item 04 application no. ip/19/00554/opf 04.pdf · planning and development control committee 24th...

PLANNING AND DEVELOPMENT CONTROL COMMITTEE 24th JULY 2019 REF.NO. PD/19/04

Item 04 Application No. IP/19/00554/OPF

Ward: OUTSIDE BOROUGH

Proposal: Outline application to East Suffolk Council for erection of up to2,700 dwellings (33% affordable), apartments with C2accommodation, vehicular access from A12, roadimprovements, neighbourhood centres, schools, greeninfrastructure, sport facilities, community facilities (Land ToThe North of The A14 and To The West Of The A12, Foxhall).

Address: Land To The North Of The A14 And To The West Of The A12

Applicant: East Suffolk Council

Agent:


1. Proposal

The application will be determined by East Suffolk Council (ESC) as the relevant LocalPlanning Authority (ESC ref. DC/19/1988/OUT). Ipswich Borough Council is a consulteeonly.

This application is an outline application with all matters reserved except access. Theapplicant is Gladman Developments Ltd.

This is an outline application (considering the principle of the described development) with meansof access only being considered as part of the details as submitted by the applicant at this stage.

Recommendation

That the Head of Development be authorised to write to East Suffolk Council, stating thatIpswich Borough Council objects to the planning application for the following reasons:

The proposed development is on land identified as Countryside in the Suffolk CoastalDistrict Local Plan. Suffolk Coastal Local Plan policies SP29 (The Countryside) and DM3(Housing in the Countryside) where new housing will only be allowed in exceptionalcircumstances. The agreed vision for the Ipswich Strategic Planning Area (ISPA) Board(March 2019) states that there shall be ‘distinctive urban and rural environments thatcontribute towards high quality of life’. The land in question is isolated from the surroundingkey settlements and forms an attractive countryside setting around the Ipswich urban areawhich would be significantly harmed by inappropriate development in the countryside. Inaddition, East Suffolk Council are able to demonstrate that they have a 9.3 year HousingLand Supply and there is therefore no requirement or need to consider areas of unallocatedland in open countryside for residential development.

The Transport Statement anticipates that there would be 18,243 daily trips by car or van.The additional vehicle movements would have a harmful impact on traffic and air qualityinside and outside IBC. This growth in vehicle trips has not been accounted for in either thetransport or air quality modelling work that the ISPA authorities are currently working on. Ifapproved, this development would compromise the ability of the ISPA authorities to deliverthe agreed vision.

The outcomes of the Transport Statement rely upon the delivery of traffic regulation order(TRO) proposals to introduce a combination of new 40mph and 50mph speed limits on partsof the A12, that were formulated alongside the approved application for Brightwell Lakes. Itis important to note that at the Suffolk County Council Development and RegulationCommittee (11 June 2019) the TRO was rejected by the Committee. Therefore, it would bepremature and unacceptable to rely on a TRO that has not been agreed by the HighwayAuthority. As the measures for the strategic allocation of Brightwell Lakes have not beenfully agreed, the proposed Garden Village, if approved, would seriously undermine theability to deliver Brightwell Lakes and have an unacceptable impact on highway safety.Furthermore, the residual cumulative impacts on the road network in the ISPA would besevere and impacts on air quality harmful, contrary to NPPF paragraphs 103,108, 109 and181.

Through the preparation of aligned Local Plans, the authorities of the ISPA are progressingInfrastructure Delivery Plans to ensure that each authority can facilitate the anticipated levelof growth to 2036 and enhance infrastructure provision accordingly. The addition of the2,700 homes proposed through this Garden Village have not been factored into this as itdoes not form part of the identified housing supply for the Suffolk Coastal Emerging LocalPlan. The proposal would therefore have an adverse impact on the capacity and quality of

existing infrastructure, as well as the delivery of future infrastructure in the ISPA.


This means a further planning application will be required to examine the full details should thisplanning application be approved.

The planning application comprises an outline application for the erection of up to 2,700 dwellings,

(including 33% affordable housing); apartments with care (C2 use class); vehicular access from a

new roundabout off the A12, improvements to Felixstowe Road (including pedestrian/cycle

footways); accesses and two roundabouts on Bucklesham Road; Layout to incorporate

neighbourhood centres and market square (use classes A1, A2, A3, A4, A5, D1 and D2), two

primary schools; Green Infrastructure including a village green, sports pitches and courts, club

house, changing facilities, a community park (and car park), trim trail, neighbourhood equipped

areas of play, locally equipped areas of play, habitat enhancement, landscaping and public realm

works, community orchard, allotments, footpaths and cycling routes. Removal of existing on site

reservoirs.

The proposal includes:

up to 2,700 dwellings (including 33% affordable housing);

70 apartments with care (C2 use class);

vehicular access from a new roundabout off the A12;

improvements to Felixstowe Road (including pedestrian/ cycle footways);

accesses and two roundabouts on Bucklesham Road;

A neighbourhood centre comprising 23,800m2 of floorspace within use classes A1, A2,

A3, A4, A5, D1 and D2 and a market square (including retail, a medical

centre/pharmacy, community hall/pavilion, nursery/crèche facility, and a pub);

two primary schools;

car parking and a café;

a village green (including a cricket pitch and bowling green);

new sports pitches, club house, changing facilities, parking tennis courts;

green infrastructure including a new community park (and car park), trim trail,

neighbourhood equipped areas of play, locally equipped areas of play, habitat

enhancement, landscaping and public realm works, community orchard, allotments,

footpaths and cycling routes; and

acoustic mitigation and associated infrastructure including roads and sewers,

sustainable drainage systems (SuDS), and associated engineering and earth-works

(including removal of existing on-site reservoirs).

The total site area of the planning application is approximately 142.1ha. The site is situated on land

immediately to the north of the A14 (junction 58) and west of the A12 near the Seven Hills junction.

The application site is situated approximately 1km (1000m) to the east of Ipswich Borough

Council’s (IBC) administrative boundary. A copy of the location plan has been included as an

appendix for context.

The site is in land identified as ‘Countryside’ in the Suffolk Coastal Local Plan Settlement Hierachy

and is formed of two parcels of land. The northern parcel is situated between Bucklesham Road

and Purdis Road and comprises large open arable fields enclosed by trees and hedgerows. The

southern parcel is located between Bucklesham Road and the A14. It consists of irregularly shaped

open flat arable fields which are bounded by mostly trees and some hedgerows. There are two

reservoirs positioned approximately in the centre of the site.


The site is bordered to the east by the A12, a key strategic route serving as an eastern gateway

into Ipswich as well as linking the wider population with the A14. The A12 runs to the east of the

site and connects to the A14. The A14 is a major international, national and regional route

connection linking Felixstowe to the M6 and M1 and links to the Midlands and London. It is

proposed that traffic lights are set in place on the A12/A14 Seven Hills Roundabout. Other traffic

lights and mitigation works are also planned on the A12. Suffolk Showground is situated to the

west of the site.

The A14 road serves as an international freight route linked with Felixstowe Port but also as an

important local distributor particularly around the southern fringes of Ipswich.

The role of Ipswich Borough Council in terms of responding to this planning application is to assess

the impact of the proposal on the countryside setting of Ipswich. In addition, it is necessary to

ensure that the impact of the proposal on traffic flows both in terms of the A12/A14 but also non-

strategic roads are considered and that the scale of development does not adversely impact on

facilities, service and infrastructure within Ipswich and the town centre, as well as air quality inside

and outside the Ipswich Borough Council area.

2. Background

There is no planning history associated with this site. The site was the subject of an Environmental

Impact Assessment (EIA) Scoping Opinion which was determined in December 2018

(DC/18/4525/SCO). However, it’s important to note that this does not deal with planning policy

matters and the principle of development.

The applicant has not entered into any formal pre-application discussions with ESC or any key

consultees prior to the submission of this application. ESC advised in their EIA Scoping Opinion

response that:

“For a development of this scale, extensive pre-application consultation with the Local

Planning Authority (LPA) and key consultees should be undertaken from an early concept

design stage to work up an illustrative masterplan and mitigation package. Irrespective of

the policy position on the site and proposal, a collaborative approach to master planning

and mitigation measures is essential to enable efficient decision making as strongly

endorsed by paragraphs 39 – 46 of the NPPF.”

Ipswich Borough Council (IBC) in its role as a statutory consultee would be expected to be included

as part of any formal pre-application discussions for development on this site. Local exhibition

events in Bucklesham and Woodbridge took place in November 2018 but these did not form part

of a formal pre-application enquiry. To date, other than the EIA scoping opinion, IBC has not been

consulted formally on these proposals until now.

Policy SP29 of the Suffolk Coastal adopted Core Strategy (2013) provides the policy criteria against

which to assess the future development of this area. The land is outside the Eastern Ipswich Plan

Area and not within any identified settlement boundary and is therefore defined as ‘Countryside’.

The land for the ‘Brightwell Lakes’ development for 2,000 homes near Adastral Park, as approved

in April 2018 (DC/17/1435/OUT), is positioned approximately 2.2km to the north-east of the Orwell

Green application site. Brightwell Lakes is an allocated site in the adopted and emerging Local

Plans for 2,000 homes and supporting infrastructure.

Housing


The May 2017 Strategic Housing Market Assessment (SHMA) states that the objectively assessed

housing need (OAN) for Suffolk Coastal District Council (SCDC) over the period 2014 to 2036 is

10,111 dwellings (460 dwellings per annum). When re-calculated for the adopted Local Plan period

2010 to 2017 this equates to approximately 7,900 dwellings (464 dwellings per annum). SCDC

have a 9.3 year housing land supply and thus can demonstrate that they have more than a five-

years supply of housing. This is the adopted position for housing in the Suffolk Coastal part of ESC.

The emerging position, as set out in the SCDC Final Draft Local Plan (January 2019), uses the

standardised methodology that the Government introduced as part of the revised National Planning

Policy Framework (NPPF) (2018 (as updated 2019)). Policy SCLP3.1 (Strategy for Growth in

Suffolk Coastal District) identified a housing need of 10,476 over the period 2018 to 2036 (582

dwellings per annum). However, it should be acknowledged that the Final Draft Local Plan was

submitted to the Secretary of State for independent examination on 29 March 2019 and therefore

cannot be attributed any significant weight at this stage. In addition, there is a degree of uncertainty

regarding what inputs should be used in the standardised methodology, as noted by the Inspector

in their initial questions1.

The application site does not form part of an allocated site for housing delivery or any other

development in either the adopted or emerging Local Plans.

Up to 2,700 dwellings are proposed including up to 33% affordable housing. The average net

density, as illustrated indicatively on the masterplan, is recorded as 36 dwellings per hectare. The

final mix of housing has not been established at this stage but the Planning Statement states there

will be a range from 1 bed apartment to 5 bed detached houses.

The proposal includes 70 extra care apartments which the masterplan indicates would be

positioned in the centre of the site close to the neighbourhood centre.

Retail and local services

The proposal includes a neighbourhood centre which would act as a ‘local centre’. Local Centres

are defined as ‘centres which include a range of small shops of a local nature serving a small

catchment. Typically, local centres might include, amongst other shops, a small supermarket, a

newsagent, a sub-post office and pharmacy. Other facilities could include a hot-food takeaway and

launderette. Where possible, SCDC will look to ensure retail provision where this will help to meet

the day to day needs of local residents.’2

Archaeology

As there is no planning history it cannot be definitively determined what the archaeological status

of the site is. The site has never been subject to systematic archaeological investigation and,

therefore, the character, extent and significance of surviving below ground heritage assets at this

site has yet to be defined. It’s important to note that there are seven Scheduled Monuments at the

Seven Hills Cemetery in close proximity to the site.

In responding to the EIA Scoping Opinion, Suffolk County Council Archaeological Services

confirmed that the site lies in an area of very high archaeological potential, within a broader

1

https://suffolkcoastallocalplan.inconsult.uk/consult.ti/SuffolkCoastalExamination2019/viewContent?contentid=3890112 Paragraph 4.43 and Policy SSP31 of the adopted SCDC Core Strategy


landscape of cropmark evidence for early activity. They also stated that there is a strong likelihood

for remains of national significance to survive within the proposed development area.

Agricultural Land

The application site is formed of approximately 142ha of agricultural land. The Proposed

Development will have a significant major adverse impact on agricultural land resources by

permanently removing 126.7 ha of BMV (best and most versatile) land from the national stock

which cannot be mitigated against.

Biodiversity and Habitats

There are no Statutory Designated Sites of nature conservation interest within the site. The surveys

did identify some bat activity, as well as some notable invertebrate species present in the Veteran

trees, notably a small population of common lizard.

The Ipswich Heaths Site of Special Scientific Interest (SSSI) is situated approximately 850m to the

south of the site. The Stour and Orwell Estuaries Special Protection Area (SPA) and Ramsar site

are approximately 2.5km to the south.

Landscape

The Suffolk Coast and Heath Area of Outstanding Natural Beauty (AONB) is roughly 250m to the

south of the site at its nearest point. The site lies within the Ipswich Peripheral Area IP3 of the

Settlement Sensitivity Assessment Volume 1: Landscape Fringes of Ipswich (2018).

Flood Risk

The site lies entirely within Flood Zone 1. This area is defined as being at little or no flood risk at

all, with a 1 in 1000 annual probability (0.1% chance) or less of flooding from rivers or the sea in

any one year.

Rights of Way

The southern parcel of the site is crossed by a Public Right of Way (Bridleway) which runs from

the junction between Hall Road/ Bucklesham Road southwards where it then runs parallel to the

A14 road. The proposal seeks to retain this Bridleway and includes a circular walk around the

perimeter of the site that will link to existing footpaths ‘where possible’.

Public Open Space

The proposal includes a central ‘Village Green’ space (1.9ha), a Country Park (17.6ha) in the north-

west corner of the site and sports pitches (6.54ha) (including changing facilities) in the south-west

corner.

In addition to the elements above, green infrastructure will also be provided in the form of

allotments, equipped play areas, attenuation and green links.

Education

Two primary schools and early years provision are proposed, each allowing for two form entry with

expansion.

Suffolk County Council in their response to the Ipswich Local Plan – Regulation 18 (Preferred

Options) Consultation set out their initial/ indicative early education strategy based on the level of

growth set out in the Preferred Options Local Plan. The key findings for the wards in the east and

south-east of Ipswich are shown in table 1 below.


Table 1 – Suffolk County Council Initial/Indicative Early Education Strategy (Reg 18)

ElectoralWard

TotalPermitt

ed,

yet tobe

built, asof

31/03/18

DwellingsAllocated

Total toPlan for,by Ward

FTEsarising

Current

Surplus/Deficit,FTEs

Additional

PlacesRequired

Proposed Strategy,by Ward

Bixley 13 0 13 1 131 0

Current surplus suggeststhat no additional capacityis required.

Gainsborough

0 102 102 9 -94 9

Seek to increase capacityat existingsettings.

Gipping 103 485 588 51 -54 51

Explore possibility ofallocation on IP051.Otherwise on IP279 orIP003.

Holywells 266 945 1211 105 -59 105

0.1 ha at IP037 for 60places on the Island Site.Explore how many placescan be delivered atRosehill and Cliff LanePrimaries.

Priory Heath 94 297 391 34 35 0Current surplus suggeststhat no additional capacityis required.

St John's 222 0 222 20 -84 20Seek to increase capacityat existing settings.

Buses


The only existing bus stops within walking distance are located on Woodhouse Lane immediately

to the west of the site which serve the 179 bus route that links Woodbridge-Bucklesham-Kirton-

Ipswich.

The application states that the proposed Spine Road would accommodate a bus loop through the

site with the possibility of either extending the service through the site or creating a new bus link.

Phasing

The Phasing Plan indicates that development, if approved, would come forward in five phases with

the general plan to be developing the southern parcel first and the northern parcel second.

Access (forming part of the outline planning application)

It is extremely important that any off-site works to A12/A14 Seven Hills Roundabout and the off –

site measures proposed for the A12 do not increase congestion along the A12.

The most significant element of highway infrastructure proposed under this application is a new

signalised roundabout directly off the A12 to serve the development. Two secondary roundabout

accesses are proposed off Bucklesham Road, providing access to both the northern and southern

parcels of the site. A further mitigation proposal at the St Augustine roundabout is also proposed.

The highways impacts of the proposed development have been modelled on the basis of the

highway improvements to the A12, as included in the Brightwell Lakes planning permission, coming

forward.

3. Consultations

Ipswich Borough Council is a consultee on this planning application and therefore has not

consulted on the proposal independently. This would be a matter for ESC.

4. Policy

National Planning Policy

- National Planning Policy Framework (2019) and appropriate National Planning Practice

Guidance (2014)

-

The National Planning Policy Framework clearly states the Government’s planning policy and

is a material consideration when determining planning applications. Guidance is wide ranging

and LPAs are required to be proactive in making planning decisions and apply a presumption

in favour of sustainable development. Other key policy requirements include ensuring good

standards of sustainable design for new development that will function well, add to the overall

quality of an area, optimise site potential, respond to local character and reflect the identity of

local surroundings, create safe and accessible environments, and be visually attractive as a

result of good architecture and appropriate landscaping.

Local Planning Policy

Ipswich Borough Council’s Core Strategy and Policies DPD (2017)

Policies CS2 (The Location and Nature of Development), CS4 (Protecting Our Assets), CS6

(The Ipswich Policy Area), CS16 (Green Infrastructure, Sport and Recreation), CS17

(Delivering Infrastructure), CS20 (Key Transport Proposals), DM5 (Design and Character),


DM10 (Protection of Trees and Hedgerows), DM17 (Transport and Access in New

Developments), DM18 (Car and Cycle Parking), DM31 (The Natural Environment), DM33

(Green Corridors) and DM34 (Countryside).

5. Comment

Please Note: There is only one reserved matter that is to be considered as part of the outline

planning application and that is access. (However, the application does include a broad indicative

master plan for the development.) Although many aspects of the planning application submissions

are a matter for ESC, in light of the scale of development proposed and its proximity to the boundary

of IBC, there are a number of strategic-based major objections which are very important from an

Ipswich Strategic Planning Area perspective that IBC wish to raise. These are as follows:

The proposed development is on land identified as Countryside in the Suffolk Coastal

District Local Plan. Suffolk Coastal Local Plan policies SP29 (The Countryside) and DM3

(Housing in the Countryside) where new housing will only be allowed in exceptional

circumstances. The agreed vision for the Ipswich Strategic Planning Area (ISPA) Board

(March 2019) states that there shall be ‘distinctive urban and rural environments that

contribute towards high quality of life’. The land in question is isolated from the surrounding

key settlements and forms an attractive countryside setting around the Ipswich urban area

which would be significantly harmed by inappropriate development in the countryside. In

addition, East Suffolk Council are able to demonstrate that they have a 9.3 year Housing

Land Supply and there is therefore no requirement or need to consider areas of unallocated

land in open countryside for residential development.

The Transport Statement anticipates that there would be 18,243 daily trips by car or van.

The additional vehicle movements would have a harmful impact on traffic and air quality

inside and outside IBC. This growth in vehicle trips has not been accounted for in either the

transport or air quality modelling work that the ISPA authorities are currently working on. If

approved, this development would compromise the ability of the ISPA authorities to deliver

the agreed vision.

The outcomes of the Transport Statement rely upon the delivery of traffic regulation order

(TRO) proposals to introduce a combination of new 40mph and 50mph speed limits on

parts of the A12, that were formulated alongside the approved application for Brightwell

Lakes. It is important to note that at the Suffolk County Council Development and

Regulation Committee (11 June 2019) the TRO was rejected by the Committee. Therefore,

it would be premature and unacceptable to rely on a TRO that has not been agreed by the

Highway Authority. As the measures for the strategic allocation of Brightwell Lakes have

not been fully agreed, the proposed Garden Village, if approved, would seriously undermine

the ability to deliver Brightwell Lakes and have an unacceptable impact on highway safety.

Furthermore, the residual cumulative impacts on the road network in the ISPA would be

severe and impacts on air quality harmful, contrary to NPPF paragraphs 103, 108, 109 and

181.

Through the preparation of joint Local Plans, the authorities of the ISPA are progressing

Infrastructure Delivery Plans to ensure that each authority can facilitate the anticipated level

of growth to 2036 and enhance infrastructure provision accordingly. The addition of the

2,700 homes proposed through this Garden Village have not been factored into this as it

does not form part of the identified housing supply for the Suffolk Coastal Emerging Local


Plan. The proposal would therefore have an adverse impact on the capacity and quality of

existing infrastructure, as well as the delivery of future infrastructure in the ISPA.

Housing and Infrastructure

National Policy

Paragraph 72 of the NPPF (2019) explains that the supply of large numbers of new homes can

often be best achieved through planning for larger scale development, such as new settlements or

significant extensions to existing villages and towns, provided they are well located and designed,

and supported by the necessary infrastructure and facilities. It explains that it is the role of the

strategic policy-making authorities to identify suitable locations.

Paragraph 79 of the NPPF (2019) states that planning policies and decisions should avoid the

development of isolated homes in the countryside unless one or more of the following

circumstances apply:

“a) there is an essential need for a rural worker, including those taking majority control of a

farm business, to live permanently at or near their place of work in the countryside;

b) the development would represent the optimal viable use of a heritage asset or would be

appropriate enabling development to secure the future of heritage assets;

c) the development would re-use redundant or disused buildings and enhance its

immediate setting;

d) the development would involve the subdivision of an existing residential dwelling; or

e) the design is of exceptional quality, in that it:

- is truly outstanding or innovative, reflecting the highest standards in architecture, and

would help to raise standards of design more generally in rural areas; and

- would significantly enhance its immediate setting, and be sensitive to the defining

characteristics of the local area.” (Para 179, p22)

Paragraph 170 also states that planning policies and decisions should contribute to and enhance

local environment by:

“recognising the intrinsic character and beauty of the countryside, and the wider benefits

from natural capital and ecosystem services – including the economic and other benefits of

the best and most versatile agricultural land, and of trees and woodland” (Para 170(b), p49)

Local Policy

The land is identified as countryside in the Suffolk Coastal Local Plan (Core Strategy 2013) and

policies SP29 (The Countryside) and DM3 (Housing in the Countryside) state that new housing in

the countryside will only be allowed where it comprises:

“a) Replacement dwellings on a one to one basis where they are no more visually intrusive

in the countryside than the building to be replaced;

b) The sub-division of an existing larger dwelling where this would meet a local need;


(c) Affordable housing on ‘exception’ sites in accordance with Policy DM1;

(d) Conversions of existing buildings subject to certain controls (Policy DM13);

(e) Minor infilling within clusters of dwellings well related to existing sustainable settlements

(Policy DM4); or

(f) Development which would otherwise accord with the special circumstances outlined in

paragraph 553 of the National Planning Policy Framework.”

The Ipswich Local Plan Core Strategy and Policies Development Plan Document (DPD) Review

(2017) states that:

Within the countryside defined on the policies map, development will only be permitted if it:

a. respects the character of the countryside; and

b. maintains separation between Ipswich and surrounding settlements; and

c. does not result in isolated dwellings; and

d. contributes to the green rim and other strategic walking and cycling routes and wildlife

corridors where appropriate.

Major development in the countryside will only be permitted if it satisfies a. to d. above and:

e. is necessary to support a sustainable rural business including tourism, or

f. is a recreational use of land which retains its open character; or

g. is major residential development.

National and Local Policy Position

The national and local planning policy position is that the proposed development is in principle

unacceptable as it represents inappropriate development in the countryside.

The NPPF (2019) clearly states that it is the role of the strategic policy-making authorities to identify

suitable locations for large-scale developments to help meet housing needs (paragraph 72).

Proposals such as the Ipswich Garden Suburb in IBC or Brightwell Lakes in SCDC have been

planned strategically through the Local Plan process. In contrast the proposed ‘Orwell Green’

Garden Village has not been planned for appropriately.

Through the preparation of joint Local Plans, the authorities of the ISPA are progressing

Infrastructure Delivery Plans to ensure that each authority can facilitate the anticipated level of

growth to 2036 and enhance infrastructure provision accordingly to meet anticipated growth. The

addition of the 2,700 homes proposed through this Garden Village have not been factored into this

as it does not form part of the identified housing supply for the Suffolk Coastal Emerging Local

Plan. The proposal would therefore have an adverse impact on the capacity and quality of existing

infrastructure, as well as the delivery of future infrastructure in the ISPA.

Specifically, in terms of Ipswich Local Plan policy, policy DM34 (Countryside) states development

will only be permitted if it respects the character of the countryside and maintains separation

3 Now paragraph 79 of the National Planning Policy Framework (2019).


between Ipswich and surrounding settlements. The proposed development would be contrary to

both of these criteria as the development is not well-related to Ipswich or any of its surrounding

settlements and would fail to respect the character of the countryside.

The application site falls within identified landscape IP3 of the Settlement Sensitivity Assessment

(July 2018). Whilst the assessment states that the applications site forms part of an area that is

“less sensitive” than other parts of this character area, it states that residential development could

be accommodated in association with existing clusters of housing. The proposals are not in keeping

with the existing clusters of housing around Bucklesham Road and Purdis Road. The nearby

properties on these roads are set in a rural context and with a spacious, sporadic and linear layout

following the road. In contrast, the proposed Garden Village would represent a level of development

completely out of proportion with its rural surroundings as the 2,700 homes and supporting

development would fail to relate to the character of the surrounding villages.

The isolated and unsustainable nature of the site’s location is depicted in Figure 7 (Facilities Plan)

of the Design and Access Statement. The 1,200m radius around the site fails to penetrate the core

of Ipswich or any of the major centres in the Ipswich Eastern Plan Area. The hard boundary of the

A12 and A14 would act as a barrier to reaching any surrounding settlements, services or facilities

other than by means of car and the development would be overly-reliant on private car as the main

means of travel due to the lack of high-quality public transport within close proximity.

It is also pertinent to note that the Derby Road Train Station is incorrectly labelled on Figure 7. It is

actually circa 1.5km further west than shown and is over 4km from the site, not the 2.5km indicated

on the map.

Applicant’s Position

The Planning Statement submitted on behalf of the applicant argues that the outline planning

application is made in the context of the Government’s requirement to boost housing land supply

and the presumption in favour of sustainable development. Whilst it is accepted by the applicant

that the proposals conflict with policies SP29 and DM3 of the Suffolk Coastal Local Plan (2013),

they consider that in the light of the ‘higher housing need’ currently identified, the restriction of

development in the countryside proposed in these policies is inconsistent with the NPPF (2019).

The weight to be attached to these policies should be reduced and not considered determinative

in terms of decision making.

Response

The ‘higher housing need’ that is referred to in the Planning Statement is evidenced by the

‘Woodbridge decision’ (APP/J3530/W/16/3165730). The conclusion of this appeal was that the

2010 objectively assessed need (OAN) of 11,000 dwellings over the period to 2031 should be used

and not the lower 7,900 set out in the Core Strategy. This appeal decision was determined at a

time when Suffolk Coastal District Council could not demonstrate a five-year supply of deliverable

housing sites (12 April 2017).

However, the Planning Statement does not acknowledge the more recent (20 July 2018) ‘Bell Lane’

appeal decision (APP/J3530/W/16/3160194). The Inspector determined under this appeal that the

Council could demonstrate a five-year housing supply and that the new evidence in the form of the

2017 Strategic Housing Market Assessment showed a lower OAN of approximately 7,900

dwellings.


As the ‘higher housing need’ referred to in the Planning Statement is no longer applicable due to

the more recent appeal decision, it is considered that the decision of this planning application must

be taken in accordance with the relevant Suffolk Coastal Local Plan policies as these form the

development plan policy (section 38(6) of the Planning and Compulsory Purchase Act 2004). As

already explained, the proposals are contrary to policies SP29 and DM3 and therefore should be

refused.

Transport, Access and Air Quality

The ISPA authorities are currently preparing transport modelling and air quality modelling to assess

the anticipated impacts of planned growth across the ISPA area. Table 6.4 from the application

transport statement (March 2019) identifies the likely trip generation by travel method:

The table demonstrates that 18,243 daily trips by car or van are predicted. The additional vehicle

movements would have a harmful impact on traffic and air quality inside and outside IBC. This

growth in vehicle trips has not been accounted for in either the transport or air quality modelling

work that the ISPA authorities are currently working on. If approved, this development would

compromise the ability of the ISPA authorities to deliver the agreed vision.

The outcomes of the Transport Statement rely upon the delivery of traffic regulation order (TRO)

proposals to introduce a combination of new 40mph and 50mph speed limits on parts of the A12,

that were formulated alongside the approved application for Brightwell Lakes. It is important to note

that at the Suffolk County Council Development and Regulation Committee (11 June 2019) the

TRO was rejected by the Committee. Therefore, it would be premature and unacceptable to rely

on a TRO that has not been agreed by the Highway Authority. As the measures for the strategic

allocation of Brightwell Lakes have not been fully agreed, the proposed Garden Village, if approved,

would seriously undermine the ability to deliver Brightwell Lakes and have an unacceptable impact

on highway safety, the residual cumulative impacts on the road network would be severe and

impacts on air quality harmful, contrary to NPPF paragraphs 103, 108, 109 and 181.


6. Conclusion

Ipswich Borough Council strongly objects to the proposed development for the reasons outlined in

this report.

Appendix 1 – Location Plan

item 04 application no. ip/19/00554/opf 04.pdf · planning and development control committee 24th...

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