felixstowe peninsula area action plan - east suffolk council · 2016-06-20 · press releases ....

Felixstowe Peninsula

Area Action Plan

Analysis of Responses to the Issues and

Options Public Consultation

October 2015

Consultation Period

19th October 2015 - 30th November 2015

Suffolk Coastal…where quality of life counts

Appendix 2

Felixstowe Peninsula Area Action Plan Analysis of Response to Issues and Options Consultation Page 1

Contents Record of how Issues and Options consultation documents were distributed and promoted ................................................................................................................................. 4

General Comments .................................................................................................................................................................................................................................................... 7

Do you have any thoughts on the approach the Council has followed? Is there an alternative approach that you think should be considered for the more detailed

distribution of housing in the Felixstowe, Walton & the Trimleys as set out in the Core Strategy and why? ...................................................................................................... 7

Presentation of documents.............................................................................................................................................................................................................................. 15

Evidence Base. ................................................................................................................................................................................................................................................. 18

Spatial and Sustainability. ........................................................................................................................................................................................................................................ 19

Q1. How can links with the Port be enhanced? ................................................................................................................................................................................................... 19

Q2. Any opportunities for improvements to the road and rail networks? .......................................................................................................................................................... 19

Q3. Which parts of the road network are at capacity? ........................................................................................................................................................................................ 19

Q4. How can links between the AAP and Felixstowe Futures be successful? ..................................................................................................................................................... 21

Housing. ................................................................................................................................................................................................................................................................... 22

Q5. What sites identified in the SHLAA 2014 need to be allocated/ brought forward for development? ......................................................................................................... 22

Q6. Which SHLAA 2014 sites should be discounted? .......................................................................................................................................................................................... 22

Q7. Do we need to consider any other residential sites? .................................................................................................................................................................................... 22

Q9. What type and style of developments do communities want to see on future residential sites? Which sites would be appropriate for flats and other smaller units and

which sites would be appropriate for larger units? ............................................................................................................................................................................................. 22

Q10. What will be the cumulative impact of bringing these residential sites forward? ..................................................................................................................................... 22

Q8. Is the Council correct to remove the areas to be protected from development not within the Physical Limits Boundaries such as around Falkenham Church. ............. 43

The Economy. ........................................................................................................................................................................................................................................................... 43

Q11. Are all the employment sites within the Felixstowe Peninsula still required? ........................................................................................................................................... 43

Q12. Are there any other potential employment sites which need to be brought forward? ............................................................................................................................. 44


Q13. Should uses on employment sites be restricted to traditional B1 (Business), B2 (General Industry) and B8 (Storage and Distribution) uses or do we need to take a

more flexible approach? ...................................................................................................................................................................................................................................... 46

Q14. Do any other sites surrounding the Port of Felixstowe need to be included within the Strategic Employment Areas? ........................................................................... 46

Q15. Is the current town centre boundary still appropriate? ............................................................................................................................................................................. 47

Q16. Should any areas be included or excluded from the town centre boundary? ............................................................................................................................................ 48

Q17. Does the primary shopping area need to be extended to include areas fronting the Triangle? ................................................................................................................ 48

Q18. Should the boundaries of the existing District Centres be re-defined? ...................................................................................................................................................... 49

Q19. Do any other District Centres or Local Centres need to be identified as part of the Felixstowe Peninsula AAP? ...................................................................................... 49

Q20. Is it necessary to protect the existing car parks through a specific allocation? .......................................................................................................................................... 50

Q21. Can the tourism needs of Felixstowe be met under one blanket criteria based policy? ............................................................................................................................ 51

Q22. Are there any tourism related policies which the Council need to retain as specific policies? .................................................................................................................. 51

Environment............................................................................................................................................................................................................................................................. 53

Q23. Should policies protecting Landscape and Townscape features be combined as there are certain similarities within these designations which seek to avoid material

adverse impact upon these areas? If so, should there be one policy to cover these designations, or should some division be maintained? .................................................. 55

Q24. Is the criteria within the Special Landscape Area policy (AP13) still appropriate? ..................................................................................................................................... 56

Q25. What does the Coastal Change Management policy need to include? ...................................................................................................................................................... 56

Q26. Local Plan Saved Policy AP1 on Conservation Areas is more detailed that the other policies. Is this extra detail justified, and if so does this warrant a separate policy

for Conservation Areas? ....................................................................................................................................................................................................................................... 57

Q27. Should the policy on Areas to be Protected from Development be combined with the policy on Conservation Areas, as Areas to be Protected from Development

have similar protection to areas identified in conservation areas which should not be developed? ................................................................................................................. 58

Q28. Should policies be written to consider proposals for development affecting protected wildlife or geodiversity sites or landscape areas or are they adequately

covered by the Core Strategy? ............................................................................................................................................................................................................................. 58

Q29. Which sites across the Felixstowe Peninsula need to be identified to protect and enhance biodiversity and geodiversity as detailed Core Strategy policy SP14? ....... 59

Q30. Which sites across the Felixstowe Peninsula need to be identified and protected to resist settlement coalescence as detailed by Core Strategy policy SP15? ........... 59

Q31. How can the Felixstowe Peninsula AAP promote a network of green infrastructure? .............................................................................................................................. 59


Community and Well-Being issues. .......................................................................................................................................................................................................................... 60

Q32. Are the current open space designations appropriate? ............................................................................................................................................................................. 60

Q33. Are there any other areas which ought to be protected through an open space designation? ................................................................................................................ 60

Q34. What are the opportunities for improving green infrastructure within the Felixstowe Peninsula? .......................................................................................................... 61

Q35. What types of open space, sport and play facilities, community facilities are needed to generate a sustainable community? ............................................................... 62

Q37. Would the Felixstowe Peninsula benefit from greater community facilities/opportunities? .................................................................................................................... 64

Suggestions regarding specific ‘saved’ Local Plan policies and future policy development. ................................................................................................................................... 65

Maps of new sites submitted through Issues and Options Consultation Period…………………………………..………………………………………………………………………………………………………..…69


Analysis of Response to the Felixstowe Peninsula Area Action Plan Issues and Options Consultation

Issues and Options Consultation 15 December 2014 – 27 February 2015.

Below is a series of table outlining the measures the Council undertook to promote and advertise the Issues and Options Consultation. The actions and extent of the

distribution and consultation activities was guided by the SCDC Statement of Community Involvement (adopted September 2014) as well as government regulations and

examples of best practice. The information is provided as a record of what the Council undertook for that particular stage and as Local Plan documents evolve other

methods of consultation and engagement may be used from time to time.

Record of how Issues and Options consultation documents were distributed and promoted.

Type Document Date sent How documents were published and who received a copy

Consultation documents

Site Allocations and Area Specific Policies DPD 17/12/2014 - Published on SCDC website - Published on JDi - SCDC Members -Town/parish clerks -Members of the working group -Libraries

Felixstowe Peninsula Area Action Plan 17/12/2014 - Published on SCDC website - Published on JDi - SCDC Members -Town/parish clerks -Members of the working group -Libraries

Map Booklets Map booklet for Woodbridge Housing Market Area (HMA)

17/12/2014 - Published on SCDC website - Published on JDi - SCDC Members -Town/parish clerks -Members of the working group -Libraries

Map booklet of East Ipswich Policy Area (EIPA) HMA

17/12/2014 - Published on SCDC website - Published on JDi - SCDC Members


-Town/parish clerks -Members of the working group -Libraries

Map booklet for Framlingham HMA 17/12/2014 - Published on SCDC website - Published on JDi - SCDC Members -Town/parish clerks -Members of the working group -Libraries

Map booklet for Saxmundham HMA 17/12/2014 - Published on SCDC website - Published on JDi - SCDC Members -Town/parish clerks -Members of the working group -Libraries

Map booklet for Felixstowe HMA 17/12/2014 - Published on SCDC website - Published on JDi - SCDC Members -Town/parish clerks -Members of the working group -Libraries

Draft Sustainability Appraisal

Woodbridge HMA 17/12/2014 - Published on SCDC website -Members of the working group

EIPA HMA 17/12/2014 - Published on SCDC website -Members of the working group

Framlingham HMA 17/12/2014 - Published on SCDC website -Members of the working group

Saxmundham HMA 17/12/2014 - Published on SCDC website -Members of the working group

Felixstowe HMA 17/12/2014 - Published on SCDC website -Members of the working group

Saved Policies Saved Policies 17/12/2014 -Members of the working group

Letters General letter 11/12/2014 -Everyone on LDF database

Statutory Consultees 11/12/2014 -Statutory consultees

Letter to town/parish council 11/12/2014 - Town/parish councils


Promotional material

Poster 11/12/2014 -6 posters sent to every Town/parish councils -Libraries - Additional posters also sent on request

Drop in session poster 16/01/2015 -GP surgeries -Dental Practices -Members

Leaflet -Town/parish councils - SCDC Members - Additional leaflets also sent on request

Press releases Press release 1 15/12/2014 -Published in Coastline magazine - Published in East Anglian Daily Times - Published on SCDC website

Press release 2 13/01/2015 -Sent to some parish magazines to be included in their February issue+ other magazines - Published on SCDC website

Social Media Twitter Posts January – February

- SCDC Twitter Feed - Visit Felixstowe Twitter Feed

Public Drop in sessions were held at various locations across the district.

Venue Date of Session

Trimley St Martin Memorial Hall 26/01/2015

Kesgrave Community Centre 27/01/2015

Walton Community Hall 29/01/2015

Saxmundham Town Hall 29/01/2015

Felixstowe Town Hall 03/02/2015

Riverside Centre, Stratford St Andrew 05/02/2015

Council Chamber, Council Offices, Woodbridge 09/02/2015


The drop in sessions, publication and engagement undertaken generated a lot of interest in the consultation documents. The Council received the number of

representations for each document as seen in the table below.

Document Number of Responses

Site Allocation and Area Specific Policies DPD 831

Felixstowe Area Action Plan DPD 254

Below is a summary of each individual representation received in respect of the Felixstowe Peninsula Area Action Plan. The comments are presented in the order of the

consultation questions outlined within the Issues and Options consultation document. Against each representation is a summary of the comments, the Council’s

analysis of the comments and how these have impacted on the Preferred Options document.

FELIXSTOWE PENINSULA AREA ACTION PLAN Analysis of Response to the Felixstowe Peninsula Area Action Plan Issues and Options Consultation

Respondent

Summary of comments

Analysis / Comment

Recommendation

General Comments

Do you have any thoughts on the approach the Council has followed? Is there an alternative approach that you think should be considered for the more detailed distribution of housing in the Felixstowe, Walton & the Trimleys as set out in the Core Strategy and why? General Comments Recommendation

Suffolk County Council

Discussions which have taken place are revealing a number of matters which will need to be considered. These include, but are not limited to:

Assessment of highway impacts, promotion of sustainable travel options and whether or not sites can be delivered without cumulative severe

Suffolk County Council are a key partner in the delivery of the AAP and the Council welcome their continued involvement and engagement. These matters, and others, have been considered through officer level discussions as part of the work to

References have been made throughout the Preferred Options document to the input Suffolk County Council have had and these requirements have been translated into policy requirements where appropriate. Where areas of further work are required the Council will continue to work in partnership with the County Council to ensure this


transport impacts.

Delivery of key infrastructure, including education, libraries and waste facilities.

Promotion of countryside access in a manner consistent with ecological requirements.

Consideration of how development can meet the needs of an ageing population.

Management of air quality issues in some areas.

Meeting the objectives of the Suffolk Health and Wellbeing Strategy.

prepare the Preferred Options consultation.

work is undertaken at the relevant times.

Historic England I note that the SCDC SHLAA formed a significant part of the evidence base, but as noted in our previous letter we would expect the evidence base to include a list of all designated heritage assets within the AAP area, and separately identify those on the Historic England 'at Risk' Register. The AAP area includes a range of heritage assets. In addition there may be other undesignated but locally significant heritage assets. The 2014 Heritage at Risk Register includes 2 of the 3 Martello Towers, the Grade II* listed Church of St Andrew in Felixstowe and Felixstowe South conservation area.

Comments noted. Information in relation to the range of heritage assets, conservation areas and locally listed features is made within the Environment section of the Preferred Options document. The policies within the Preferred Options document complement those found within the Core Strategy.

Little Glemham Parish Council

Little Glemham Parish Council. With regard to the Felixstowe Area Action Plan Issues & Options Document [Dec'14] the council again agreed to acknowledge receipt of the document, as presented, with no further comment.

Noted. All town and parish council’s will be notified of future consultation periods and invited to make comments.

Kirton Parish Council

Held a village meeting, attended by over 155 people representing the community of approximately 600 households. Output from the meeting is direct evidence of the community need for a sustainable community to be maintained and developed.

Noted. The Planning Policy Team were pleased to be invited and attend the meeting during the Issues and Options Consultation period.

Opinions expressed at the meeting and in the consultation response have been included within the Preferred Options document.

Michael Ninnmey

Maps of Brown field Site and prime agricultural land needed.

Noted. Brownfield sites across the Peninsula have been considered as part of the work the Council


undertook for the 2014 SHLAA which has demonstrated that brownfield opportunities are limited. Providing a map of these limited opportunities is not considered appropriate. Natural England identifies the prime agricultural land across the country and is available as an up to date on line resource.

Comments of Objection

Gillian Mason The strategic employment centre of the peninsula is focused to the south and west, concentrating on the Port and some retail and tourism. We would point out that the biggest housing sites deemed suitable by the Council (sites 502e and 451g) are to the north and east, and are therefore not 'sustainable' as this word is defined in para 6.1.

Residential opportunities in close proximity to the port are limited and the housing options are considered to be in accordance with the Core Strategy regarding housing distribution and growth across the district.

Preferred housing sites are required to provide footpath and cycle links to link in with existing communities as well as providing alternatives to use of the private motor car. Sites across the Felixstowe Peninsula are well related to local employment opportunities as appropriate.

No Adastral New Town

The Martlesham, Newbourne and Waldringfield Area Action Plan is not mentioned in any of the documents/maps. The area covered by the Martlesham, Newbourne and Waldringfield Area Action Plan, so clearly included in the EIPA has been removed from the EIPA in the Allocations & Area Specific Policies documents/maps. Waldringfield & Newbourne are listed in the Felixstowe HMA but are excluded, quite rightly, from the Felixstowe Area Action Plan.

The area is covered by the Site Allocations and Area Specific Policies DPD, the Martlesham Neighbourhood Plan and the planning application for the Adastral Park site which is still before the Council for consideration.

No change.

Comments of Objection regarding C13/3069/OUT (Land West Of Ferry Road Residential Centre, Ferry Road, Felixstowe.

Eric Southgate Site 166b should be discounted, or at least protected from severe overdevelopment. 200 potential slums should be reduced to 70 real, sustainable, HOMES. " to ensure that any future development is located in the most suitable locations". And you

SHLAA site 166b has been discounted. Planning Committee minutes recording the proceedings regarding the determination of C13/3069/OUT (Land

Preferred Options does not include site 166b. The maps include the site at Ferry Road within the Preferred Options document because of the extant planning permission which establishes the principal


consider that the "most suitable location" for 200 three storey houses is to cram them into a 4.8ha field (A density of 42 houses per hectare), in clear line of sight from within an Internationally recognised Area Of Outstanding Natural Beauty, (The Deben Estuary) do you?

West Of Ferry Road Residential Centre, Ferry Road, Felixstowe) are on public record.

of residential development on this site.

J Stafford Following my personal experience of the 'consultation' process for the Ferry Road OPA (Outline Planning Application), I find these very hollow words. This OPA attracted over 250 local resident objects, rejection by the Felixstowe Town Council, the Felixstowe Society and many others. Despite this, the resident's objections were never fully addressed or discussed and the approval was steamrollered through by SCDC Planning Officers and District Councillors, who did not even represent Felixstowe. This has left residents totally disillusioned with the SCDC Planning process and does little to promote a feeling of democracy or real involvement on planning decisions. Section 3.4 states "ensure future development is located in the most suitable location" How then was the Ferry Road OPA approved for 200 houses on a field in a semi- rural location, with only one small access road, farthest possible from local facilities and amenities!! Section 4.9 "the Physical Limits Boundary has been 'tweaked' (i.e. extended) to include the recent Ferry Road OPA" a. I strongly object to this 'tweaking'. The Ferry

Public consultation is a fundamental part of any planning application or planning document which the Council undertake. The debate and reasoning for the approval of the outline planning application is available in the public domain. The Council considered the application on its individual merits and taking into account material planning considerations. The site is still outside of the physical limits boundary as seen on the 2001 Local Plan Proposals Maps. The AAP seeks to redraw this boundary in light of

As part of the preferred options, public consultation will be undertaken which will enable greater community involvement and engagement. The AAP is unable to change the Council’s decision with regards to the Ferry Road application. No change to the AAP. The maps include the site at Ferry Road within the Preferred Options document because of the extant planning permission which establishes the principal of residential development on this site.


Road field remains OUTSIDE the current Felixstowe Town Boundary, OUTSIDE the current Physical Limits Boundary and remains prime Greenfield Agricultural land. b. Yet in another example of SCDC Planners bending the rules in order to influence and achieve a pre-defined objective. Section 2.5 states "it will be for the Felixstowe Peninsular AAP, through the democratic process, to identify which of the sites area appropriate" More hollow words! The Felixstowe Town Councillors were democratically elected by Felixstowe residents to represent their wishes. They rejected the Ferry Road OPA but this counted for nothing. The OPA decision was actually made by SCDC Councillors from other areas (none of whom were elected to represent Felixstowe residents) egged on by Senior SCDC Planners who had clearly already made up their minds on the required outcome of this OPA.

the application that has been approved. Felixstowe Town Council have been actively engaged in the evolution of the AAP since the Issues and Options consultation period. Alongside this, the Council has been coordinating a Felixstowe Peninsula Working Group which is made up of Felixstowe Town Councillors and District Councillors engaged in the process to represent the local community.

The AAP has been prepared with involvement of Felixstowe Town Council and District Councillors which represent the communities across the Felixstowe Peninsula.

Ian Buxton The council ignore local community involvement in the process for the allocation around Ferry Road. Last sentence para 4.9: Revise the words in a new sentence. SCDC followed due process in agreeing the allocation at Ferry Road in Felixstowe but completely ignored the comments from local community. How do we change from a culture of consult and ignore to one of Consult and debate? The consultation to most people appears to be something forced upon the council to do NOT because they really want to change through consultation. They think its too difficult,

Public objection does not result in the refusal of a planning application. The Council as local planning authority have to consider these comments along with other material planning considerations and make a decision as detailed in the Case Officers report and minutes of the meeting. Public engagement in the AAP is fundamental and does influence the Council’s thinking and decision making. The preferred options document will be subject to extensive public consultation which provides further opportunity to

No change. Public consultation responses have influenced the preferred options document in the form of suggested policy requirements, changes to boundaries and how the document and supporting maps are presented. During the preferred options consultation the Council will be undertaking drop


pandering to the lobby groups & so called Nimby's but local democracy is being undermined. its because the local people feel that they have unsuitable development foisted upon them that they become disengaged or aggressively negative.

debate issues and engage with the local communities.

in sessions to enable greater community engagement in line with the Council Statement of Community Involvement.

Percival King An example was the meeting held in Trimley St Martin on 14th March 2007 at which the Council unveiled their vision of our future. Villagers were aghast at the number of new homes proposed, and that the Trimleys had become part of a Greater Felixstowe. The impression was given that proposals were written in stone with little room for compromise/consensus. Another meeting was promised in the Autumn, but failed to materialize. Further meetings were held, at which the Council maintained their stance, but failed to garner support for their proposals. Many concerns were raised, but appeared to fall on deaf ears.

The meetings in 2007 were focused on the preparation of the Core Strategy which was adopted in July 2013. The AAP will be subject to specific public consultation with the next stage being the preferred options in autumn 2015. The Statement of Community Involvement (SCI) sets out how the residents, businesses and other interested parties in the district will be involved in the preparation of the Suffolk Coastal District Local Plan.

No change.

Eric Southgate "We are always open to suggestions as to how we can encourage more people to get more involved in the decisions which shape their future lives". Your own words. Answer. SIMPLE. Stop treating the community, who pay your wages, as an irritation to be ignored, as lesser beings to be simply frightened off or locked out of meetings, told not to contact councillors who could have direct input into decision making for us, and intimidating us so that we are too frightened to challenge you over the "shape of, what's left of, our future lives". Reference 3.2. Whenever the community quoted the David Lock report, in any meeting with SCDC, we were told in no uncertain terms that the

Engagement with the local community is fundamental to the success of the AAP and the Council welcome comments from every section of the community. Officers welcome discussions with the local community at every opportunity and drop in sessions will be held during the preferred options consultation to facilitate this engagement. The David Locke Report from 2006 is now an old evidence base document. Although it may still contain positive

Public consultation responses have influenced the preferred options document in the form of suggested policy requirements, changes to boundaries and how the document and supporting maps are presented. During the preferred options consultation the Council will be undertaking drop in sessions to enable greater community engagement in line with the Council Statement of Community Involvement. The preferred options document does not make reference to the David Locke report published in 2006.


David Lock report would cut no ice with them. We were once told that "All this sort of thing is alright on paper but in the real world it carries no weight at all". To do this, policies and proposals should be founded on a robust evidence base". Your words. In answer to a FOI request I received the following "There is therefore no exact methodology which was used to determine the suggested housing density for each site". Plucking densities out of thin air may be your idea of a 'robust evidence base' but it isn't mine.

aspects the AAP does not place any reliance on this old evidence. See SHLAA 2014 methodology regarding calculation of site density estimates which followed examples of best practice and the guidance as published by government. The SHLAA is a document which demonstrates capacity. The AAP translates these details into policy requirements.

The 2014 SHLAA provided a range of sites across the Felixstowe Peninsula which the AAP has then taken forward as part of the preferred options document.

Julie Cornforth I would say that at least 75% of the population of Felixstowe does NOT know about this consultation. Why doesn't SCDC send details to every house in Felixstowe? They manage to send out the "Suffolk Coastal" magazine every few months. Put the details in that.....on the FRONT PAGE! PRIOR TO THE CONSULTATION!

The Council will seek ways and avenues of promoting the consultation further across the Felixstowe Peninsula. Articles in Coastline will be published if its circulation coincides with the consultation period anticipated in Autumn 2015.

The AAP will be promoted through Coastline when possible.

Kimberley Williams

There has been inadequate community involvement and more should have been done to consult a wider group of stakeholders including residents and businesses and community groups. Extend the consultation process and engage more meaningfully with the public to raise awareness - only one public evening session is not enough, people work during the day and those that do not may have young children so the day time drop in session was poorly attended in Walton. Felixstowe Town Council had to get an extension of time to submit its response which is an indication that insufficient time was allocated to the process in the first place. There was not time

The Issues and Options consultation ran for 11 weeks which is an extended period of time and should have enabled communities to engage in the process. During the next round of public consultation, the Council will seek to undertake drop in sessions at more appropriate times (4-8pm) at a range of venues across the Felixstowe Peninsula. Felixstowe Town Council considered the Issues and Options document in the manner they considered most appropriate. How they conduct their

The AAP will be promoted to a wider range of stakeholders in the future. Public drop in sessions will be advertised through a variety of avenues and mediums such as posters, online, newsletters, websites. Felixstowe Town Council have been actively engaged in the evolution of the AAP from Issues and Options to Preferred Options.


for a separate public meeting, public involvement has been limited to 30 minutes of public speaking at the outset of an extra ordinary meeting scheduled to adopt the council`s response when in fact a meeting should have been held earlier to allow public views to be heard before the council formulated its response. Community involvement has been poorly promoted. The process has not been advertised well, even the town council had to get an extension of time to out forward its views. Many people in the community are unaware of the Consultation greater community involvement over a longer period of time, it was mistake to start the consultation over the christmas and new year period when people are otherwise distracted.

meetings is beyond the remit of the District Council. The next round of consultation will be undertaken with greater publicity to promote increased community engagement. It is anticipated that the preferred options consultation will be undertaken during the autumn 2015 which will avoid Christmas, easter and summer holidays.

The preferred options consultation will seek to avoid the Christmas and new year period.

Save Trimleys Against Growth

The task of "identifying the most appropriate sites" is a futile aspiration. According to Table 2 of the FPAAP, which is based on the Strategic Housing Land Availability Assessment(SHLAA), there is capacity on suitable sites ‘submitted to the Council by developers, agents and landowners" to build between 806 and 1107 units, depending on house types and sizes. Since land for "at least" 850 houses still needs to be allocated, it is obvious that most if not all of this identified capacity will be taken up. Therefore, identifying "which of these sites ...are the most appropriate" will be a meaningless exercise.

The SHLAA identifies an indicative capacity on each site, the AAP takes these sites and translates them into policies which will guide the future development across the Felixstowe Peninsula. It is anticipated that only an element of these sites is required to deliver the number of units required.

The preferred options document outlines a range of sites which will ensure that the Core Strategy housing requirement is met.

Mr J Stafford Section 2.4 states "Policies and proposals should be founded on a robust evidence base" also Section 3.3 states "to support identified need within the Felixstowe Peninsular" What 'robust evidence' is there of an actual need for large

The Core Strategy and the evidence underpinning that document define the housing and job targets for the district over the plan period 2010-2027. It is not the role of the AAP to redefine

No change.


scale housing development in Felixstowe? What 'robust evidence' is there for any large scale increase in employment opportunities in Felixstowe that will require such a large quantity of additional housing? With increasing competition from newer ports, Felixstowe Dock expansion is being met mostly through increased mechanisation not manual labour.

these requirements that is to be undertaken as part of the Local Plan Review in the future.

Presentation of documents. Ian Buxton The housing numbers in 4.16 are inconsistent

(again) with numbers in 4.3: Align all numbers throughout and simplify. The words, table and numeric are confusing in Paras 4.2, 4.3 and 4.4 and uses terminology that is far from plain English. This leads to suspicion that the council is trying to hoodwink ordinary people through planning terminology and hard to understand numbers. e.g 1760 + 35 = 1795 - 943 = 852 NOT 850. The para says that there is little to differentiate sites - which is correct BUT the housing densities are completely different: Explain why the housing densities between the sites should be so different.

The Council will ensure that any future versions of the document will include consistent numbers and in a more simplified manner. The principal of development on the sites is similar when considered as part of the Sustainability Appraisal process.

The preferred options document will provide consistent and simplified figures throughout. The sites identified as preferred options have been subject to Sustainability Appraisal in accordance with the regulations and best practice.

Felixstowe Town Council

Page 10, Para. 3.0 Saved Policy AP170 is clear on how housing developments will be considered in Felixstowe. Core Strategy Policies SP19 and SP21 do not give as much detail. In any case, clearer explanation should be given on the housing requirements outlined in the Core Strategy including how the allocation of an additional 1,440 homes in the defined AAP area

As the AAP evolves further clarification will be given in respect of the number of units expected on each site. These details will provide the background as to how sites will be developed alongside policy requirements and mitigation measures.

The preferred options provide the detail which is lacking in the Core Strategy.


will be met and whether the figure of 1,440 is up to date or requires revision.


The phrase "a minimum" in Paragraphs 4.3 and 4.16 and "It is essential that the Council provides over and above the minimum amount of land needed to meet the target" in Paragraph 4.16 confirms that considerably more than 850 new houses will be allocated to Felixstowe and the Trimley Villages. It is disturbing that the housing needs figures quoted in the above Paragraphs, and elsewhere in the FPAAP, are stated as being factual, without any caveats or indications that they could be considerably higher.

The AAP seeks to deliver the level of housing as outlined in the Core Strategy. Any increase in numbers will be considered as art of the Local Plan Review which will need to update the district’s objectively assessed housing need.

The preferred options seeks to deliver the Core Strategy targets but will look to over allocate sites to ensure the Council can maintain a five years land supply which provides choice of locations for developers and those looking for a new dwelling in the Felixstowe Peninsula.

Mr J Stafford Section 4.6 - SHLAA indicative capacities for each site Table 2 (attached) outlines the sites under consideration within the Felixstowe housing market, their size and indicative capacity. However, to give a true picture of the potential impact, you should have included the density per hectare for each site. The table illustrates that the density for Site 502e (and also the Ferry Road Field OPA site) is c.0.30% greater than any other site and 60% greater than the average of the sites proposed for Felixstowe, Walton and Trimley. The density is also far greater than the existing housing in this area.

The details from the SHLAA have been provided to demonstrate that across the district there is sufficient land available for development. Details of how each site will be delivered will be included within the preferred options document.

The preferred options include a clear indication of how the Council expect sites to come forward.

Harry Dangerfield

The Local Plan Document gives an indicative capacity of just 1100 dwellings for Felixstowe and the Trimleys. At an average of, say, 1.5 vehicles per dwelling, that would be about 1650 extra vehicles at the end of the peninsula. I would suggest that 1100 dwellings is excessive given the transport infrastructure and the geographical context. However, I do recognise the definite need for social/ affordable housing for existing local residents.

Regarding infrastructure, Suffolk Coastal District Council Infrastructure Delivery Plan May 2014, provides details of what infrastructure is required and how it will be provided, who is to provide the infrastructure, how will the infrastructure would be funded and when the infrastructure is required. Suffolk County Council as highways authority have been engaged with the

Measures to mitigate the impact of transport will be included within the preferred options document as directed by Suffolk County Council.


production of the AAP.

Joanna Beedel I know we need more houses for the growing population to live in. There is an increasing number of elderly people in Felixstowe who require a bungalow to live in, that would vacate some of the bigger houses for families to live in. How about the schools? Are there enough places for more pupils? How about the surgeries? They are already stretched. Where are all the jobs for the people who will inhabit these new homes? Will they commute to Ipswich and London to work? These are all critical questions to consider before the development of large housing estates.

A range of housing types and tenures will be required as part of any future development across the Felixstowe Peninsula. These are expected to provide housing opportunities for all sections of the local community. Infrastructure requirements have been identified in the Suffolk Coastal Infrastructure Delivery Plan which the Council will use to consider future requirements across the Felixstowe Peninsula.

Mitigation measures will be included within the preferred options document.

Levington & Stratton Hall Parish Council

We are extremely concerned about the creeping and proposed industrialisation of the A14 corridor between Ipswich and Felixstowe: *we very strongly believe that it is essential to preserve an open agricultural separation between these two distinct large settlements; *severely mars the rural landscape and would destroy the treasured open character of the Suffolk countryside if this area was given over to urbanisation; *the local infrastructure, in particular the road network, cannot cope; *this continually reduces the amount of agricultural land for food production in an ever-increasing population; *causes light & noise pollution;

The Core Strategy does not identify a need for large scale employment provision on the A14. Therefore the AAP will seek to concentrate employment opportunities on existing sites across the Felixstowe Peninsula.

The preferred options document identifies the Strategic Employment Areas and General Employment Areas which will provide a range of employment opportunities in line with the preferred policy requirements.

Kimberley Williams

There is no clearly identifiable need for 850 houses to be allocated to Felixstowe in addition top those already built or approved since the adoption of the core strategy. The figures are out of date: commission up to date research on current and future housing needs. Preserve

The AAP seeks to deliver the level of housing as outlined in the Core Strategy. Any increase in numbers will be considered as art of the Local Plan Review which will need to update the district’s objectively assessed housing

The preferred options seeks to deliver the Core Strategy targets but will look to over allocate sites to ensure the Council can maintain a five years land supply which provides choice of locations for developers and those looking for a new dwelling in the Felixstowe Peninsula.


greenfield and agricultural land. need.

Eric Southgate Your plan for Felixstowe is not. "Organic and evolutionary growth". It is, however. A. Grotesque 'URBAN sprawl' burying for ever, high grade, food producing, agricultural countryside with no significant infrastructure improvements. B. A Dumping ground for slums of the future, at a density higher than new builds in Ipswich, (St Clements Hospital site is only going to have a density of 18 houses per hectare. You have given planning permission for 42 houses per hectare in Ferry Road). C. The constant Gridlocking of the road system, to and from the dock, with thousands of extra cars from these new houses using the A14.

The sites identified within the preferred options are considered to represent organic and evolutionary growth as they focus on the areas which are well related to existing communities, services and facilities. Sites will come forward in keeping with the adjacent areas and seek to meet the housing needs of the communities across the Felixstowe Peninsula.

The preferred options document outlines the most suitable sites across the Felixstowe Peninsula as well as requiring a range of mitigation measures and policy requirements.

Evidence Base. Kimberley Williams

The David Locke report is ten years old and needs updating to ensure it is still relevant if relying on it for making policy!

The David Locke Report from 2006 is now an old evidence base document. Although it may still contain positive aspects the AAP does not place any reliance on this old evidence.

The preferred options document does not make any reference to the David Locke Report.


The housing needs figures in the Felixstowe Peninsula Area Action Plan are wrong because not only are they based on data that is nearly 5 years out of date but they are also overstated because the population of Felixstowe and the Trimley Villages is going down rather than up. In addition, firm commitments made in the Local Plan to update these figures have also been broken. Implementation could mean a linear urban development stretching all the way from Felixstowe to the outskirts of Trimley St Martin.

The Core Strategy sets the target with regards to housing provision across the district. The AAP seeks to deliver this minimum housing target on a range of appropriate sites. The Core Strategy acknowledges that the target is likely to be higher in the future but this is yet to be determined through up to date evidence.

The AAP will seek to meet the housing requirement outlined in the Core Strategy.


The District Council should provide a summary of the evidence base used to support the Core

The evidence which under pinned the Core Strategy has been used to inform

No change.


Strategy Policy SP5 that which "outlines that at least 8.5 hectares of additional land within the district will be allocated to support business and help facilitate the creation of new jobs." The Town Council has not been made aware of any proposals for employment land other than core strategy designation in the port area. We would welcome further information on the "variety of proposals for employment sites" the District Council states it has received.

the AAP. Full details of the evidence base can be found on the Council’s website. A list of employment sites received have been identified in the SHLAA and have been considered through the Sustainability Appraisal process.

Michael Ninnmey

3.3 Evidence needed- Housing need survey needs updating A.S.A.P. 4.6 Towards 50% of dwelling comes from reduction in occupancy Regional figure, calculated before 2008 crash. What is the actual figure taken from 2011 census? Should figure be reduced?

The Core Strategy sets the target with regards to housing provision across the district. The AAP seeks to deliver this minimum housing target on a range of appropriate sites. The Core Strategy acknowledges that the target is likely to be higher in the future but this is yet to be determined through up to date evidence.

The AAP will seek to meet the housing requirement outlined in the Core Strategy.

Spatial and Sustainability.

Q1. How can links with the Port be enhanced?

Q2. Any opportunities for improvements to the road and rail networks?

Q3. Which parts of the road network are at capacity? Mr & Mrs Buck Not enough consideration is given to the impact

of increased traffic on minor roads in the area of developments; Gulpher Road (currently a "quiet lane") will struggle to cope with the inevitable increase in traffic if there is further development in Ferry Road.

Suffolk County Council as the statutory Highways Authority consultee provides advice in Highways matters and they have been involved with the preparation of the Preferred Options Document. Planning Committee minutes recording the proceedings regarding the determination of

Suffolk County Council have identified that any future development in the area of Ferry Road will need to take into account the designation of Gulpher Road as a quiet lane. This requirement has been included within the preferred policies.


C13/3069/OUT (Land West Of Ferry Road Felixstowe) are on public record.

Julie Cornforth You state that the "importance of the Port cannot be underestimated" When you build 1600 plus dwellings on Felixstowe's peninsula do you think the "port" will continue to thrive? What happens when the A14 becomes grid-locked due to overuse/accidents? Will that help the Port? Time wasted - money lost.

The A14 is the primary route of access to the Felixstowe Peninsula and Suffolk County Council have been involved with the preparation of the Preferred Options Document. The SCDC Infrastructure Delivery Plan May 2014 details what infrastructure is required across the district.

The AAP recognises the importance of the A14 and directs heavy traffic movements to areas easily accessible from the A14 and away from residential areas. Studies undertaken for the Core Strategy are clear that the A14 has capacity to deal with the level of growth anticipated across the Felixstowe Peninsula.

Carol Florey The combined A14/A12 section is close to capacity now particularly the Orwell Bridge. If an accident occurs here Ipswich becomes completely gridlocked. Being as this is effectively two main highways combined it should be at least 3 lane and should incorporate another crossing over the River Orwell. Another option would be for the A12 to be diverted through the North of Ipswich.

The SCDC Infrastructure Delivery Plan May 2014 details what infrastructure is required across the district and will be kept under review. SCDC will continue to work with Suffolk County Council to ensure that the necessary upgrades or improvements to the road network is undertaken at the appropriate times

The AAP recognises the importance of the A14 and SCDC will continue to work closely with Suffolk County Council to ensure that the road network is able to serve the needs of the population and businesses in the Felixstowe Peninsula.

Christopher Leffler

We have the small half-road now, but in the event of a major accident blocking the A14 there will be chaos unless this relief road is capable of carrying even slow HGV and motor traffic in both directions. The structure of that road was deliberately made a single track with passing places to stop its use as a 'rat-run'. I believe that it's essential that it be upgraded while there is time before all the new traffic is generated, to prevent the 'trapping' of the traffic in and out of the peninsula for however long an accident blocks the road.



Kimberley Williams

The A14 is at capacity, Felixstowe is at the end of the road and so if you want to improve access for the port the port should be encouraged to invest in improved rail and road links, may be widening the road. It is wrong to assume that the port

The SCDC Infrastructure Delivery Plan May 2014 details what infrastructure is required across the district and will be kept under review. SCDC will continue to work with Suffolk County Council to



always be the main employer in Felixstowe it makes the town vulnerable and alternative business should be encouraged

ensure that the necessary upgrades or improvements to the road network is undertaken at the appropriate times

Julie Cornforth I object to SCDC building 1600 plus dwellings on the Felixstowe Peninsula. Does SCDC think 1600 plus houses on Fxt Peninsula will not have a detrimental effect on the 14/PoF? The A14 will not be able to cope and some days it may become gridlocked due to various incidents/accidents. Why kill the Golden Goose (PoF) that provides a living for many people who live in the area. Also not everyone who lives in Felixstowe wants to work at the Dock/or indeed in Felixstowe. It's called personal choice!!!!!! Pepper-pot housing where they are needed around Suffolk. Not where the developers are going to benefit most. PS Where were the S106 goodies when the developers took over the old Bartlett Hospital?????


The Core Strategy outlines the level of growth expected on the Felixstowe Peninsula and seeks to balance this growth against employment opportunities and community facilities. The Core Strategy distributes housing across the district following the principles of sustainable development. SCDC works in partnership with other service providers and landowners to ensure that any s106 benefits are delivered for the good of the community. In July 2015, SCDC introduced the Community Infrastructure Levy which has replaced the previous S106 arrangements.

Q4. How can links between the AAP and Felixstowe Futures be successful? Landguard Project Officer

The new 'Felixstowe Futures' should have an enabling/ coordinating role for delivery of the AAP objectives. It should be the link between District - Town and community for all AAP issues. There are some projects where it may become more heavily involved, perhaps hosting externally funded project staff for particular projects. WDC Major Projects Team could possibly provide the model for 'FF'. Delivery of infrastructure / visible change and improvement is imperative to the community's perception of 'FF' success.

Noted. The AAP provides links with Felixstowe Futures and seeks to ensure a successful future for the Felixstowe Peninsula.


References to Felixstowe Futures should be updated to refer to the replacement group Felixstowe Forward.

Noted. The Council will continue to work and engage with the activities of Felixstowe Futures as the AAP evolves.

Felixstowe Futures will be referenced where appropriate within the Preferred Options document.


Housing.

Q5. What sites identified in the SHLAA 2014 need to be allocated/ brought forward for development?

Q6. Which SHLAA 2014 sites should be discounted?

Q7. Do we need to consider any other residential sites?

Q9. What type and style of developments do communities want to see on future residential sites? Which sites would be appropriate for flats and other smaller units and which sites would be appropriate for larger units?

Q10. What will be the cumulative impact of bringing these residential sites forward?

Felixstowe sites. General comments.

Eric Southgate I see from this map that you have taken it upon yourselves to extend the physical limits boundary to encompass a field in Old Felixstowe that is at present designated as countryside. Why ask us for our opinions when you have already decided these matters behind our backs and prior to this consultation?

The physical limits boundaries have not been changed, the consultation document only published these for comment. Changes have been made where planning permission has already been granted and therefore the principal of development is already established.

The Preferred Options document will include a draft physical limits boundary for public consultation.

Kimberley Williams

Physical limits of Felixstowe should be clearly identified and constrained to avoid over development.

Noted. The Preferred Options document will include a draft physical limits boundary for public consultation.

Michael Ninnmey

6.9 Mitigation on noise/light impact of a extra (?) needed for residential dwellings along route to dock.

Noted. Mitigation measures will be factored into all future residential sites.

Site 502e-Land behind 15 and 16 Conway Close.

General comments.

Michael Ninnmey

502e- Some localised network enhancement may be required to receive FW. 4.18 Supported Housing. Good Quality, intelligent

Noted. Noted

No action. The AAP seeks to ensure good design across the


design, whole life, affordable and (?) to services needs to be requirement as proportion of all New Buildings. ADD Policy is support self build: (UK less than 10% compared to many European countries around 50% , why?

Felixstowe Peninsula. Self build developments will be supported by SCDC on sites within the physical limits boundaries.

Comments of Objection (Discount site).

J Stafford The Felixstowe Peninsula Local Strategy Final Report by David Lock Associates states that the land between Ferry Road and Estuary Drive should not be developed and why. Whilst this has been ignored in contradiction to paragraph 3.2 and 1.6, it would seem perverse if these reasons are ignored again regarding site 502e. It seems perverse that Local Objectors and Felixstowe Town Council were told the David Lock findings were not adopted, so could not be used by them in support of the Objectors Case. However, it seems quite acceptable for SCDC to 'cherry pick' from the report when it suits!

The report entitled ‘Local Strategy for Felixstowe Peninsula-Final Report’ April 2006, was tasked with identifying various future scenarios based upon the key issues and trends that the Peninsula and its residents currently face and those that they might face in the future. While the consultant team have developed the scenarios, it is the communities of the Felixstowe Peninsula, and their elected representatives, who have the responsibility to implement a preferred strategy through the Local Plan (LP) process.

The Council acknowledges that the 2006 report is now an old evidence base document. All references to this report and its findings will be removed from the Preferred Options document.

Please note - Due to the number of comments received regarding this site citing similar responses, the key points have been summarised below;

Mr & Mrs Whitlock Ian Buxton Keith Mahoney J Stafford Christopher Leffler Peter Wain Mary Wain Michael Smith R Wood J Catchpole Carole Lissauer John Jay

The cumulative impacts of the site being developed adjacent to the Ferry Road application site;

The cumulative impacts have been considered and the AAP recognises the two development sites in this part of Felixstowe.

Suffolk County Council has advised that the cumulative impacts in respect of transport will need to be considered through a transport assessment as part of any future planning application. The Council will continue to work with Suffolk County Council to understand the cumulative impacts of development across the Felixstowe Peninsula.

Development would create a precedent for further development;

The sites identified in the AAP provide certainty as to where future development will take place. Once adopted the Council will be in a stronger position to refuse development proposals on sites outside

No change.


of those allocated.

Whether the potential density of housing would be appropriate for the site;

The number of units proposed in the Preferred Options document is considered appropriate for the location and makes efficient use of land.

The preferred options document includes the number of units expected on the site.

That brownfield land should be developed before greenfield sites;

Agreed, however brownfield opportunities across the district are limited which therefore places a greater reliance on green field sites.

No change.

Potential commuting distances from the site to local services including sources of employment;

Any new development will need to make links to the existing footpaths, cycle ways and road network in the area which will improve access to local services and employment opportunities.

No change.

Road access, capacity and safety issues:

Exacerbating existing school related issues,

Impacts on the Strategic road capacity,

Lack of public transport;

Potential affects on Gulpher Road (designation as a Quiet Lane);

Suffolk County Council as the statutory Highways Authority consultee provides advice in Highways matters.

Suffolk County Council has advised that a transport assessment will be required as part of any future planning application which will identify any capacity and safety issues as well as mitigation measures required. The impact on Gulpher Road has also been included as a constraint for this site.

Concern regarding proximity to AONB;

Development of site might damage the appeal of the AONB and;

consequently, the tourist offer in Felixstowe;

Although in close proximity to the AONB, the development is not expected to cause damage to the appeal of the AONB.

The Preferred Options document requires low rise buildings (maximum 2 storey) to reflect the existing properties and also to minimise any impact on the AONB.

Loss of prime agricultural land (Grade 1 and 2); The Core Strategy identifies that some prime agricultural land may be lost as a result of meeting the housing needs across the Felixstowe Peninsula.

No change.

Potential impacts on European sites habitats; No significant impacts on European site designations have been identified because of this proposed development.

AAP requires development to be sympathetic to the surrounding area.

Less sustainable site due to lack of local services, amenities, infrastructure and facilities.

Any new development will need to make links to the existing footpaths, cycle ways and road network in the area which will improve access to local services and employment opportunities.

No change.


No requirement for more private housing in Felixstowe;

The Core Strategy identifies a housing requirement for Felixstowe over the next 15 years.

Sites are identified in the Preferred Options document to meet the Core Strategy target for growth and development over the next 15 years.

New residents will create social disharmony; Noted. No change.

Comments of Support.

Optima Land and Property

Support the delivery of the site. Noted. Site is identified as a Preferred Option.

Site 451g-Land at and surrounding Felixstowe rifle club, south of Dockspur roundabout.

General comments.

Anglian Water May require Mains Diversion. Some localised network enhancement may be required to the sewerage network.

Noted. Improving the capacity of the sewerage network as a result of this site has been included as a policy requirement within the Preferred Options.

Historic England Potential harm to the setting of WALTON HALL, 395 HIGH STREET (south side) Grade II* AND 362 HIGH STREET (north side) lodge building Grade II. Limited development on east of site.

Noted Mitigating the impact of any potential development on the setting of the listed buildings nearby will be included within the Preferred Options.

Environmental Protection Team

Site borders the A14 and an air quality assessment would be required if this site was developed. A buffer zone would also be needed in this area to protect any future residential amenity.

Noted and agreed. The preferred options document will include a policy requirement for a buffer zone as well as an air quality assessment on this site.

Carol Florey Lorna Adamson

A buffer zone alongside the A14 and Candlet Road should be considered in order to protect housing in the new development from being exposed to poor air quality.

Noted and agreed. Introducing a buffer between future residential development and the A14 Dock Spur and Candlet Road will be included within the Preferred Options.



Carol Florey Dave Norman Lorna Adamson

Saved policy AP171 identifies this land as a physical separation between Felixstowe and the Trimleys. Area 451g is Grade 1 farmland identified under section 6.6 as valuable.

The Local Plan Policy identifies that this policy will be reconsidered in a review of the next Local Plan. The AAP provides that time for review. Development in this area is considered appropriate to balance the need for future growth in an organic and evolutionary manner which protects as

The AAP identifies a new area to be protected from development to the west of the A14 which will maintain the separation between Felixstowe and Trimley St Mary. The AAP seek to protect prime agricultural land which is outside of the proposed physical limits boundaries.


far as possible prime agricultural land. The site offers the opportunity to locate new housing in a location close to existing services and facilities which will integrate with the existing communities.


Trinity College Cambridge

Support for site identified in the SHLAA 2014 as Deliverable – approximately 12 hectares capable of accommodating 243-360 dwellings,

Noted. Site identified as a Preferred Option

1011c – Land at Felixstowe Sunday market site, Sea Road.

General Comments.

Anglian Water Encroachment advisory zone for WRC (20). Noted. Improving the capacity of the sewerage network as a result of this site has been included as a policy requirement within the Preferred Options.


Blue Street Properties

Support for site 1011c (0.58 ha) (identified in the SHLAA 2014 as deliverable) with the proviso that policy AP201-Felixstowe: Sea Road Frontages be removed.

Noted. The site presents an opportunity for the redevelopment of previously developed land. The Sea Road frontage is a key contributor to the tourist and resort activities of Felixstowe and is to be retained through revised tourism policies in the AAP.

Site identified as a Preferred Option but with commercial/tourist activities on the ground floor frontage of any development which comes forward on this site.

Felixstowe sites - General Comments.

Michael Ninnmey

50% of the need for dwellings comes from reduction in occupancy Regional figure, calculated before 2008 crash. What is the actual figure taken from 2011 census? Should figure be reduced?

Noted. The AAP seeks to provide the housing requirements outlined in the Core Strategy. Any new calculations based on objectively assessed needs will be considered through a future Local Plan review.

No change.

Christopher Leffler

The proposed plots of land which could be made available for housing seem to be a sensible set of proposals, some I think go back to the plan in about 1980.(without looking it up!)

Noted. No change.

Kimberley There is no such site as Walton Green south it Name of the site will be changed to The AAP will refer to the site in Walton as Land


Williams was created by Tesco and Bidwells in connection with applications for a housing development. It is wrong to build on this land as it was available for food production.

provide further clarity as to its location. The Core Strategy seeks to resist development as far as possible on prime agricultural land. The site could provide a large number of units in a location which is close to existing communities, services, facilities and education opportunities. Other land across the Felixstowe Peninsula identified as prime agricultural land will be protected outside of the physical limits boundaries.

north of Walton High Street in the Preferred Options document.


Un-numbered 'unsuitable site', Dock Gate 1/Haven exchange roundabout. I realise that this site is marked as 'unsuitable' anyway but I need to make a specific comment here as if this site were to have housing it might result in the need for an AQMA due to the amount of heavy traffic in the area.

The site is not identified for housing within the AAP, but is identified as a General Employment Area and this may have an impact on the AQMA identified at Ferry Lane, Felixstowe.

The AAP identifies the site as a General Employment Area where employment opportunities are to be created and any future residential uses will be resisted. Any future development in this area will need to be accompanied by an air quality assessment and consider the impact it will have on the AQMA identified at Ferry Lane, Felixstowe.


Whilst the Town Council may provide comment on the type and nature of development for sites in Felixstowe identified by the SHLAA, no support (or otherwise) for the development of these sites is given or implied and therefore should not be inferred. The Town Council will consider development proposals for Felixstowe in the usual way through its Plans Committee or as otherwise brought to Council for consideration.

Noted. No change.

Defence Infrastructure Organisation

I can confirm that the MOD has no comments to make in relation to the Felixstowe Area Action Plan as it falls outside of any MOD published statutory safeguarding consultation zones.

Noted. No change.

Julie Cornforth

The population of Felixstowe is decreasing not increasing Change To Plan: Tell the truth.

The AAP seeks to provide appropriate residential opportunities for the population over the next 15 years.

No change.


Why is Felixstowe being called a "Major Centre" - it is a town on a peninsula.

The Core Strategy identifies Felixstowe as a Major Centre because it is the largest town in Suffolk Coastal and has a wide range of employment, education, retail and tourism opportunities and facilities.

No change as the remit of the AAP does not allow for the settlement hierarchy to be reconsidered. The settlement hierarchy will be reconsidered as part of a future Local Plan review.

Why should Felixstowe meet the overall housing need across the district?

The Core Strategy identifies a housing target for Felixstowe, Walton and the Trimleys. This housing target is only a part of the overall need across the district.

No change.

Surely "affordable housing" should be built around the district where it is needed.

Agreed, affordable housing should be built alongside market housing in line with Core Strategy policy DM2. Sites in the Felixstowe Peninsula will be expected to provide 33% affordable housing.

The residential policies in the AAP make reference to the need for affordable housing provision in line with Core Strategy Policy.

We don't need "huge mansions" built on housing estates. Local people cannot afford them. Will they become second homes for the rich? The outskirts of Wickham Market springs to mind.

The Core Strategy identifies that a range of house types are to be built across the district. The sites identified in the AAP will be expected to provide a mix of units to meet the needs of the wider community.

The residential policies in the AAP make reference to the need for mix of house types in line with Core Strategy Policy.

Mr & Mrs Buck The proposed development sites should have included information regarding whether they are green field or brown field.

Noted. The definition of previously developed land is found within the National Planning Policy Framework and does not need to be repeated in the AAP.

No change.

Rt. Hon Therese Coffey MP

Site 889: In the event of increase in dwelling numbers, the proposals for a Eco Village, approved by Felixstowe Town Council at Croft lane, submitted to Core Strategy by myself

Site 889 is not considered to present organic and evolutionary growth as detailed in Core Strategy Policy SP21. The site is in the countryside and Core Strategy Policies and the National Planning Policy Framework seek to resist inappropriate development in

Site not taken forward as a preferred option.


isolated countryside locations.

Mr J Stafford Section 1.4 states "A high proportion of the population are of retirement age and communities within the peninsula have fewer people of working age than many other communities within Suffolk. The age profile could become critical to the vitality of the Felixstowe Peninsula and the services it provides if the slow population growth.....". The benefit of the 'grey pound' has been ignored in this equation. It is a proven fact that retired people currently have more disposable income and a higher propensity to spend than their younger counterparts. This actually of benefit to the local economy, not a disadvantage.

Noted. The Council is aware of the benefit retired people bring to the local economy through increased spend in local services.

No change.

Julie Cornforth

How can you support a strong, vibrant healthy community if you build on the Grade 1 agricultural land that is needed to grow food on to feed them? The only Grade 1 Agricultural Land in SUFFOLK is found in Felixstowe. How do you minimise waste and pollution and reduce carbon by building more houses in a confined space like Felixstowe? More houses - more cars!

See Natural England Technical Information Note TIN049. Policy to protect agricultural land. Government policy for England is set out in the National Planning Policy Framework (NPPF) (paragraph 112). Decisions rest with the relevant planning authorities who should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of higher quality. The Agricultural Land Classification (ALC) provides a method for assessing the quality of farmland to enable

The AAP will include reference to prime agricultural land and the need to protect this as far as possible in line with the Core Strategy.


informed choices to be made about its future use within the planning system. It helps underpin the principles of sustainable development. The Core Strategy seeks to protect prime agricultural land as far as possible but this needs to be balanced against other policy requirements such as meeting housing needs, locating new housing in locations well related to existing communities, services and facilities, as well as providing a range of sites which provide organic and evolutionary opportunities for growth. The site north of Walton High Street meets most of these policy requirements and when considered on balance the loss of prime agricultural land is not reason in itself to discount the site for future development.

Suffolk is known as the "Bread Basket of England" Re:- Food Security - DEFRA leadership key. Report 1st July 2014 "The food security report supports the idea of "sustainable intensification" - producing more food with fewer resources - and calls on Defra to stem the decline in UK self-sufficiency and deliver more resilience in the UK food system. It notes that for key cereal crops, for example WHEAT, yield levels have not increased for over 15 years" see www.parliament.uk

Noted. The AAP seeks to protect farming opportunities across the Felixstowe Peninsula by proposing physical limits boundaries which represent organic and evolutionary growth and protect farming opportunities outside of these boundaries.

5.2 Felixstowe has quite a few "employers" Noted. A large proportion of the No change.


contributing to the economic growth and prosperity of the whole district. It's called "FARMING" Perhaps you would like to see the www.votebritishfood.com website. It states "Buying safe, traceable British food is vitally important but it is a FACT that our self-sufficiency has fallen steadily for the past 30 years. It's already down to 60%" So why does SCDC want to build on the best agricultural land that we have. GRADE 1 ????

district’s workforce is employed in the faming industry.

You "encourage brownfield development where it is not of high environmental value" "The DEFRA Agricultural Land Classification states that in early 2000's it estimated that Grade 1 and 2 together form about 21% of all farmland in England".

The Core Strategy acknowledges a lack of previously developed land across the district. Where possible previously developed land will be brought forward in line with planning policies.

No change.

Kimberley Williams

Much of the land identified in the SHLAA is grade 1 and 2 agricultural land and should not have been included in the SHLAA because the core strategy says that growth for Felixstowe will be organic and preserving wherever possible agricultural land that is being used for food production. Use brownfield sites in Felixstowe only, spread housing more widely across the district. Review whether then housing quotas which are over ten years olds still apply

The Core Strategy acknowledges that the loss of prime agricultural land will be avoided as far as possible. Outside of the physical limits boundaries, the Council will seek to protect the prime agricultural land which will continue to provide faming and food production opportunities. Housing figures will be updated as part of the work the Council will undertake as part of a Local Plan review.

The preferred options document (and the Core Strategy) acknowledges that some prime agricultural land will be lost where this represents organic and evolutionary growth.

Land adjacent to the AONB in Walton is grade 1 agricultural land with diverse wildlife which will be lost if houses are built on it, and the land should be preserved for food production

Outside of the physical limits boundaries, the Council will seek to protect the prime agricultural land which will continue to provide faming and food production opportunities.

The preferred options document does not propose any development on sites which will have a detrimental impact on the AONB.

The presumption in favour of sustainable development is flawed where it causes irreparable damage to land, especially grade 1 agricultural land and is wrongly used by planners to justify propping up the building industry,

The Core Strategy acknowledges that the loss of prime agricultural land will be avoided as far as possible. Outside of the physical limits boundaries, the Council will seek to protect the prime

No change.


economically it is not sustainable as we have seen in Portugal and the USA.

agricultural land which will continue to provide faming and food production opportunities.

Some sites in the SHLAA are green field and must not be built on as they needed for food production

Previously developed land across the district is limited and will not deliver the number of units required. Therefore development on green field sites is necessary.

No change.

The Walton site will be detrimental to the Countryside and must be preserved for food production.

The site is considered to represent organic and evolutionary growth, well related to existing communities, services, facilities and education opportunities.

Development on the site north of Walton High Street will protect other sites across the Felixstowe Peninsula.

The sustainability appraisal fails to adequately consider the environmental impact of building in Walton North: preserve the land in Walton for food production.

The Sustainability Appraisals have been updated and revised following public consultation responses.

Revised Sustainability Appraisal information will be published alongside the preferred options document.

The APP must protect grade one agricultural land at all cost to encourage diversity of wildlife and maintain sufficient land supply for food production.

The Core Strategy acknowledges that the loss of prime agricultural land will be avoided as far as possible. Outside of the physical limits boundaries, the Council will seek to protect the prime agricultural land which will continue to provide faming and food production opportunities.

No change.

The AONB and agricultural land mist be protected I do not accept the statement though "except where in the public interest to do so" as this is too wide and open to abuse.

Noted and agreed. The preferred options document will seek to protect the AONB.


References made to the "Best and Most Versatile Agricultural Land" are not highlighted in Core Strategy Policy SP21 as stated but can be found in Chapter 11 and paragraph 112 of the NPPF.

Noted, the references to best and most versatile agricultural land are taken from the NPPF. Core Strategy SP21 makes reference to “prime agricultural land for essential food production”.

The preferred options document will use the same wording as the Core Strategy for consistency.

Mr & Mrs Buck The importance of good agricultural land does not seem to be taken into account. We should be

Outside of the physical limits boundaries, the Council will seek to

The preferred options document (and the Core Strategy) acknowledges that some prime


safeguarding our ability to continue producing as much of our own food as possible.

protect the prime agricultural land which will continue to provide faming and food production opportunities.

agricultural land will be lost where this represents organic and evolutionary growth.

Trimley St Martin and Trimley St Mary.

General Comments.

Environmental protection Team

Sites 936, 383a, 451b, 451c, 451d, 383b, 383f, 451f and 607 within the Trimleys will need to have cumulative traffic effects considered with regard to air quality. Traffic from these sites travelling into Felixstowe using the route via High Street Trimley and not the A14 needs to be calculated and air quality impacts at the junction of High Road West and Garrison Lane will need to be determined. This junction has in recent times become more congested along the Trimley High Road West arm at peak times.

Noted. The AAP seeks to identify policy requirements and mitigation measures. Issues with regards to air quality will be included where appropriate within the Preferred Options document.

Anglian Water Water Mains Crossing Site 451c. Noted. The Preferred Options will make reference to the water mains crossing the site.

Comments of Support (Discount sites).

Rt Hon Therese Coffey MP

Trimley St Martin - Agree that 920 and 889 are completely unsuitable; Trimley St Mary - Concern that the current road network could not cope with significant development on 383F. Agree with unsuitability of 383c,d,e & 451e as too far away from centre.

Noted. The Council works in partnership with Suffolk County Council in respect of highways issues.

The Preferred Options has been informed by Suffolk County Council as Highways Authority. Where transport assessment or highways issues have been identified these have been included within the Preferred Options.

Agree that 920 and 889 are completely unsuitable.

Noted. No change.

Percival King Sounds good in theory; in practice, you cannot legislate where people live/work or their mode of transport as the go about their daily routines.

The Core Strategy seeks to provide opportunities for organic and evolutionary growth across the Felixstowe Peninsula. This is done by locating new residential opportunities which have the appropriate mix of housing types, values and affordable provision in locations close to existing

The AAP seeks to introduce a new area to be protected from development in between Trimley St Martin and Trimley St Mary which will seek to maintain the separation between the villages. New residential development will be expected to provide a range of house types and tenures as well as the appropriate level of affordable housing

I consider all the sites, apart from 607 located in the Trimleys to be inappropriate for the following reasons: a. All consist of prime agricultural land. b. Four of the sites represent a green belt, which


distinctly divides the two historic and individual settlements that are the Trimleys. Their use for homes would, in effect, merge the villages.

communities. The new residential developments will provide footpath and cycle way links to the existing communities and built up areas which will encourage people to use means of transport other than the private motor car. Maintaining the gap between Trimley St Martin and Trimley St Mary is important and the AAP will seek to ensure that these communities retain their individual character and do not become merged.

provision in line with the Core Strategy Policy.

Whilst the planned numbers may meet the required target, the type is unlikely to, for, in reality it is only affordable houses that are in demand. The fact that it is not now incumbent on developers to provide 33.3% of the total build in affordable homes if it is considered not financially viable for them so to do; this could result in ta significant shortfall. Building large numbers of speculative homes, presumably to boost the number of affordable homes, merely exacerbates the problem, because few are purchased by local people. Quite frankly the demand for affordable homes, in my opinion, can only be met by, local authorities, once again, building homes for rent/assisted purchase.

Kimberley Williams

Provided the new sites coming forward are brownfield only.

Opportunities for development on previously developed land are extremely limited across the district. Where possible the Council will seek to facilitate and encourage redevelopment of previously developed land.

In principal any development opportunities on previously developed land within the physical limits boundary will be supported. Although opportunities are limited the Core Strategy promotes the delivery of previously developed land.

Anything that helps to reduce the number of new homes to be built on greenfield sites is welcomed.

Site 936 – Land to the north of Heathfields.

General comments.


Site 936 borders the A14 and an air quality assessment would be required if this site was developed. A buffer zone alongside the A14 should be considered in order to protect housing in the new development from being exposed to poor air quality.

Noted. The AAP does not seek to take this site forward as a Preferred Option. It is not a location the Council are seeking to encourage future residential development.

Site 451d – Land surrounding Trimley Old Rectory, Church Lane.

General comments.


Historic England Potential impact on LB - content for Suffolk Coastal to assess the impact and the level of any harm that might result. If sites 451d is brought forward; then the green 'wedge' of land between 383f, 607 and 451f that contains the two Grade II listed churches and the Grade II listed Old Rectory will become an increasingly important. Recommended that this land be identified as an 'Area Protected from Development'.

Noted. The Preferred Options document identifies the potential impact development in this area may have on the Old Rectory and any future developers need to be sympathetic to the setting of this heritage asset. The Preferred Optionsalso identifies land between Church Lane and Thurmans Lane as an area to be protected from development.

Stephen Bozier 451c, 451d Desirability of accessing sites off Howlett Way.

Suffolk County Council as highways authority has been consulted on the potential access requirements for all sites.

The Preferred Options document makes specific reference to the primary vehicular access being off Howlett Way.

Lorna Adamson Site actually 9.2ha, Traffic impacts, Question results of SA report

Noted. The Preferred Options document takes into account highways comments from Suffolk County Council. As the AAP progresses the SA will be revisited in light of consultation comments and engagement with communities and stakeholders.


Denise Scott Support for 451D. Noted. The AAP includes this site as a Preferred Option.

Site 451b – Land off Grimston Lane and High Road.


Historic England Historic England has concerns over site 451b, which would impact on the setting of the Hand in Hand Public House and Nos 251 and 253 High Road.

Noted. The Preferred Options document includes reference to the impact residential development on this site may have on the setting of the Hand in Hand Public House.

Denise Scott Opposed to 451B. Noted. The AAP includes this site as a Preferred Option.

Trinity College, Cambridge

Land off High Road (Opposite 'Hand in Hand') Extension of 0.15ha to deliverable site 451b submitted by promoter of site.

Noted. The AAP includes this site as a Preferred Option but limits the extent of the site to not go beyond the rear of 21 Grimston Lane.

Percival King I consider all the sites, apart from 607 located in the Trimleys to be inappropriate for the following reasons: a. All consist of prime agricultural land.

The Core Strategy seeks to provide opportunities for organic and evolutionary growth across the Felixstowe Peninsula. This is done by

The AAP seeks to introduce a new area to be protected from development in between Trimley St Martin and Trimley St Mary which will seek to maintain the separation between the villages.


b. Four of the sites represent a green belt, which distinctly divides the two historic and individual settlements that are the Trimleys. Their use for homes would, in effect, merge the villages. When the then Secretary of State for the Environment threw out an appeal for homes on site 383f, he emphasised the above in the strongest possible terms.

locating new residential opportunities which have the appropriate mix of housing types, values and affordable provision in locations close to existing communities. Maintaining the gap between Trimley St Martin and Trimley St Mary is important and the AAP will seek to ensure that these communities retain their individual character and do not become merged.

Site 607 – Land at 182 High Road.


Percival King 607 good, all other sites bad. Noted. The AAP proposes a change to the Trimley St Mary physical limits boundary to include other sites off the Josselyns and Thomas Avenue. As a result site 607 is within the physical limits boundary.

Historic England Historic England does not wish to comment in detail on these sites, but note our comments on the open land to the north set out above, and in addition we note that site 451f will have some adverse impact on the setting of Mill Farmhouse (Grade II listed). No doubt this site once formed part of its agricultural holding, but retaining the open land to the north will ensure a degree of protection to its remaining agrarian setting.

Noted.

The Preferred Options policy outlines that any future development in this part of Trimley St Mary will need to be sympathetic to the setting of Mill Farmhouse.

Site 383f – Land south of Thurman’s Lane and opposite to High Road.

General comments.

Historic England Historic England does not wish to comment in detail on these sites, but note our comments on the open land to the north set out above, and in addition we note that site 451f will have some adverse impact on the setting of Mill Farmhouse

Noted. The Preferred Options policy outlines that any future development in this part of Trimley St Mary will need to be sympathetic to the setting of Mill Farmhouse.


(Grade II listed). No doubt this site once formed part of its agricultural holding, but retaining the open land to the north will ensure a degree of protection to its remaining agrarian setting.

Site 451f – Land adjacent to Mill Farm, 38 Thurman’s Lane.

General Comments.

Historic England Sites 451f. Historic England does not wish to comment in detail on these sites, but note our comments on the open land to the north set out above, and in addition we note that site 451f will have some adverse impact on the setting of Mill Farmhouse (Grade II listed). No doubt this site once formed part of its agricultural holding, but retaining the open land to the north will ensure a degree of protection to its remaining agrarian setting.

Noted. The Preferred Options policy outlines that any future development in this part of Trimley St Mary will need to be sympathetic to the setting of Mill Farmhouse.


Addition of approximately 0.26 ha to SHLAA 2014 site 451f (identified as deliverable)

Noted. The AAP includes this site as a Preferred Option


Trimley St Mary Parish Council

The Parish Council supports the sites identified as suitable but comments that these sites are only suitable subject to the infrastructure provision that will be necessary.

The Council is working in partnership with infrastructure providers such as Suffolk County Council and Anglian Water to determine the range of infrastructure required.

The AAP includes this site as a Preferred Option along with a range of policy requirements to help the delivery of this site.

Bucklesham sites.

Site 914-Land north of White House, The Street.

General comments.

Historic England Potential impact on LB - content for LA to make judgement Site 914 is identified for 7 houses, presumably fronting the existing road. This development may have some negative impact on the setting of a Grade II listed house, but Historic England is content for the Local Planning Authority to assess

Noted. The Council will ensure that any future development on this site takes into account the setting of the listed building nearby.

Noted. Site not taken forward as a preferred option.


whether the provision of housing outweighs any harm that might result..

Anglian Water Sewers Crossing Site. Noted. Site not taken forward as a preferred option.


Rt. Hon Therese Coffey MP

All sites- Bucklesham - Most sites are too big and too far away from village centre.

Noted. No sites are identified as Preferred Options within Bucklesham.

Kirton/ Falkenham sites.

General comments.

Kirton & Falkenham Parish Council

Community view is that no more than 30 units are needed, these should be a mixture of affordable and sheltered units. Reference para 4.86 of the Core Strategy.

Noted. Kirton is the largest local service centre within the Felixstowe Peninsula and is expected to take some growth over the plan period.

The level of growth outlined in the Preferred Options document is considered appropriate for the settlement.

Issues and Options is inconsistent with Core Strategy which states that Key Service Centres may be required to have as many as 30 units. Kirton is a Local Service Centre so this figure should be less.

Noted. Kirton is the largest local service centre within the Felixstowe Peninsula and is expected to take some growth over the plan period.

The level of growth outlined in the Preferred Options document is considered appropriate for the settlement.

Kirton should not become a dormitory, improvements to services and infrastructure required.

Noted Services and appropriate infrastructure are to be supported where possible and may be delivered through the Community Infrastructure Levy.

If development at B&M Concrete site is approved. The AAP must not include any other sites in Kirton.

Application approved by the Council in June 2015.

Additional site included to propose a location for sheltered housing/bungalows as required by public consultation responses.

Overwhelming consensus that there is a need for sheltered housing in Kirton.

Noted Policy requirement for sheltered housing/bungalows to be included within the Preferred Options.

Village does not require any more 4/5 bedroom detached houses, these do not reflect community need.

Noted Any future development will be required to provide a mix of dwelling types and tenures.

None of the sites are appropriate without improvements to roads, footpaths and sewers. Some of the sites have major surface water drainage issues.

Noted. Sites included within the Preferred Options document will have a policy requirement for improvements to footpaths and sewers.

Selection of sites is flawed – one owner of a site has stated no intention of developing it.

Sites were submitted to the Council following various “calls for sites”. All sites submitted are available to view.

Site not taken forward as a Preferred Option.


However where ownership changes (as was the case with this site) the Council can only rely on the most recent information.

Timescales for the AAP must be greatly expedited. It is clear that by the time the policy has been approved and used the majority of sites will have been developed.

The Council is following government advice to ensure plans are prepared and adopted in a timely manner. Producing the document in accordance with the timetable will provide certainty for local communities and enable to Council to demonstrate a five year housing land supply.

The AAP is expected to be completed within the next 12-15 months.

Indicative figures for each site must be removed as they are very misleading.

Noted and agreed. The SHLAA is part of the evidence base, it is for the AAP to determine the number of units on each site.

Any figures within the Preferred Options document will be used to give a minimum indication of what level of development is expected on the site.

Sewerage system cannot cope with current level of housing in Kirton. Overflows at high pressure along Bucklesham Road and streams of sewerage can be seen near the church.

Noted. The Council will work with Anglian Water to ensure that any mitigation measures or improvements are brought forward as part of the AAP.

Mitigation measures included within the Preferred Options.

Site 950 – Land adjacent to village hall, Falkenham Road.

General comments.

Anglian Water 950: Water Mains Crossing Site, Sewers Crossing Site.

Noted. Site not taken forward as a Preferred Option

Christopher Leffler

Pleased that AONB is being protected. Noted. Site not taken forward as a Preferred Option

Site 951 – Land east of Church Lane.

General comments.

Anglian Water 951: 305mm potable water main on edge of site. Noted. Site not taken forward as a Preferred Option

Historic England 5 separate sites of varying capacity are identified around the village. Historic England is satisfied that none would adversely impact on the historic environment, but would request that the northern boundary of site 951 is formed of native species hedging so as to protect the wider setting

Noted. Site not taken forward as a Preferred Option


of the Grade II listed Church of St Mary and St Martin.


Church Lane is too narrow to be used as access for new housing.

Noted Sites on Church Lane not taken forward as a Preferred Options.

Site 325a – Land to the rear of 101-137 Bucklesham Road.

General comments.

Anglian Water 325a: May require Mains Diversion. Water Mains Crossing Site, Sewers Crossing Site.

Noted. AAP includes this site as a Preferred Option with a policy requirement that drainage in this area needs to be improved before any development can come forward.

Site 712 – Land to the rear of 18 Falkenham Road.

General comments.

Rt. Hon Therese Coffey

It is my understanding the Falkenham Road site has been backed in a local consultation session run by the Parish Council. Concerned about over development if all the other sites were approved.

Noted. Planning permission granted on this site for 43 units in June 2015. Application reference DC/14/4225/FUL.


SCDC should insist on a change of the housing mix currently seen as part of the application on this site.

Planning applications are considered on their own merits by Development Management colleagues and ultimately the Planning Committee.

A change to a specific planning application is currently beyond the remit of the AAP. Planning permission granted on this site for 43 units in June 2015. Application reference DC/14/4225/FUL.


Maaike Lensen The provision of affordable housing in Kirton will increase the range of housing options available to younger families in the village.

Noted. The AAP will seek to deliver 33% affordable housing in line with Core Strategy Policy DM2.

Mark King

The provision of affordable housing in Kirton will increase the range of housing options available to younger families in the village.


More homes needed for young families, especially Kirton where house prices are high. I strongly support this proposal.


Comments of Objection (Discount sites) - Due to the number of similar objections towards sites 325a, 770, 951 and 950 in Kirton/Falkenham,


the comments have been summarised as below:


Jane Bartle Donna Sperling John Jay J Durrant Sarah King Helen King R & T King Paul & Caroline Skippins Peter Woodmass Ann Worledge Mr & Mrs Payne Brian Baker Fred Last Mrs J Crosbie Mr & Mrs D Piotrowski Eleanor Piotrowski Olivia Piotrowski Colin & Sue Walker Andrew Camplin

Inadequate access and potentially difficult approach road to site; Development would lead to increased levels of traffic and may overburden local road network; No footways;

Additional housing will overburden the sewer system;

Detrimental affect on residential amenity - especially noise, disturbance and light pollution;

Development will block views of the countryside;

Infilling could ruin the character of the village of Kirton whilst Estate development would overwhelm it;

No requirement for additional private open market housing in Kirton/Falkenham;

No local employment opportunities in Kirton/Falkenham;

Development would adversely affect the value of my property;

Insufficient infrastructure to support further development;

No local employment opportunities in Kirton/Falkenham;

Detrimental affects on the natural environment;

Confusion regarding the volume of future housing being proposed for Kirton.

Site 770 is landlocked unless 951 is developed.

Proposed housing mix does not meet Kirton’s needs.

Remarks concerning the scoring findings in Sustainability Appraisal.

Kirton is identified in the Core Strategy as a Local Service Centre and therefore is expected to take an element of growth and development over the plan period (2010-2027). The Council has been working with partners such as Suffolk County Council and Anglian Water to identify infrastructure constraints in the village. Any potential development across the district will be expected to meet Core Strategy policies in relation to affordable housing provision and housing mix and type which will provide a range of housing opportunities for all. Future development needs to take into account impact on landscape and the natural environment and these issues will be revisited through the Sustainability Appraisal process which evolves alongside the production of the AAP.

Planning permission was granted for 43 units on a site at Falkenham Road in June 2015. As a result, Kirton has taken some growth during the plan period in line with its position as a Local Service Centre. A further site has been identified as a Preferred Option (Site 325a, Bucklesham Road) which will provide a small number of further housing opportunities in the village over the remainder of the plan period.

Ref 3004 - Land at Bucklesham Road, Kirton.


Support for site for housing (0.2 ha) by promoter of site.

Site is very small and would only provide a limited number of units which

Site is not included within the Preferred Options as the Council considers it appropriate to identify


Map of site provided at the end of the document may not deliver the appropriate level of affordable housing provision or a mix of housing types and tenures as required by the local community.

other sites.

Ref 3020 - Land at Kirton Road, Falkenham.

Stephen Creasey

Support for site for housing (2.21 ha) by promoter of site. Map of site provided at the end of the document

Noted. Site is adjacent to existing properties but would lead to an increase in ribbon development in this location and may lead to settlement coalescence between Kirton and Falkenham.

Site is not included within the Preferred Options as the Council considers it appropriate to identify other sites.

Ref 3002 – Land at Searson’s Farm, Cordy's Lane, Trimley St Mary.


Support for site for housing (0.41 ha) by promoter of site. Map of site provided at the end of the document

Site is adjacent to existing properties but is considered to be an isolated location on the edge of the countryside which is only accessed via a single track carriageway. Small site would only provide a limited number of units which may not deliver the appropriate level of affordable housing provision or a mix of housing types and tensures as required by the local community.


Ref 3003 - Land at Great Street Farm, Trimley St. Mary.


Support for 1 ha site for housing by promoter of site. Map of site provided at the end of the document

Noted. Site is not included within the Preferred Options as the Council considers it appropriate to identify other sites.

Ref 3011a - Land at Candlet Road, Felixstowe.

Christchurch Property Company Limited

Large scale site with potential for 500+ dwellings and associated infrastructure on a site north of Candlet Road. Subject to planning application DC/15/1128/OUT which was refused. Map of site provided at the end of the document

Site refused planning permission by Planning Committee in June 2015. The site is not considered to represent organic and evolutionary growth of Felixstowe as required by the Core Strategy. Across the Felixstowe Peninsula, the sites identified as



preferred options provide the number of units required to meet the Core Strategy targets.

Ref 3028 - Land at Manor Terrace, Felixstowe.

Dave & Tricia Bewers

Support for small site to be used for housing by promoter of site. Map of site provided at the end of the document

Noted. Sits is currently used for caravan accommodation which supports the tourism industry of Felixstowe and should be retained.


Ref 3031 - Land off Thurmans Lane, Trimley St Mary. Resubmission of SHLAA site 383h

ADP Limited Site submitted for residential development by the promoter of the site.

Noted. Site is small and below the 0.25ha threshold outlined in the SHLAA. Access could only be achieved from Thurmans Lane which the County Council have discounted. Adjacent to an area proposed to be protected from development and future development may have an impact on setting of Listed Buildings nearby.


Q8. Is the Council correct to remove the areas to be protected from development not within the Physical Limits Boundaries such as around Falkenham Church. Kirton & Falkenham Parish Council

Special protection for Falkenham Church and the Churchyard to remain. Essential to retain the protection as well as the removal of the physical limits boundary.

Noted The Preferred Options will include the Area to be Protected from Development in Falkenham.

The Economy.

Q11. Are all the employment sites within the Felixstowe Peninsula still required? Hutchinson Ports UK Limited

Noted that this plan is now superseded by the proposed Map of Employment Areas and Proposed Strategic Employment Areas in Felixstowe (Revised Jan 2015). Comments will be made on this proposed Map separately.

Noted. Boundary of the Strategic Employment Area has been redefined in the AAP. The Preferred Options document and the maps accompanying will define the extent of the


We suggest that the boundary coloured red follows the quay line at the Port (i.e. new berths 8 & 9); plus FSR 2; all of Trinity Terminal and the North Rail Terminal; additionally the boundary might extend 70m seaward from the quay this is the extent of the Ports limits of jurisdiction.

Strategic Employment Area and General Employment Areas.

EDF Energy Networks Ltd

The document recognises that the Felixstowe Peninsula economy is dominated by the Port of Felixstowe which is of strategic importance within the regional and national economies. EDF Energy supports the Council's approach to protect its use as it plays an important function for sea transport of goods to the existing Sizewell B station and could potentially serve the future Sizewell C station.

Noted. The AAP recognises the strategic importance of the Port of Felixstowe and its contribution to the wider economy.


Felixstowe Town Council Kimberley Williams

The Port has been automating jobs rather than creating new ones, those people who had their jobs made redundant need to be redeployed first, before encouraging inward migration, besides not everyone wants to live where they work as evidenced by the relatively lower cost of housing in Felixstowe compared to other parts of the District.

Noted. The Council have been in discussions with the Port of Felixstowe to understand their current position which has informed the AAP.

The AAP seeks to provide a more robust and balanced employment base across the Felixstowe Peninsula which will reduce the reliance on the Port for employment opportunities.

Q12. Are there any other potential employment sites which need to be brought forward? Discounted SHLAA 2014 site 998 - Land to the

rear of Street Farm, Levington Lane, Bucklesham.

Artisan Planning & Property Services Ltd

Proposed for mixed use employment and residential led scheme (2.17 ha). There is an identified need recorded at paragraph 5.4 of the FPAAP 2015 for a further 8.5 ha of additional land within the district which is

The site was discounted in the 2014 SHLAA because the site is poorly related to the existing settlement and access is only available through an existing commercial site.

The AAP does not identify this site as a preferred option as other sites are considered more appropriate to meet housing and employment needs across the Felixstowe Peninsula.


required to support business and help facilitate the creation of new jobs. It is expected that part of the 8.5 hectares of employment land needed will be located within the Felixstowe Peninsula area in order to facilitate potential employment generating uses. The land at Street Farm is capable of delivering some of that employment land need and that should be recognised in the emerging plan.

General comments.

Christopher Leffler

I believe that the District would do well to encourage new businesses by setting provisionally low business rates for them for, say, two years, to encourage entrepreneurship. The plan does not notice the small District Centre in Walton from the Garrison Lane junction towards the Main centre.

The AAP seeks to provide a more robust and balanced employment base across the Felixstowe Peninsula which will reduce the reliance on the Port for employment opportunities. The parade of shops at Garrison Lane does not meet the criteria identified for a District Centre. Although these shops provide local shopping opportunities they are not adjacent to a supermarket like the other District Centres.

The vision and objectives for the AAP recognise the need for a more balanced economy across the Felixstowe Peninsula. Parade of shops not identified as a District Centre.

Michael Ninnmey

David Lock recommended a non- Port Business/ Science Park away from the Port, Master plan suggested West Walton, alongside Dockspur roundabout: not part of FPAAP.

Local employment opportunities at land north of Walton High Street would provide another site for employment across the Felixstowe Peninsula.

The AAP includes a requirement for employment units to be delivered alongside residential units on the site north of Walton High Street.

Hutchinson Ports UK Limited

We suggest that the boundary coloured blue follows the quay line at the Port (i.e. new berths 8&9). The whole of Trinity Terminal and the North Rail terminal.

Noted. Boundary of the Strategic Employment Area has been redefined in the AAP. The Preferred Options document and the maps accompanying will define the extent of the Strategic Employment Area and General Employment Areas.


Q13. Should uses on employment sites be restricted to traditional B1 (Business), B2 (General Industry) and B8 (Storage and Distribution) uses or do we need to take a more flexible approach? Save Trimleys Against Growth

Paragraph 5.6 of the FPAAP states: "The Council expects that the type of business activity on the employment sites will be restricted through future policies to ensure that only appropriate uses take place at particular locations, e.g. restricting storage uses in locations where HGV's may have a detrimental impact on the rural road network and local residents." Comment By STAG: It is good that this expectation seems to exclude the use of land at Innocence Farm as a Distribution Centre and rail head.

Noted. The AAP seeks to provide a more robust and balanced employment base across the Felixstowe Peninsula which will reduce the reliance on the Port for employment opportunities. The only strategic employment area identified is the Port of Felixstowe. Any future strategic allocations will need to be considered through a Local Plan review.

The vision and objectives for the AAP recognise the need for a more balanced economy across the Felixstowe Peninsula.


As part of its evidence base, the Town Council recommends that the District Council investigate how port-related expansion plans may impact local projections across a range of scenarios, having regard to social economic and environmental factors.

Noted. This work will form part of the evidence base to support the a future review of the Local Plan.

No change.

Q14. Do any other sites surrounding the Port of Felixstowe need to be included within the Strategic Employment Areas? Mr J Stafford The document fails to mention the fact that Port

is facing a threat of increasing competition from new and existing ports within the U.K, and also European ports such as Rotterdam. A significant proportion of this investment is in automation. Whilst there is some potential opportunity for employment is supporting activities, much of this will be offset by increased automation in core port operations. Also the perceived link between dock 'expansion' and new housing needs in Felixstowe is spurious and misguided. Few jobs now have the long term security needed to justify uprooting your family each time you change jobs.

Noted. The AAP seeks to provide a more robust and balanced employment base across the Felixstowe Peninsula which will reduce the reliance on the Port for employment opportunities.


Hutchinson HPUK on behalf of the Port of Felixstowe Noted. The vision and objectives for the AAP recognise the


Ports UK Limited

welcomes the publication of this important document and the recognition of the importance of the Port on the local, regional and national economy.

importance of the Port of Felixstowe.

Keith Mahoney The document understandably does not mention the fact that Port faces the threat of increasing competition from investment in capacity at new and existing ports within the U.K. A significant proportion of the investments is in automation. In order to remain competitive Felixstowe Port must follow so whilst there is opportunity for employment in supporting activities this will be offset by increased automation. What is the strategic plan for developing other employment opportunities to reduce the risk and reliance on the continued success of the port other than tourism? There is no mention of this in the document.

Noted. The AAP seeks to provide a more robust and balanced employment base across the Felixstowe Peninsula which will reduce the reliance on the Port for employment opportunities.


Q15. Is the current town centre boundary still appropriate? Felixstowe Town Council

Felixstowe town centre has become a destination in its own right and provides a unique tourism opportunity due to its relationship and proximity to the seafront. Any policies relating to Felixstowe Town Centre should seek to acknowledge and further enhance this.

Noted. Felixstowe town centre provides a range of shopping facilities and services which serve communities across the Felixstowe Peninsula and further afield. The Council recognises the retail attractions as well as the tourist attractions found in the town centre.

The AAP seeks to protect the vibrant and successful town centre for town centre uses.

The Town Council proposes that the Town Centre boundary be redrawn in accordance with the map provided.

Noted. The Council welcomes the proposed revisions to the town centre boundary as suggested by the town council.

The AAP proposes a revised boundary which includes the areas below as suggested by the town council:

Waverley Hotel,

Auction Rooms on Orwell Road,

Ranelagh Road Car Park,

Area adjacent to railway station,

Rear parking areas on Fleetwood Road and off


Cobbold Road.

Policies AP180 and AP181 should be reviewed within the AAP to be included within any policies for the town centre as a whole

Noted. The AAP has included the key aspects of these Local Plan policies as preferred options.

The Town Centre Management Plan was a worthwhile process which produced several benefits for the town, such as shared space. This should be revisited to create a new up-to-date Town Centre Management Plan.

Noted. Although Town Centre Management is beyond the scope of the AAP the further continuation of the shared space scheme is welcomed.

The AAP has included the continuation of the shared space scheme (between Orwell Road and Bent Hill) within the preferred options document.

It is important to restrict residential uses in this area to upper floors only and to limit office space to upper floors as per policy AP180

Noted. The AAP seeks to protect ground floor uses to retail only and welcomes no retail uses on upper floors in accordance with the Use Classes Order and Permitted Development Rights.

Carol Florey I support the change of boundary in the North West Corner as it seems strange to cut across the middle of a site.

Noted. The preferred options document includes a revised boundary for the town centre which includes this site.

Q16. Should any areas be included or excluded from the town centre boundary? Christopher Leffler

The first two areas should be included. The areas fronting the Triangle should be included. The Car Parks are a vital part of the local economy for both residents and tourists. It is difficult for us residents to find a parking place in the season, and increasingly at other times of the year. It may be necessary to consider building more capacity by either adding a second storey at Ranelagh Road, or building downwards for an underground area.

Noted. The preferred options document includes a revised boundary for the town centre as well as a policy which seeks to protect car parking opportunities across Felixstowe.

Q17. Does the primary shopping area need to be extended to include areas fronting the Triangle? Felixstowe Town Council

The expansion of 'other facilities' for the town centre referred to in Core Strategy Policy SP21 should be given more detail. The Town Council would support a revision of this paragraph where it refers to the 'sequential test as stated in NPPF paragraph 24'.

Noted. The AAP needs to be in accordance with the NPPF, Use Classes Order and Permitted Development Rights which give flexibility to town centre uses and other facilities normally found within town centres.

The preferred options document includes town centre policies which promote retail activity alongside other uses and facilities which are found within the town centre.


The Town Council recommends extending the Primary Shopping Area, as defined by saved policy AP179, to include the areas of Hamilton Road and Cobbold Road to the east and south of The Triangle. Policy AP179 to be retained in a format which retains a flexible control over a range of uses, whilst preserving primarily retail uses.

Noted. The preferred options document includes an extension to the primary shopping frontage, as well as a policy which seeks to retain retail uses within the primary shopping area.

Carol Florey I support the idea of extending the primary shopping frontage to include the Triangle shops.

Noted. The preferred options document includes an extension to the primary shopping frontage.

Q18. Should the boundaries of the existing District Centres be re-defined? NO SPECIFIC COMMENTS RECEIVED

Q19. Do any other District Centres or Local Centres need to be identified as part of the Felixstowe Peninsula AAP? Carol Florey I would suggest the parade of shops near to the

crossroads of High Road and Garrison Lane should be considered as a District Centre or the Walton District Centre extended to include it. I do not consider the parade of shops at Faulkeners Way sufficient to be considered as a District Centre.

The parade of shops at Garrison Lane does not meet the criteria identified for a District Centre. Although these shops provide local shopping opportunities they are not adjacent to a supermarket like the other District Centres.

Parade of shops not identified as a District Centre.


Page 27, Map Extract 2: This should be redrawn to include the surgery but not the adjacent open space. This should be redrawn and extended in both directions from the Garrison Lane junction to Longcroft to include the various premises along this road. The Town Council supports the identification of both the Spar supermarket and parade of shops on High Road East, opposite Brackenbury Sports Centre; and, Lidl Supermarket and the parade of

Noted. Surgery to be included within the District Centre. Walton District Centre extended to include Surgery and Public House on the corner of Maidstone Road. Extending the District Centre further is considered inappropriate because it will include a large number of residential units. Noted.

The AAP includes a revision to this District Centre boundary as a preferred option. The AAP includes a revision to this District Centre boundary as a preferred option. The AAP includes a revision to this District Centre boundary as a preferred option.


shops at Undercliff Road West, near the Ordnance Roundabout as District Centres. The Town Council supports the concept of smaller retail areas to be identified as Local Centres and would include the vicinity of Beach Station Road traffic lights and the junction of Wadgate Road/Grange Road. A clear policy is required to protect the character of these.

Noted. Individual shops provide shopping opportunities across the district through Core Strategy Policy DM30 which identifies individual shops as a Key Facility.

Individual shops are not shown on the maps supporting the preferred options document.

Michael Ninnmey

5.2b New District- Walton-cum-Felixstowe between Chester Road and Garrison Lane (Traffic Lights).

The parade of shops at Garrison Lane does not meet the criteria identified for a District Centre. Although these shops provide local shopping opportunities they are not adjacent to a supermarket like the other District Centres.

Parade of shops not identified as a District Centre.

Q20. Is it necessary to protect the existing car parks through a specific allocation? Carol Florey I strongly support the idea of free parking after 3

in car parks adjacent to the primary shopping area.

The management of car parks and charges within these is outside of the scope of the AAP.

The AAP seeks to protect car parking provision across the Felixstowe Peninsula.

Hutchinson Ports UK Limited

In respect of 2 of the Landguard Car Parks this land is leased from the Felixstowe Dock and Railway Company and not owned by SCDC. It is suggested the wording is amended in both the text and table to refer to Car Parks being 'operated' by SCDC not 'owned'.

Noted. The preferred options does not list the car parks across the Felixstowe Peninsula


The Convalescent Hill site provides a good opportunity for a comprehensive development. A multi-level design incorporating, as a minimum, the existing public parking provision within a mix of resort, parking and residential use could be considered here. Potential references for such a designed could include the Design Brief referred to in AP199 and the David Lock report. Similar potential exists at Garrison Lane car park. This large site could lend itself to a design

Noted. The AAP seeks to protect car parking provision across the Felixstowe Peninsula, but redevelopment opportunities will be supported as and when these come forward as long as they maintain the same level of car parking provision within the same area.


incorporating retail and parking. Coach parking is known to be required and this site provides, at present, the optimum location for this.

Q21. Can the tourism needs of Felixstowe be met under one blanket criteria based policy? The Theatres Trust

The Trust supports measures to enhance and promote tourism and tourism facilities and are pleased the Spa Pavilion is acknowledged as an important local facility. However, to reflect planning guidance at Para 70 of the National Planning Policy Framework, the AAP should also seek to protect, as well as enhance existing community and cultural facilities. Facilities such as the Spa Pavilion support the social and cultural well-being of the local community and tourists and to the local economy.

Noted. The Spa Pavilion is an essential part of the tourism and resort in Felixstowe and is to be protected and enhanced.

The AAP outlines a number of preferred policy options which consider tourism uses in Felixstowe.

Q22. Are there any tourism related policies which the Council need to retain as specific policies? Felixstowe Town Council

Resort began in Victorian times (c.1891). The Town Council requests that the character of each of the distinct sections of the Felixstowe coastal frontage are protected by specific policies in the AAP. Paragraphs 11.160-11.219 of the 2001 Local Plan and its corresponding Proposals Map are regarded by Members as being generally still valid and provide a reference point for this. All the policies referred to in that section should be updated for inclusion in the AAP; with the exception of AP202, which has been implemented, and references made in 11.212 to the Marine Aggregate Terminal, which are now obsolete.

Noted. Historic references to Felixstowe will be corrected in the preferred options document. The AAP seeks to protect the coastal frontage of Felixstowe and identifies individual character areas which are the focus of the policies.

The AAP outlines a number of preferred policy options which consider tourism uses in Felixstowe.

Vivien Grant I notice that Land at Felixstowe Sunday market site, Sea Road, is included in the above plan as a SHLAA site within the Felixstowe Housing Market Area (Table 2, Page 14). I do not understand how

Any redevelopment of the Sunday market site would be conditional on the retention of tourist/resort/commercial activities on the Sea Road frontage in

The AAP includes a preferred policy which outlines how the Sunday Market site will be redeveloped for residential uses but with a focus on tourism/retail/commercial activities on the Sea


this area can be included, as it is a long standing feature of Felixstowe and attracts crowds of visitors each year. In the Plan, Mannings and the Sunday market are noted in paragraph 5.35 on page 30 as being combined with ' important tourist attractions' and 'provide a fundamental contribution to the resort'. How can these two aspects be reconciled?

line with the long standing policy as well as the successful relocation of the Market.

Road ground floor frontage.

Carol Florey The Sea Road Promenade area is a disgrace and should be identified as an area for immediate attention. It is in the centre of the tourism area and is an absolute disgrace.

Noted. The AAP outlines a number of preferred policy options which consider tourism uses in Felixstowe and the aspirations for the sea front.

Graham Henderson

Felixstowe Ferry is supposed to be part of the Town yet apart from comment on houseboats and some references to tourism we get no specific mention in the document. Nor are we included on the document maps of Felixstowe and the Trimleys.

Noted. Felixstowe Ferry will be shown on the maps supporting the preferred options document and the AAP recognises the unique character of Felixstowe Ferry in the tourism policies.

Historically there was SCDC planning policy that stated that there would be no further building allowed at Felixstowe Ferry. Has this now been dropped from policy?

No. Felixstowe Ferry is still outside of the physical limits boundary and is subject to the countryside restraint policies. Outside of the physical limits boundaries, new development is severely restricted.

Felixstowe Ferry is shown as being outside of the physical limits boundary on the maps supporting the preferred options document.

I would remind you of a survey some years ago by County Council that Felixstowe Ferry was the hottest tourism spot in Suffolk with over 200,000 annual visitors.

Noted. The AAP recognises the unique character of Felixstowe Ferry in the tourism policies.

Landguard Project Officer

A single tourism strategy for Felixstowe would be useful providing a joined up approach to all the elements that make up the tourism offer; attractions, accommodation, retail, food/drink, signage, car parks, marketing/events/promotion. Felixstowe coastal strip has 4 distinct areas that attract visitors: Felixstowe Ferry & Golf Course, Spa and Seafront Gardens, Pier/Leisure Centre to

Noted. The Council recognises the different areas on the Felixstowe sea front and identifies these in the AAP. Issues such as signage/marketing/promotion are outside the scope of the AAP.

The AAP outlines a number of preferred policy options which consider tourism uses in Felixstowe and the aspirations for the sea front.


Manning's/Martello Park, and Landguard. Although the character of each area needs to be kept distinct they need to be joined up with pedestrian, cycle, bus routes, car parks, signage and facilities. A single pedestrian/cycle accessible promenade from ferry to Landguard would be a good start.

Environment. General comments.


Gillian Mason Trevor Mason

It is essential that the AAP seeks to develop a revised and relevant policy on areas to be protected from development, and those areas which are adjacent to the AONB, should be included. Site 502e cannot be deemed "suitable" when measured against sustainability and environmental assessments. This site, together with 502-502c, should form part of those areas of high environmental importance which help form the townscape and communities within the peninsula. The development at Ferry Road went against the Core Strategy environmental policies, and saved Local Plan Policies; this should not be allowed to happen with any more greenfield sites.

Areas to be protected from development relate to areas which make a significant contribution to the open character of an area and are not used in relation to the landscape and areas adjacent to the AONB. The site north of Conway Close (502e) has been subject to Sustainability Appraisal and considered against a range of environmental policy constraints. These have identified that the site is suitable for potential development. The Council’s considerations in relation to the development at Ferry Road are well documented in the Case Officer report and the Minutes associated with that decision.

The AAP identifies land north of Conway Close as a preferred option.

RSPB All designated wildlife sites should be identified. These should include non-statutory sites such as County Wildlife Sites, as well as those benefitting from statutory protection such as SSSIs and European sites (SPAs, SACs and Ramsar sites). In addition, sites supporting priority habitats and

All designated sites are taken into account alongside planning applications and future redevelopment proposals or potential allocations.

The AAP includes reference to the relevant designations where appropriate or where mitigation measures are required.


species under the Natural Environment and Rural Communities Act (2006) should be identified. It should be noted that such protection should not be limited to consideration of impacts from development directly on or adjacent to a protected site, but should include indirect impacts such as those of increased recreational pressure.

Michael Ninnmey

Should River Orwell, north shore be a AONB? 6.18 Settlement time line between the orwell- Deben rivers much longer than (?)- from BC 2500-now. Becker- Roman (Castle till 15c) LANGUARD (HENRY VIII) MARTELLO TOWERS (8 now 9 1/2) RAF FELIXSTOWE/BAWDSEY (RADAR HOME) COLD WAR BUNKER

Noted. Noted.

The maps supporting the AAP identify this area as part of the AONB. The AAP will ensure that the evolution of Felixstowe will be detailed correctly.


Suggest that a paragraph dedicated to the DEP (Deben Estuary Plan) be included in the AAP.

The Deben Estuary Plan is just one document within the evidence base which the AAP is based upon.

The AAP includes reference to the Deben Estuary Plan where relevant.

Graham Henderson

Para 6.17 makes reference to the DEP Plan but only states that there may be a need to take similar risk base on estuaries as for coastal zones. It should not be "maybe a need" but applied. There are other aspects of the DEP Plan that need inclusion once agreed by council but I assume can only be after it has been adopted/endorced by Council in March.

Noted. The Deben Estuary Plan is just one document within the evidence base which the AAP is based upon.

The AAP includes reference to the Deben Estuary Plan where relevant.

AQMAs (Air Quality Management Zones)

Julie Cornforth Why have only 1 AQMA in Felixstowe. Air pollution in Felixstowe doesn't just stop in one place! The prevailling winds takes the pollution from the dock over Felixstowe town so it might be an idea to test the air quality in other locations around the town and the A14? Test the air quality all around Felixstowe and the A14 to

The Council’s Environmental Protection Team deal with issues of air quality across the district. AQMA’s have been identified in various places across the district and are closely monitored to determine whether air quality is increasing, decreasing or is static. No

The AAP does not include reference to an additional AQMA.


ensure that the Air Quality within these areas is not to the detriment of the environment or public health.

additional AQMA’s are identified at this time.

Hutchinson Ports UK Limites

Suggest amended and additional wording, ... at Ferry Lane, Felixstowe. This is as a result of concentrations of Nitrogen Dioxide above the national objective in 2009. The most significant sources of NO2 at the AQMA have been identified as Container Handling (37%), External Heavy Duty Vehicles (29%) and Background Concentrations (23%) emissions from and associated with the Port of Felixstowe.

Noted. The Council’s Environmental Protection Team are aware of the reasons for the AQMA and continually monitor the air quality in and around Ferry Lane.

No change to the AAP.


The continued monitoring of nitrogen dioxide levels within the AQMA allows us to determine what the levels are and whether they are increasing, decreasing or static, it does not in itself actually enable us to ensure that air quality is not detrimental. This is tackled by the statutory Air Quality Action Plan which has been produced for the AQMA - the aim of which is to protect Public Health only. Air quality affecting 'the environment' itself is not covered or tackled by the Local Air Quality Management process but will obviously be positively impacted upon.

Noted. Issues surrounding air quality will be explored further as the AAP evolves through consultation.

The preferred options document includes reference to the need for air quality assessments, the requirement to mitigate the impact of future development on air quality and monitoring to ensure that any future development across the peninsula does not have a negative impact on the AQMA identified at Ferry Lane, Felixstowe.

Q23. Should policies protecting Landscape and Townscape features be combined as there are certain similarities within these designations which seek to avoid material adverse impact upon these areas? If so, should there be one policy to cover these designations, or should some division be maintained? Michael Ninnmey

6.9 Mitigation on noise/light impact needed for residential dwellings along route to dock.

Noted. The AAP seeks to identify future requirements as opposed to mitigating the existing issues.



The Town Council would recommend that division of policies protecting Landscape and Townscape features be maintained.

Noted. The preferred options document outlines policies for landscape, access to the countryside, heritage as individual policies.

Historic England The European definition of Landscape includes Noted. The AAP includes a preferred policy which focuses


urban landscapes and therefore there may be some logic to combining policies to protect natural landscape and urban landscape features, but care will be needed to ensure there is no blurring of the issues resulting in a loss of protection. We would specifically advise that the policy on Areas to be Protected from Development is not combined with policies on Conservation Areas. Some conservation areas contain sites that are currently negative features where development might result in enhancement. Historic England generally favours separate policies specific to the needs of the historic environment.

on areas to be protected from development. Conservation Areas are covered by Conservation Area Appraisals and Core Strategy Policy SP15.

Q24. Is the criteria within the Special Landscape Area policy (AP13) still appropriate? Felixstowe Town Council

The Town Council requests additional information on where sites designated as Special Landscape Areas are in Felixstowe.

No part of Felixstowe is covered by Local Plan ‘Saved’ policy AP13-Special Landscape Area. The only Special Landscape Area within the Felixstowe Peninsula is in Kirton.

The maps accompanying the preferred options document show the environmental designations across the Felixstowe Peninsula.

Q25. What does the Coastal Change Management policy need to include? Marine Management Organisation

The MMO feels there is merit in also including reference to East Inshore and East Offshore Marine plans as another document to consider aligning with. The East Inshore and East Offshore Marine Plans are available on line via the link provided https://www.gov.uk/government/collections/marine-planning-in-england. Under sections 5.7 to 5.11 Felixstowe port and its importance are discussed. This would be an appropriate area to mention the East marine plan ports policies, especially PS3 which supports port growth and development.

Noted. The evidence base supporting the AAP is comprehensive and includes many documents and studies including the Marine Plan.

The preferred options document makes reference to appropriate evidence base document where appropriate.

https://www.gov.uk/government/collections/marine-planning-in-england

https://www.gov.uk/government/collections/marine-planning-in-england


Section 6.11 makes reference to climate change and links can be made to the east marine plan.

Michael Ninnmey

Coastal/river defence dual purpose- defence/tourism.

Noted. No change to the AAP


Any Coastal Change Management policy must not preclude development within areas that are protected from flooding or erosion. Town Council is firmly of the view that when considering such a policy, full regard to existing defences should be included. Similarly, the 30m buffer zone may be too restrictive in several otherwise suitable locations if adequate coastal protection measures have already been introduced.

Noted. Upon further consideration of the Shoreline Management Plan and discussions with the Coastal Management Team, the AAP does not require a Coastal Change Management Policy because the Shoreline Management Plan seeks to hold the existing coast line in Felixstowe.

The AAP includes an explanation as to the current thinking and position on Coastal Change Management Areas for the Felixstowe Peninsula.

Graham Henderson

6.15. This para makes vague reference to following Waveney policy of no building within a 30m buffer of projected 100 year risk zone. This makes no logical sense as the 30m distance could still be on a flood plain. A policy should be adopted of NO building in an EA specified flood cell or below 5m contour line on coast and estuaries. It does concern me that planning committees get comment from the Environment Agency on planning applications but members of the Committee do not have these specific recommendations brought before them at meetings as they are not statutory.

Noted. The Environment Agency are a statutory consultee in respect of flood risk and any future development will be directed to locations which are in areas not at risk of flooding. A Coastal Change Management Policy is not required because the Shoreline Management Plan seeks to hold the existing coast line across the Felixstowe Peninsula.

The AAP includes references to flood risk constraints in the appropriate areas across the Felixstowe Peninsula. It also includes an explanation as to the current thinking and position on Coastal Change Management Areas for the Felixstowe Peninsula.

Q26. Local Plan Saved Policy AP1 on Conservation Areas is more detailed that the other policies. Is this extra detail justified, and if so does this warrant a separate policy for Conservation Areas? Christopher Leffler

The Ferry Area should be both a Vulnerable area and a conservation area. The wild area between the Recreation Ground pitches and the A14 should be retained as it is as a conservation area where dog walkers and children are daily looking for recreation.

Felixstowe Ferry is outside of the defined physical limits boundary and therefore not a location which the Council expects to see future development. The area north of the A14 and Candlet Road is also outside of

The maps accompanying the AAP clearly show these areas as being outside of the physical limits boundary.


the physical limits boundary and the AAP seeks to protect this area from future development.

Q27. Should the policy on Areas to be Protected from Development be combined with the policy on Conservation Areas, as Areas to be Protected from Development have similar protection to areas identified in conservation areas which should not be developed? Felixstowe Town Council

The Town Council believes that the extra detail provided in the saved Policy AP1 on Conservation Areas is justified and a separate policy for Conservation Areas is warranted. The policy on Conservation Areas and policy on Areas to be Protected from Development should be kept separate as there are locations in Felixstowe that do not fall in to the conservation area but which require specific protection under a policy similar to AP28.

Noted, however Core Strategy Policy SP15 provides the strategic policy with respect of conservation areas in parallel with the Conservation Area Appraisals published for the individual areas. Areas to be protected from development have been identified and are covered by a separate policy.

The AAP includes a separate policy for Areas to be protected from development. These areas and conservation areas are shown on the maps accompanying the preferred options document.

Q28. Should policies be written to consider proposals for development affecting protected wildlife or geodiversity sites or landscape areas or are they adequately covered by the Core Strategy? RSPB Core Strategy policies need to be 'supported by

appropriate detail' (see para.6.5) within the AAP to ensure protection/consideration of national and international wildlife sites (SPA/SAC/Ramsar/SSSI) and protected and priority species is commensurate with that given to e.g. the Heritage Coast and AONB. We recommend that a specific policy emphasising the importance of biodiversity and protected sites should be included.

Noted. Core Strategy Policy SP14 outlines the Council’s position to Biodiversity and Geodiversity and it is not considered appropriate to repeat this policy (or a similar policy) within the AAP.



Policies should be written to consider proposals for development affecting protected wildlife or geodiversity sites or landscape areas to support the Core Strategy policies SP14 and SP15 as per Page 33, Para. 6.5.

Noted. Core Strategy Policy SP14 outlines the Council’s position to Biodiversity and Geodiversity and it is not considered appropriate to repeat this policy (or a similar policy) within the AAP.

No change to the AAP. Policy requirements relating to green


Undoubtedly there will be many ways in which the Felixstowe Peninsula AAP can promote a network of green infrastructure; however this wide ranging issue requires additional time to consider.

Noted and agreed. The AAP will seek to facilitate the necessary green infrastructure and access to the countryside alongside development which comes forward across the Felixstowe Peninsula.

infrastructure and access to the countryside have been included within the Preferred Options document.

Q29. Which sites across the Felixstowe Peninsula need to be identified to protect and enhance biodiversity and geodiversity as detailed Core Strategy policy SP14? NO SPECIFIC COMMENTS RECEIVED

Q30. Which sites across the Felixstowe Peninsula need to be identified and protected to resist settlement coalescence as detailed by Core Strategy policy SP15? Michael Ninnmey

6.22 Coalescence already taken place Felixstowe, Walton and Trimley St Mary.

Noted. The AAP identifies an area to be protected from development between Felixstowe and Trimley St Mary to resist any further settlement coalescence.


Retained Policy AP171-Felixstowe Peninsula-Separation of Town from Trimleys requires a buffer area of greenfield separation, whose size has not been defined, to be retained between Walton and Trimley St Mary. If properly enforced, this could mean that some or all of the prime food producing farmland described as "at and surrounding Felixstowe Rifle Club, south of Dockspur Roundabout" (Site 451g), could be excluded from the sites deemed to be suitable for housing allocations. It will be remembered that this area of farmland was previously the subject of a rejected Planning Application for a Tesco Superstore and a new housing development.

The site north of Walton High Street has been identified as this presents an opportunity for organic and evolutionary growth in a location well related to existing services, facilities and education opportunities. The Council is aware that this would lead to the loss of some prime agricultural land but on balance is considered appropriate.

The AAP identifies an area to be protected from development between Felixstowe and Trimley St Mary to resist any further settlement coalescence. A preferred policy detailing policy requirements to bring the residential allocation forward is also included.

Q31. How can the Felixstowe Peninsula AAP promote a network of green infrastructure? Julie Cornforth The David Lock report stated that the AONB

should be extended. The Haven Gateway Plan also stated that there

Noted. The AONB is defined by Natural England as the statutory body. Links to the countryside from new development

The AAP includes a policy in relation to accessing the countryside as well mitigation measures to ensure that new development provides links to


should be "green corridors" for the wildlife. Perhaps SCDC should consider the protection of wildlife in the Felixstowe area.

sites will be welcomed as part of the AAP.

green infrastructure opportunities.

Community and Well-Being issues.

Q32. Are the current open space designations appropriate? Julie Cornforth It was identified in the Haven Gateway Green

Infrastructure Plan that Felixstowe has the least accessible "Natural Green Space" at present. The town's location together with the scale of the port means that there are limited opportunities to gain easy access to the countryside. So why ruin what little countryside that we have left.

Noted. Development sites have been identified by taking into account the impact they will have on the countryside and the opportunities they present to improve access to the countryside.

The AAP includes a policy in relation to accessing the countryside and what steps will be taken to ensure that deficiencies identified in the evidence base are overcome.

Q33. Are there any other areas which ought to be protected through an open space designation? Ian Buxton All current green space should be protected. The

area of outstanding natural beauty to the North of Ferry and Gulpher Roads to the Deben estuary should be protected from development and enhanced access provide for local people to enjoy.

Noted. The development proposed in the AAP is not considered to have a detrimental impact on the AONB and protects the open countryside outside of the built up area.

The maps accompanying the preferred options document show the physical limits boundary for the settlements in the Felixstowe Peninsula. These boundaries protect the countryside by directing future development to areas within the physical limits.

Carol Florey I cannot see the Grove mentioned anywhere but this should be an area to be protected from development. I also believe all existing parks and playing fields should be covered in this way.

Noted. The Grove is an important area of open space and recreation for the Felixstowe community. It is protected from future development through Core Strategy Policy SP16 and DM32. The Grove is also outside of the physical limits boundary so development in this area is considered inappropriate.

The maps accompanying the preferred options document shows the Grove outside of the physical limits boundary of Felixstowe.

Christopher Leffler

The allotment sites, all 5 of them need protecting as well as the public open spaces. There is a statutory proportion of plots per quantity of housing units, and it is vital if the areas are to be developed intensively, that those who wish to

Noted. Allotments are protected by Core Strategy Policy DM33 and it is not appropriate to repeat this policy in the AAP.

No change.


have plots should be able to get them. Allotment land is not marginal, it is essential for food, health via exercise as well as the produce, and mental health.

Sport England Suffolk Coastal DC have recently completed a Playing Pitch Strategy (PPS) which seeks to assess existing and future needs for playing fields and other outdoor sports facilities within the district. Sport England believes that playing fields should be protected from inappropriate development and the PPS will help to identify key sites within the Felixstowe AAP area which should be designated to strengthen their protection. This could include playing fields and other outdoor sports facilities such as artificial pitches, tennis courts, bowling greens etc.

The Playing Pitch Strategy is part of the evidence base which supports the AAP. Playing fields are protected under Core Strategy Policy SP16 and DM32 and it is not appropriate to repeat these policies within the AAP

No change.

Q34. What are the opportunities for improving green infrastructure within the Felixstowe Peninsula? Michael Ninnmey

7.1 Widen access to physical activity of all types for all ages for improved well being and Health. Sports field provision fallen/ significant restriction on access is school sport fields. Review across the whole FPAAP area. 7.2 Create a river to river walk, make a walkway from Jacobs Ladder to Dip Promenade, possible to add cycle route? 3.9 Public Access to Sea/rivers needs is improve (Public access, when dock closed Public Quay; removed. Proper Quay needed at Orwell mouth to support Sea/River trips: LANGUARD-HANWICH; SHOTNEY; IPSWICH Seatrips- Felixstowe Ferry- LANGUARD. Ferry-

Noted. The Suffolk Coastal Leisure Strategy which is part of the evidence base underpinning the AAP identifies measures to increase physical activity and leisure opportunities across the district. The Council will consider proposals for extending the promenade on their merits and in partnership with the relevant bodies and organisations if and when funds and projects come forward.

The preferred options include references to making links to existing sports and play facilities as appropriate.


Woodbridge- Sutton Hoo Promote tourism/Leisure/Sport ect 6.10/14 Coastal/river defence dual purpose- defence/tourism.

RSPB Para. 7.1 states that the Felixstowe AAP has the opportunity to identify site specific projects such as playing fields, green links, allotments and other facilities which are fundamental to the local communities. We note that opportunities should also be sought to enhance local ecological networks through the restoration, enhancement, buffering and linking of sites of biodiversity value. We recommend that strong links are made to the outputs of the Haven Gateway Green Infrastructure Strategy. As recommended above, this could be used to generate advice for developers regarding green infrastructure and biodiversity measures targeted at the requirements of the Felixstowe peninsula.

Noted. The Haven Gateway Green Infrastructure Strategy is part of the evidence base which supports the Core Strategy and the AAP. The Core Strategy details the Council’s approach to Biodiversity and Geodiversity is outlined in Core Strategy Policy SP14 and it is not appropriate for the AAP to repeat this policy.

The preferred options include reference to green infrastructure requirements where appropriate and promotes access to the countryside through an individual policy.


Undoubtedly there will be many opportunities for improving green infrastructure within the Felixstowe Peninsula; however this wide ranging issue requires additional time to consider. The AAP should support the proposals contained within the Felixstowe cycle infrastructure review recently conducted by Suffolk County Council for opportunities for improving the cycle network within the Felixstowe Peninsula.

Noted. The Felixstowe Cycle Strategy is part of the evidence base which supports the AAP.

The preferred options include requirements to ensure that new developments provide links to the existing network of footpaths and cycle ways.

Q35. What types of open space, sport and play facilities, community facilities are needed to generate a sustainable community? Felixstowe Town Council

Clickett Hill is not open space, it has planning permission as industrial land and therefore this designation has been superseded. Please can the Cliff Gardens be renamed to Spa Gardens.

Noted. Clickett Hill is included within the Strategic Employment Area. The preferred options document will include reference to the Spa Gardens.


With regards to the types of open space, sport and play and community facilities needed to generate a sustainable community, the AAP should overtly reference where these are included in the Leisure Strategy. Yes, the Felixstowe Peninsula would benefit from greater community facilities/ opportunities.

The preferred options document makes reference to a range of community facilities throughout.

Theatres Trust In regards to the question on page 40, we recommend that this section include policy for all community and cultural facilities that are important to quality of life, for which we would support the comment that the Felixstowe Peninsula AAP can play a key role in ensuring that facilities are retained and guarded against inappropriate development. .

Noted. These facilities are covered by Core Strategy Policy DM30 which seeks to protect Key Facilities across the district. It is considered inappropriate to repeat this policy within the AAP.

No change.

Sport England Community indoor and outdoor sports facilities all help to generate a sustainable and healthy community. Facilities include playing fields, tennis courts, bowling greens, multi-use games areas, swimming pools, sports halls, youth facilities (skate parks etc.) and informal areas for sport (parkland for kick abouts).

Noted. These facilities are covered by Core Strategy Policy DM30 and DM32 which seek to protect key facilities and sport and play facilities across the district. It is considered inappropriate to repeat this policy within the AAP.

The preferred options include references to ensuring that development is linked into existing footpaths and cycle ways which provide access to community facilities and recreation opportunities.


Allow cycling on the promenade (A similar sized seaside town - Bognor Regis, has already successfully implemented this). A network of better off road, well signed family safe cycle routes joining up the Peninsula. Well placed car parks and facilities so people from outside the Peninsula can access the network. It would relieve pressure on car parks in the town, near to the coast. Encourage more local people to cycle to school, work and during leisure time. These facilities, as well as being for the community can also be important attractions for visitors/tourists. The Leisure Centre review is an

Cycling along the Promenade is not within the remit of the AAP. The AAP takes into account the Suffolk Coastal Leisure Strategy and identifies the Leisure Centre as an important

No change. The preferred options document identifies the Leisure Centre as a attraction.


opportunity to provide top class, wow factor swimming/leisure pools with slides, small outside heated pool, etc. This would provide excellent facilities for the community and also be a major boost to tourism which would finance annual maintenance costs. It would also have the secondary benefit of boosting regeneration of commercial properties along sea road and the wider town, and allow the town to compete with other seaside destinations.

tourist and resident attraction in the town. Any proposals to redevelop the Leisure Centre would be considered on their merits in accordance with the AAP and Core Strategy policies relating to regeneration and redevelopment.

Q36. What are the opportunities for improving the cycle network within the Felixstowe Peninsula?

NO SPECIFIC COMMENTS RECEIVED

Q37. Would the Felixstowe Peninsula benefit from greater community facilities/opportunities? Landguard Project Officer

Raise profile of the town and improve image. Encourage younger people and families to stay/ move into the town. Improve fitness, health and wellbeing. Increase tourism, create jobs, boost local economy and encourage further outside investment.

Noted. The AAP seeks to identify the Council’s aspirations for the Felixstowe Peninsula and promotes the area in a positive manner.

Educational capacity.

Eric Southgate Spaces are available here because parents are sending their children to any school that they can get into off the Felixstowe peninsular because the local schools are below government approved levels according to OFSTED. Not Fit For 'Looked After Children' means not fit for purpose of anyone else’s children.

Noted. Suffolk County Council as education authority have been involved with the preparation of the AAP.

The AAP includes the requirement to link development to existing education opportunities across the Felixstowe Peninsula.

Carol Florey I challenge the statement 'there is capacity across the area for both primary and secondary education.' As I understand it there was only an additional capacity of 100 when the new Academy was built. This is not capacity to cope with 850 new families.

Noted. Suffolk County Council as education authority have been involved with the preparation of the AAP.

No change.


Suggestions regarding specific ‘saved’ Local Plan policies and future policy development. Need for retention of ‘saved’ Local Plan policies.

AP208 - Felixstowe urban fringe.


Gillian Mason Trevor Mason

Policy AP208-Felixstowe Urban Fringe-this policy saved from the Local Plan has served Felixstowe well in terms of protecting its limited countryside and open green space. Following the breaching of this policy in granting OPP on fields in Ferry Road, the green space left in that area provides valuable recreational opportunity and general "well being" to residents, visitors and tourists. As such the policy should be retained in the AAP, and not replaced by one which extends the town boundary. As smaller towns and rural villages in the district are protected from development, so Felixstowe should be afforded the same entitlement.

Areas outside of the defined physical limits boundaries are protected by Core Strategy Policy SP29: Countryside. This policy acknowledges the important economic, social and environmental assets that areas outside of the settlements bring to local communities and the district.

It is not considered necessary to repeat Core Strategy policy in the AAP. A newly defined physical limits boundary is shown within the preferred options document for public consultation.

AP171 - Felixstowe Peninsula - separation of town from Trimleys.


Retained Policy AP171-Felixstowe Peninsula-Separation of Town from Trimleys requires a buffer area of greenfield separation, whose size has not been defined, to be retained between Walton and Trimley St Mary. If properly enforced, this could mean that some or all of the prime food producing farmland described as "at and surrounding Felixstowe Rifle Club, south of Dockspur Roundabout" (Site 451g), could be excluded from the sites deemed to be suitable for housing allocations. It will be remembered that this area of farmland was previously the subject of a rejected Planning Application for a Tesco Superstore and a new housing development.

Noted, the AAP will seek to resist settlement coalescence where possible but in some locations communities will become closer as the organic and evolutionary growth comes forward as anticipated by the Core Strategy. It will be important to retain the separation of Felixstowe and Trimley St Mary but the Local Plan Policy is considered to be too restrictive and in part has already been eroded by developments such as Felixstowe Academy and the outline planning permission granted for up to 190 units on land south of Walton High

The preferred options document identifies a new area to be protected from development to the west of the A14 Dock Spur to maintain the separation between Felixstowe and Trimley St Mary. The preferred options document identifies a site for residential development with some business units and open space. The site is considered to be broadly in accordance with the Core Strategy and is extremely well related to the existing communities, services and facilities and education opportunities which on balance overcome the loss of the prime agricultural land in this location.


Street.

AP206 – Felixstowe – Landguard Fort /207 – Felixstowe – Land around and adjacent to Landguard Fort.


AP206/207 pertaining to development of Landguard as a visitor attraction are out of date. Under the S106 agreement with the port an interim visitor centre/cafe have been installed. Car parking has been increased but is still insufficient. The Landguard Partnership is seeking funding to improve the visitor offer in terms of access and interpretation, including the fort, museum and nature reserve. There is still uncertainty over when/if FSR2 will go ahead which will have a further impact on Landguard. Balance of needs of increased visitors and Nature Reserve/SSSI. There seems to be no policy regarding the Felixstowe-Harwich-Shotley Foot Ferry?

The AAP will seek to develop a policy which focusses on Landguard in respect of the unique character of this area. Proposals which boost tourism uses but are sensitive to the protected landscapes on the Landguard Peninsula will be supported. The Council will continue to be an active part of the Landguard Partnership and the AAP will be complementary to the work of the partnership.

The preferred options document contains a specific policy in respect of Landguard which strikes the balance between the unique landscape, scheduled ancient monument, visitor pressures and proximity to the port.

AP170 – Felixstowe – restraint.


The District Council should provide assurance that the principles of AP170 will be covered by the AAP.

The AAP will seek to ensure that Felixstowe grows and develops in an appropriate way which is in accordance with the Core Strategy and the NPPF.

The preferred options document provides further detail as to how Felixstowe will grow and develop.

AP187 – Felixstowe - Enhancement scheme.


Whilst the Town Council acknowledges the reason given for removing policy AP187 (as being that most improvements will be achieved through the imposition of landscaping conditions attached to planning permissions as part of normal development control considerations and by this means resources will become available) the AAP should provide some comment on how the appearance of industrial areas will be enhanced.

AP187 was superseded by the Core Strategy. Any future developments will be judged on their own merits and will be expected to ensure they do not have a detrimental impact on the surrounding area through loss of light or poor design.

The preferred options document provides details of the mitigation measures that are required for some developments across the Felixstowe Peninsula.

AP175 – Felixstowe – Carr Road.



Policy AP175: This must be retained as it is critical to avoid potential container traffic in this area. Policy SP5 in the Core Strategy defines general employment areas as being B1, B2 & B8 unless "specified in specific policies". Carr Road needs to continue to be restricted to B1 & B2 only to minimise heavy lorry movements. Similarly, Bridge Road should be restricted to B1 & B2 only to minimise heavy lorry movements to and from this site and consideration should be given as to how the number of containers currently located in this area can be reduced.

Noted and agreed The preferred options document includes a specific policy in respect of the Carr Road/Langer Road General Employment Area.

AP193 – Felixstowe - Clifflands carpark.


Policy relating to Clifflands Car Park has not been fully implemented and should be retained. "Bus Station, Garrison Lane" should now be renamed to the area north and east of the Garrison Lane / Langer Road junction.

Noted. The preferred options document contains a tourism policy which covers Clifflands car park.

Comments in Support of future policy development.


With regards to houseboats, the Town Council would like the see a policy which supported replacement of existing houseboats (rather than new/additional number). Houseboats, where appropriate, are part of the character of Felixstowe Ferry.

Noted. The preferred options document contains a tourism policy in respect of Felixstowe Ferry which addresses the issue of house boats and access to the River Deben.

Wm Morrison Supermarkets Ltd

There is no indication that the future policy would require Retail Impact Assessments to be carried out where applications for retail schemes are proposed on edge or out-of-centre sites. Our client's view is that this should be required in association with any application for retail development of 1,000sqm and above to reflect recent changes in consumer shopping habits and the changing face of convenience goods retailing: stores are becoming smaller and people are

Noted. The Council has undertaken some additional work to consider retail capacity across the district.

The AAP does not include a specific reference to retail impact assessment, therefore the threshold in the NPPF is that which the Council will use in respect of future retail applications.


generally shopping more frequently.


Maps of new sites submitted through the Issues and Options consultation

A number of sites were submitted to the Planning Policy and Delivery Team during the Issues and Options consultation for the Site Allocations document and the Felixstowe Peninsula AAP.

Some of these sites were resubmissions of sites previously identified in SHLAA 2014 as ‘deliverable’ or ‘discounted’ and are therefore not included as maps but are listed for clarification in the main document - Appendix 3: Tables of all sites considered. All new sites, and those where the boundary of a previously submitted site has been altered, are included below.

The new sites submitted are accompanied with lists of relevant constraints which have been identified on the Council’s GIS system and a brief summary of the sites’ status. The sites are laid out in a similar way to the SHLAA for consistency. Sites are drawn with a red boundary. A key is provided to identify policy designations on maps.

© Crown Copyright and database rights 2012 Ordnance Survey 100019684


FELIXSTOWE PENINSULA AAP 3002 Felixstowe housing market sub area Site ref

Parish Address Size (ha)

Constraints

3002 Trimley St Mary

Land at Searsons Farm, Cordys Lane

0.41 Saved policy AP172 – Felixstowe Port – Protection of the AONB

AONB to west Adjacent to countryside management site Listed buildings to the south (Searson’s Farmhouse,

grade II; Cartlodge to W of Searson’s Farmhouse, grade II; Barn to SW of Searson’s Farmhouse, grade II.

Site to east may be archaeological interest

Site discounted The site lies outside the physical limits boundary and therefore is in countryside. Development of the site may result in harm to the setting of nearby listed buildings. Potential encroachment on an existing employment site. Contrary to Saved policy AP172 – Felixstowe Port – Protection of the AONB.


3028 Felixstowe housing market sub area Site ref


Constraints

3028 Felixstowe Land at Manor Terrace

0.19 Adjacent to Landguard Nature Reserve

Flood Zone 2 and 3 < 0.25ha threshold.

Site discounted Site forms part of an existing caravan site. Site to be retained for tourism purposes. SP8 - Tourism


3003 Felixstowe housing market sub area Site ref


Constraints

3003 Trimley St Mary

Great Street Farm

1.01 Listed buildings to north-east Allotments to north/north-west Site of archaeological interest to

south SWT consultation area TPO nearby Public Right of Way nearby

Site discounted Development of this site had the potential to create development of a potentially undesirable ‘backland’ nature. The site would be accessed from High Road and issues regarding the siting of an electricity sub-station within the access area would need to be investigated further.


3004 Felixstowe housing market sub area Site ref Parish Address Size

(ha) Constraints

3004 Kirton Land at Bucklesham Road 0.20 N/A

Site discounted Site has been discounted in favour of an alternative site receiving greater community support.


3011a Felixstowe housing market sub area Site ref


Constraints

3011a Felixstowe Land north of Candlet Road

31.7 Floodzones 2&3 in NE corner of site Area which may be of archaeological

interest BAP species (including badgers) have

been recorded on site Sites and monuments: Cowpasture Farm

See DC/15/1128/OUT Planning application refused 12.06.2015.


3020 Felixstowe housing market sub area Site ref Parish Address Size (ha) Constraints 3020 Falkenham Land at Kirton Road 2.21 Listed building to east

Site discounted Falkenham is classified as an ‘other village’ and is therefore located in countryside. The site was considered to relate poorly to Kirton and would constitute potential ribbon development creating a potential risk of coalescence between Falkenham and Kirton.


3022a Felixstowe housing market sub area Site ref


Constraints

3022a Trimley St Martin

Land to the rear of Mill Lane

3.0 Allotments to NE Sites and monuments in site to

NW

Site discounted Resubmission and enlargement of SHLAA 2014 site 383a. Site 383a was identified as suitable in SHLAA 2014 however concern exists as to the suitability of Mill Close as an access route through an existing housing estate. Highways Authority was not in favour of direct access from High Road.


3022b Felixstowe housing market sub area Site ref


Constraints

3022b Trimley St Martin

Land to the west of High Road

1.66 Sites and monuments in site to NW, SW and

Site discounted Resubmission of discounted SHLAA 2014 site 383. The site was discounted as being poorly related to existing settlement. Although the original site has been reduced from 2.35 ha to 1.66 ha the issue of relative remoteness remains.


3022c Felixstowe housing market sub area Site ref Parish Address Size (ha) Constraints 3022c Trimley St Mary Land at Thurmans Lane 3.54 Listed buildings to west

TPOs to west Badgers recorded 35m west

Site discounted Resubmission of discounted SHLAA 2014 site 383c. The site was originally discounted due to Highways advice: Thurman’s Lane not suitable to serve further development. To prevent potential coalescence between Trimley St. Mary and Trimley St. Martin, and to protect the setting of nearby listed buildings, the preferred option for this site is for it to be designated as an Area to be Protected from Development.


3022d Felixstowe housing market sub area Site ref Parish Address Size (ha) Constraints 3022d Trimley St Mary Land at Thurmans Lane 1.24 Listed buildings to SW

Sites and monuments to SW

Site discounted Resubmission of discounted SHLAA 2014 site 383d. The site was originally discounted due to Highways advice: Thurman’s Lane not suitable to serve further development. To prevent potential coalescence between Trimley St. Mary and Trimley St. Martin, and to protect the setting of nearby listed buildings, the preferred option for this site is for it to be designated as an Area to be Protected from Development.


Key to site maps

Planning Policy and Delivery Team

Suffolk Coastal District Council

Council Offices

Melton Hill

Woodbridge

Suffolk

IP12 1AU

Tel: 01394 444761 / 01394 444558

E-mail: [email protected]

felixstowe peninsula area action plan - east suffolk council · 2016-06-20 · press releases ....

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