PLANNING AND DEVELOPMENT CONTROL COMMITTEE 24 th 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 to 2,700 dwellings (33% affordable), apartments with C2 accommodation, vehicular access from A12, road improvements, neighbourhood centres, schools, green infrastructure, sport facilities, community facilities (Land To The 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:
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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:
PLANNING AND DEVELOPMENT CONTROL COMMITTEE 24th JULY 2019 REF.NO. PD/19/04
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.
PLANNING AND DEVELOPMENT CONTROL COMMITTEE 24th JULY 2019 REF.NO. PD/19/04
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.
PLANNING AND DEVELOPMENT CONTROL COMMITTEE 24th JULY 2019 REF.NO. PD/19/04
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
PLANNING AND DEVELOPMENT CONTROL COMMITTEE 24th JULY 2019 REF.NO. PD/19/04
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
PLANNING AND DEVELOPMENT CONTROL COMMITTEE 24th JULY 2019 REF.NO. PD/19/04
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.
PLANNING AND DEVELOPMENT CONTROL COMMITTEE 24th JULY 2019 REF.NO. PD/19/04
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.