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”.
----------------------------------------------
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)
----------------------------------------------------
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.
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.”
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;
_capsvr2_planedms_A5C7BF56556811E683D8A0481C859811.pdf
