitigation measures on Colchester -Valley Road are unacceptable and inadequate.

5. Westerfield Station “Improvements”: References to “Multi starts”/ phasing by IBC in relation to possible improvements of service to be gained for Westerfield Station (and Network Rail’s interest), are questionable. The Crest Proposal is unlikely to benefit the situation re Westerfield Station.

• The increase of dock traffic will take precedence over passenger services for two reasons; economic and health.
• Increase use of rail over freight is necessary to alleviate Air Pollution (LAQMA) impacts at Gate 1 Felixstowe. Services have been badly affected and deteriorated for passenger services over the past 2-3 years. This is likely to be the case for the foreseeable future.

Network Rail response to CREST also raise concerns,

“I can confirm that Network Rail have been consulted on a large development to the south of the railway and have previously outlined a number of concerns in relation to how that development will impact upon the railway and our assets.”

Network Rail have a number of concerns relating to what potential impact such a large development will have on the rail network at this location."

6. Inadequate road infrastructure in the vicinity of proposal and inadequate traffic surveying and inadequate methodology to determine adverse impacts on unclassified radial roads ("rat runs" and E-W routes linking A14 to A12 (A1214) and adversely impacting Suffolk Coastal area, are unaddressed.

The following objections, which substantiate SOCS concerns, are quoted from many of the local Parish Councils and include the MP for the area as well. 

 

SOCS note that the Traffic Management Officer for Suffolk Constabulary view is that;

“....there will be a bigger impact than described in the application. An increase of 1100 and eventually 3500 homes/business will have a significant impact on traffic in and around Ipswich...."

* Parish Councils of Great Bealings, Little Bealings, Tuddenham St Martin and Westerfield July 2015

Reference letter sent jointly raised concerns and asked for the needs of, not only the immediate vicinity of the development, but also of existing residents of surrounding villages to be considered properly in the planning of the Northern Fringe Development.

* 2016 Westerfield Parish Council;

the traffic forecast from the Henley Gate section of the Ipswich Garden Suburb on local roads in Westerfield has been underestimated and will have a detrimental effect on the village environment and Road Safety.

Furthermore the cumulative effects of traffic from the whole development have been grossly underestimated and give an unrealistic view of the detrimental effect on the village environment and Road Safety.

* Parish Council traffic counts for peak hours along Lower Road and Church Lane regularly show between 500 and 550 vehicles per hour – along roads of width as low as 4.9m with property frontage access and no footpaths. These measured flows are not inconsistent with the 2016 daily flows of 3592 (Lower Road) and 3822 (Church Lane) used in the assessment for this application. The Environmental Statement accompanying this application forecasts that even without any development of the Ipswich Garden Suburb the flows on these two road by 2030 will increase by a further 733 and 779 causing increased danger and distress. The Parish Council consider that the predictions for traffic by 2030 from the Henley Gate section of the IGS that are likely to use Lower Road for journeys are low at 355 and unbelievable at zero for Church Lane bearing in mind the likelihood of such journeys being to Martlesham, Felixstowe and East Ipswich which are the reasons for much of the current through traffic on these roads. Even more unacceptable are the figures for the cumulative effect by 2030 of the whole Ipswich Garden Suburb that for the considerable number of extra dwellings where only 42 are assigned to Lower Road and 76 to Church Lane. With the forecast delays from Westerfield Road by 2030 it is most likely that local knowledge will cause drivers to seek alternative routes and that these forecast figures will be greatly exceeded.

RESPONSE-SUMMARY Westerfield Parish Council consider that the traffic forecast from the Henley Gate section of the Ipswich Garden Suburb on local roads in Westerfield has been underestimated and will have a detrimental effect on the village environment and Road Safety. Furthermore the cumulative effects of traffic from the whole development have been grossly underestimated and give an unrealistic view of the detrimental effect on the village environment and Road Safety.

* Henley Parish Council in July 12, 2016.

After discussion, it was agreed to respond to the consultation being conducted by Ipswich Borough Council by noting that the provision of 1000+ at the so-called Henley Gate would cause serious additional problems for already over-stretched local roads. The route into Ipswich via Henley Road via the Valley Road crossroads would inevitably be more crowded; and the route from Ipswich north to the A14 via Rede Lane and/or Mill Lane would also be under much more pressure. Major housing development has to be accompanied by major consideration of how local roads in both major directions can cope with the additional vehicles of all sizes.

 

* Rushmere St Andrew Parish Council

This phase of the development of the Garden Suburb is mainly situated off Henley Road with a small proportion off Westerfield Road. The effect on traffic flows in Tuddenham Road does not appear to be addressed in detail and we believe there will be a marked effect on traffic within and through Rushmere St Andrew. Currently as soon as the Valley Road, Colchester Road, Heath Road route is busy, traffic starts to “peel off” into Tuddenham Road towards the countryside. Following the route of Humber Doucy Lane this traffic then re-joins Woodbridge Road (A1214) at some point, either via Rushmere Road, Playford Road or, more often than not, via Rushmere Village. There is also the “reverse flow” of this “rat run” to contend with, which continues to add to the traffic problems in Rushmere St Andrew. We believe it may be difficult to prevent such “rat run” car journeys. However, there is a real chance to address the issue of lorry movements (especially construction traffic) from taking this route. A traffic order preventing such heavy vehicle movements is vital now in that if left to chance, residents of Humber Doucy Lane and Rushmere Village will be put at significant risk.

 * Dr Daniel Poulter MP (excerpt)

 

* Mid Suffolk District Council;

"the issues to highlight in officer opinion is the potential harm in traffic and safety to road links between Claydon and Henley Road. This is already a cut through for vehicles crossing the north of Ipswich between Claydon and A14 to Henley and onward to North Ipswich and even Woodbridge. The submitted details available on line in

terms of identification of areas to consider in relation to traffic and associated impacts especially at busy times do not appear to include any of these link roads. Rede lane/Church Lane to Claydon and Mill Lane/Coopers Road/ Church Lane to Claydon need to be assessed and potentially improved as a result of this application.”

4. likely public health and well-being adverse impacts including estimates for increased mortality rates; particularly on very low levels of environmental exposures e.g. air pollution and its significant detrimental impacts on child mental and physical health³ (New research is first to establish the link and builds on other evidence that children are particularly vulnerable to even low levels of pollution)

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 3 Even low levels of air pollution appear to affect a child’s lungs Date: April 12, 2016 Source: American Thoracic Society (ATS) Dramatic improvements in air quality in U.S. cities since the 1990s may not be enough to ensure normal lung function in children, according to new research.     https://www.theguardian.com/environment/2016/jun/13/air-pollution-linked-to-increased-mental-illness-in-children

5. likely damage to environment and biodiversity, both at construction phase and later.

* Suffolk Wildlife Trust

“Information to inform a Habitats Regulations Assessment (HRA)
In order to avoid any adverse impacts upon the Stour and Orwell Estuaries Special Protection Area (SPA) and Ramsar site, we consider that it is essential that the proposed country park should be operational prior to the occupation of the first dwelling within the overall Ipswich Garden Suburb. Whilst 6.3.10 and 6.3.11 in Appendix 9.3 indicate there is the potential for increased numbers of visitors to the designated site if the country park is not operational ahead of the occupation of any significant residential development, there is no definition of the term ‘significant’. In addition, the conclusions of 6.5 do not specifically highlight the timing for delivery of the country park in the context of the development phasing.

We are also concerned that in Chapter 9 of the Environmental Statement (Ecology and Nature Conservation) it is stated in 9.1.90 that the country park forms an integral part of the strategic mitigation strategy for three local authorities (Ipswich BC, Suffolk Coastal DC and Babergh DC).
For the reasons set out above, we considered that there is currently insufficient information available to conclude that the proposed development will not result in a significant adverse effect on sites of international nature conservation importance and protected species (including hazel dormouse and bats). We therefore object to this application.”

6. The application may adversely impacts on local aquifer and water supply and increase flooding risks to Westerfield and the Gipping Valley further upstream- inadequate proposal in the light of global warming the Climate Change agenda and likely increase in adverse weather events impacting on Westerfield in particular, with possible non compliance with IBC SPD on Sustainable Drainage, Suffolk Local SuDS Guide, nor compliance with the Suffolk Flood Risk Management Partnership (SFRMP) Floods and Water Management Act 2010 and the Flood Risk Regulations 2009.

SOCS also note that the Environment Agency state, “part of the development is located over a Source Protection Zone 1, with the majority located over a Source Protection Zone 2, associated with potable public water supply groundwater abstractions located north of the site. Some of the site is located over unproductive strata, but some overlies principal and secondary A aquifers, which form part of EU Water Framework Directive Drinking Water Protected groundwater bodies. The site location is therefore classified as highly environmentally sensitive.”

* comments on this application from Claydon & Whitton Parish Council are as follows:

“If the drainage from this development is to go into the River Gipping it has the potential for flooding the area around Hill View Business Park.”

Appendix

(with thanks to North Fringe Protection Group.)

NORTHERN FRINGE PROTECTION GROUP Safeguarding the Character of Ipswich Representation on Planning Application:16/00608/OUT Crest Nicholson Land North Of Railway And East Of Henley Road Note: We have had insufficient time to fully assess the above outline Planning Application due to our commitments to supporting the draft Revised Local plan Examination and associated public hearings, which only concluded on 20th July 2016. Our submission deadline for the above is 28th July 2016. We object to the above outline planning application

See detail here;

https://ppc.ipswich.gov.uk/xappnletters.asppageNumber=10&iappID=16%2F00608%2FOUT&

_capsvr2_planedms_A5C7BF56556811E683D8A0481C859811.pdf