Saturday, 18 July 2015

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Dear Framlinghamians

This is it now. Any comments must be with The Planning Inspectorate by               
Please encourage family and friends to write as well.

Reference: APP/J3530/W/15/3011466

Reference: APP/J3530/W/15/3011493

·         The original planning applications from Taylor Wimpey and Persimmon were refused on a number of grounds including matters relating to employment transport and infrastructure (not least health and education); failure to protect the sensitive setting and edges of the town; matters relating to design; and, in the case of Fairfield Road, failure to maintain and enhance a sense of place. 
·         Suffolk Coastal District Council’s (SCDC) Head of Planning, Philip Ridley, recently announced that by the end of the month of July the Council expects to have a 5.18 years supply of land. Developers can no longer, therefore, argue for an automatic presumption in favour of sustainable development absent a 5 year land supply.
·         Taking in to account completed developments and outstanding/pending planning permissions in Framlingham, SCDC have a “suggested residual requirement” of between 75 and 150 homes for the Town between 2014 and 2027. Combined, Mount Pleasant and Fairfield Road would deliver 270 new homes in the next few years.  
·         SCDC recognise that “The numbers of homes which the two sites would provide would more than meet the numbers of new homes that the district council would be looking for Framlingham to contribute to the overall district housing total”. This suggests that the total number is in fact excessive and disproportionate both relative to the existing size of the Town (30% increase) and as a percentage of housing earmarked for the five Market Towns (25% v 19%).  This will have a material impact on the Town’s infrastructure and is unsustainable.

·         In January this year, Lord Rogers (Richard Rogers, the architect) stated in the House of Lords that there were enough brown-field sites available within the UK to build 1.2 million houses, right now. In light of this, surely any proposed housing developments should be preferentially considered on brown-field sites rather than prime agricultural land, particularly if there is no perceived benefit to the local community?

·         Also very limited attention has been paid by the developers to preservation of natural habitat with no plans on how to mitigate adverse impacts, let alone how to promote biodiversity.

General Points Applicable to Mount Pleasant and Fairfield Road
         ·            Contrary to Strategic Policy SP23, the proposed developments on Mount Pleasant and Fairfield Road do not demonstrate that they will support the Town “as a tourist destination”. Indeed, it may well detract from the Town’s “high quality historic character” and not “retain its role as a tourist centre”
         ·            With regards to Employment, there is little if any comment about how the proposed developments will benefit the Town. The proposed sites are to be used purely for residential purposes. It does not provide for employment. There is nothing in the proposed planning documents to suggest that local people will be employed in the construction of the development, nor its maintenance. In any case, what local employment opportunities might arise will be short-lived, ad-hoc and unsustainable. Local employment opportunities are limited and those opportunities that do exist are mostly insufficiently well-paid to fund a mortgage for the types of property proposed by the applicants.  Therefore most new residents of working age will have to commute. Contrary to Strategic Policy SP23, therefore, this proposal does not “increase the scale and range of the (sustainable) employment offer”.
         ·            With regards to Education, the County Council point to the fact that, the local primary school is likely to exceed capacity in the near future and that any additional increase in pupil numbers arising from new housing developments (estimate: 93 children) will most likely lead to pupils in Framlingham and the wider catchment area having to travel to other schools and quite possibly having to be schooled in temporary buildings. Quite how many years for is unclear but evidently, the proposed developments will severely impact educational infrastructure in the Town in a way that is unsustainable.  In addition, there appears to be no mention or consideration of the impact of increased pupil numbers on pre-school provision which is already severely limited.    
         ·            With regards to Health, the GP Surgery’s Practice Manager’s has previously commented “In summary, without additional funding to expand our site and range of services, any large housing development application approved in Framlingham will place a great strain on our existing infrastructure. This increase in demand will have a significant adverse impact on our ability to meet the needs of our patients and capacity to deliver a high standard of health services”. 
         ·            With regards to Transport, Framlingham is far from being a so-called transport hub; enhancements such as new bus stops, ignore the fact that most households drive to work, school, the supermarket (often out of Town) and so on. The development of new homes, where many households will have more than one car, will only add to increased traffic in the Town and surrounding villages.   
         ·            Overall, the adverse impact of these schemes on what is a quintessentially English historic market town is not outweighed by the socio-economic benefits.
Site Specific Comments (Fairfield Road)
         ·            With regards to Topography the Suffolk Preservation Society “... considers that the proposal for a large housing development on this site will impact on the setting of the conservation area and therefore, by failing to enhance or better reveal the significance of a conservation area or heritage asset, the application is contrary to para. 137 of the NPPF. It is also not in line with local plan policy SP23 which, in setting out its vision for Framlingham, aims to maintain the high quality historic character of the town and retain its sensitive setting and edges”.
Because of the nature of the site, and to mitigate the problems of flooding (see Drainage below), Taylor Wimpey have had to position the development further up the site which rises steeply from Fairfield Road (see the Senior Design and Conservation Officer's comments below). The net result of this development will change the views towards the numerous heritage 
assets of Framlingham, all of which read strongly on the skyline and will be lost forever.
         ·            The Senior Design and Conservation Officer’s own report states “It is unusual and still, for me, problematic, that the countryside edges to this site are fully built up to – where more open green space of the nature proposed at the front would have been welcome as a buffer or looser edge – and the key long edge to the site that abuts a road - which would have benefited from the creation of positive streetscene, enclosure and buildings addressing it - has an open green wedge behind it. This, perhaps, draws into question the suitability of the development of the density and nature proposed as the proposed layout relationship to the frontage and countryside edges are the reverse of what I would usually describe as good urban design. Such an inversion, incidentally, has increased the visual impact of the scheme with more development set back and, therefore, higher up”
         ·            Fairfield Road falls within the Conservation Area and forms part of the character areas within the Town that has developed and grown over a considerable period of time. SCDC’s own documents relating to the location and design of residential developments (SPG7) note that “While the area is small, the character is strong and diverse. A rural feel is apparent on Fairfield Road from the junction with Fore Street, and exists to the southern boundary. This character is established by the lack of pavement to most of the east side of the road...Street furniture is at a minimum on Fairfield Road, with the exception of lamp posts which, although beneficial features to the raised bank pavement, do detract from the rural character of the road”. The proposal to build 163 new homes along Fairfield Road will remove forever its “rural feel” and “rural character” and blight the conservation area and wider character of the Town.     
         ·            With regards to Drainage on Fairfield Road, the Case Officer writes that “The current flooding issue cannot therefore be attributed to the site and the consideration of this application should be limited to the demonstration that this proposal will result in “Nil Detriment” to that current position. Inevitably any flooding events on Fairfield Road would prohibit occupiers of the development gaining vehicular access via the southern end of Fairfield Road but this would be a temporary issue and it would not cut the development off from the highway network”. This is incorrect on a number of counts. Firstly, current flooding can be attributed to the site as excess rainwater does run-off the land (and not, as the Case Officer suggests from the River Ore overflowing). Secondly, the planning application does not demonstrate that this proposal will result in “Nil Detriment”. In any event, this is contrary to NPPF paragraph 100 which states ‘Local plans should use the opportunities offered by new development to reduce the causes and impacts of flooding. The development should and could reduce the causes and impacts of flooding in Fairfield Road but it doesn’t. It therefore does not meet NPPF requirement so should be refused.

 ·            With regards to Infrastructure, the route out of the Fairfield Road development will be either north towards Fore Street junction, or south towards the B1116, Woodbridge Road/Station Road junction. Both routes result in 'pinch points' which will potentially lead to problems of congestion and safety. This will be further exacerbated if Fairfield Road floods, making exit to the south impassable. The southern access has at its junction a narrow bridge and a sharp bend to Station Road. And if residents exit Framlingham using Brick Lane on it's southern boundary, they will encounter a narrow country lane with few passing places, a sharp bend and a difficult and dangerous junction with the B1116. With few employment opportunities in Framlingham, we can expect that most people will have to commute and therefore these potential problems will all too quickly become reality.
Site Specific Comments (Mount Pleasant)
         ·            Paragraph 1.20 of the Appeal papers presented on behalf of Persimmon Homes suggests that financial contributions to education, healthcare and community facilities will “mitigate” any impact ie of the Mount Pleasant housing development on the Town. The proposals do nothing to enhance the Town on a longer term, sustainable basis.   
         ·            With regard to Sustainability, the Suffolk Preservation Society notes that the affordable housing is spatially separated from the open-market housing and has a distinctly higher density. This is contrary to the design guidance on developing inclusive sustainable communities, and directly opposed to the policy SP1 (Sustainable Development).
        ·            With regard to the Location, as stated in the Council’s refusal of this Application the local plan policy SP23 (Framlingham) specifically requires that “developments retain the sensitive settings and edges of the town…  The site has intrinsic countryside qualities in its appearance and character which make a positive contribution to its surroundings: the development proposed would result a significant urban intrusion into this important landscape on the edge of this settlement.” This greenfield site should not be built on.
         ·           The Senior Design and Conservation Officer’s own report states “I would have preferred that the applicant (supported, ideally, by the landowner’s agent) had been much more responsive to our requests for proper consideration to be given to the ambitions of the NPPF; and had provided a raised standard of house design throughout the entire layout.”
        ·            With regard to Infrastructure, from the developers transport reports it can be seen that the junction of Mount Pleasant with College Road is one of the busiest in Framlingham.  This development will result in more traffic and significantly longer queues and delays.  The whole stretch of the road from this junction down to the junction with Fore Street will risk becoming grid-locked.

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