Item No: 1 Reference: B/15/00993/FUL Parish: SPROUGHTON ... · landscaping, sustainable urban drainage systems and highway improvements. Full planning consent for residential development

Planning Committee 10 February 2016 5

Item No: 1 Reference: B/15/00993/FUL

Parish:

SPROUGHTON

Ward Members: Cllrs Barry Gasper and Nick Ridley

Location:

Land to the north and south of, Poplar Lane

Proposal: Hybrid planning application in relation to: Outline planning consent (all matters

reserved) for 29.7ha of mixed use development, comprising: - the erection of up

to 475 dwellings (10.74ha); - 4ha of employment land, to include A3, A4, A5, D1,

D2 and Sui Generis use classes; - 1.2ha of land for primary education use; -

public open space, including childrens play areas; and, - associated

landscaping, sustainable urban drainage systems and highway improvements.

Full planning consent for residential development of 11.83ha of the outline

application site, comprising: - the erection of 145 dwellings; - public open space

and children's play areas (LEAP+); - green infrastructure, hard and soft

landscaping, and boundary treatments; - sustainable urban drainage systems

and pumping station; - highway improvements; and, - an electricity substation.

Applicant: Taylor Wimpey UK Ltd. and Building Partnerships Ltd.

Case Officer: Gemma Walker Date for Determination: 3 November 2015

RECOMMENDATION:Subject to a Section 106 Agreement, Grant Planning Permission

This application is referred to Development Committee as the proposal is of a scale that

requires consideration by Members

A Panel of Members inspected the site on 21 October 2015

THE SITE 1. The application site forms an area of land bounded by the A14, A1214 London Road and by

the A1071, although an area of the site projects northwards beyond the A1071 into a small valley. Poplar Lane, a no-through road runs through the site from the A1071 towards the A14.

2. Adjacent to the south-eastern corner of the site is The Holiday Inn Hotel, situated on the

junction between the A1214 London Road and A1071. Accessed from Poplar Lane are five residential properties, including the Grade II Listed Poplar Farm enclosed by the application site, and Thompson and Morgan, one of the UKs largest mail order seed and plant companies, situated to the west of the site. To the southern-western corner of the application site is another residential property, served by a separate access from London Road.

3. The wider surrounding area is varied in character, with the urban edge of Ipswich to the East

of the site, agricultural land and Chantry Park to the north in the intervening space between the site and the built up area of Ipswich. To the South the site adjoins the Interchange Retail Park adjacent to the A12/A14 junction. To the West is the A14 and subsequently open countryside.

4. The site forms the majority of the area identified in Policy CS7 Strategic Site Allocation for the

Babergh Ipswich Fringe.


THE PROPOSAL 5. This application is a hybrid application for part outline and part full planning permission.

6. The outline aspect of the proposal would extend to 29.7ha, comprising 10.74ha of land for

residential development, with up to 475 dwellings proposed, 1.2ha of land for a primary school, 4ha for employment development to include A3 (restaurants and cafes), A4 (drinking establishments), A5 (hot food takeaways), D1 (non-residential institutions including health centres, crèches, museums and libraries), D2 (assembly and leisure including cinemas, music, concert, bingo and dance halls) and sui generis uses, 2.2ha for public open space including children's play areas, landscaping and 5.39ha for green infrastructure, Sustainable Urban Drainage Systems (SuDS) and highway improvements.

7. The full part of the application extends to 11.83ha, comprising 145 dwelling houses, 1.14ha for

public open space including a children's play area, landscaping including 3.62ha of green infrastructure, SuDS, highway improvements and an electricity substation.

8. The residential land in the full application is an area of land on the eastern side of the

application site, between Poplar Lane and the A1071. This proposal would provide the following mix of dwellings:

Market Housing Affordable Housing

1 bedroom apartments 0 6 2 bedroom apartments 0 6 2 bedroom house 24 10 3 bedroom house 80 6 4 bedroom house 10 1 5 bedroom house 2 0 Total 116 29

9. The mix of dwellings for the remainder of the site would form part of reserved matters details.

10. The application documents can be viewed on line via the planning pages on the District Council's website.

RELEVANT HISTORY

11. B/86/01144/OUT - Outline application for residential, public park, shops, public house, medical centre, supermarket, exhibition centre, business park and construction of new roads and alteration to existing roads.

12. This application was refused as contrary to the County Structure Plan and proposed alterations to the County Structure Plan with regards to the scale and location of future large scale development and as the proposal would not maintain the open character of land which separates the villages around Ipswich from each other and from Ipswich itself. In addition, as the application would break through the strong existing visual edge to Ipswich into an area of attractive countryside, the environment of which would be unacceptably disturbed and as significant views into the area would be seriously and adversely affected. The loss of agricultural land, material increase in traffic using existing roads which do not have sufficient capacity and that the application did not demonstrate that the site can be satisfactorily drained to public sewerage were also reasons for refusal.

13. B/89/00263 - Outline application for erection of offices, petrol filing station, non-food retail outlets, garden centre, diner and residential development together with construction of all roads, access, car parking and service facilities.

14. This application was withdrawn.


NATIONAL PLANNING POLICY FRAMEWORK 15. The National Planning Policy Framework (NPPF) contains the Government's planning policies

for England and sets out how these are expected to be applied. Planning law and the NPPF continue to require that applications for planning permission be determined in accordance with the Development Plan, unless material considerations indicate otherwise. The policies contained within the NPPF are a material consideration and should be taken into account for decision-making purposes.

16. The NPPF is supported by the Planning Practice Guidance (PPG), which assists applicants

and decision makers to interpret the NPPF. Both the NPPF and PPG are referred to within this report where relevant to the assessment.

PLANNING POLICIES 17. The Development Plan comprises the Babergh Core Strategy 2014 and saved policies in the

Babergh Local Plan (Alteration No.2) adopted 2006. The following policies are applicable to the proposal:

Babergh Core Strategy 2014

CS1 Applying the Presumption in Favour of Sustainable Development

CS2 Settlement Pattern Policy

CS3 Strategy for Growth and Development

CS7 Strategic Site Allocation - Babergh Ipswich Fringe

CS12 Sustainable Design and Construction Standards

CS13 Renewable/Low Carbon Energy

CS14 Green Infrastructure

CS15 Implementing Sustainable Development

CS18 Mix and Type of Dwellings

CS19 Affordable Homes

CS21 Infrastructure Provision

Babergh Local Plan (Alteration No.2) 2006

EN22 Light Pollution

SP02 Retail Trip Generating Development

SP03 Retail Development Outside Town Centres

HS31 Public Open Space

HS34 Smaller Dwellings

CR04 Special Landscape Areas

CR07 Landscaping Schemes

CR08 Hedgerows

CN01 Design Standards

CN04 Design and Crime Prevention

TP01 Pedestrians

TP02 Public Right of Way

TP03 Provision of Cycle Routes

TP15 Parking Standards - New Development

TP16 Green Travel Plans

TP17 Transport Assessment


Supplementary Planning Documents

Ipswich Fringe Wolsey Grange Strategic Masterplan Document July 2015

18. Core Strategy Policy CS7 sets out the strategic site allocation and requires a Masterplan. The details set out in Policy CS7 informed the preparation of an initial Strategic Masterplan. The draft Masterplan underwent consultation, with a public consultation event in January 2015, a six-week consultation in May/June 2015 and a further public exhibition in June 2015. These consultations also included the site and neighbouring Parish Councils as well as Ipswich Borough Council.

19. The Masterplan was also presented to the Design Review Panel, 'Design: South East'. 20. The Masterplan was considered at Planning Committee on 22nd July 2015, with the

recommendation and subsequent resolution that "the content of the Strategic Master Plan Document, Babergh Ipswich Fringe be noted as an informal planning document that will be used with immediate effect to guide the consideration of future planning applications on the site."

Affordable Housing SPD (2014)

Suffolk County Parking Standards (2015)

21. The relevant policies can be viewed on line. Please see the notes attached to the schedule.

CONSULTATIONS

Sproughton Parish Council 22. Object for the following reasons:

On 13th October 1987 a public enquiry was held into the appeal by Wilcon Homes against the refusal of their planning application to develop Chantry Vale, which reasons are still valid:

Loss of agricultural land

Material increase of traffic on roads which do not have sufficient capacity

Break through strong existing visual edge into countryside.

23. In June 2009 BDC completed its final report of a Strategic Housing Land Availability Assessment. It ruled out development of a nearby site, SB280, on the other side of the A1071 on the grounds of access constraints. Infrastructure changes have not been substantial since then and the same constraints apply now.

24. Taylor Wimpey are proposing 475 houses. This goes against Policy CS7, which references

'approximately' 350 houses. 475 houses is a 35% increase on 350, by no means 'approximately 350 houses'. 475 houses is almost equivalent to another Sproughton.

25. Taylor Wimpey own land on the other side of the A1071 up to Chantry Park. It is entirely

possible that Taylor Wimpey will apply to build on that land in the future and the 1987 development plan for that area was 1400 houses. This again is against policy CS7.

26. High quality agricultural land being used, could the brown-field sugar beet site be used

instead? Although primarily designated as a commercial development site, 350 homes would only take up a fraction of the site with little impact on its primary allocation and significantly less impact on the environment.

27. The site is defined as Special Landscape Area. Development in this area is supposed to be

minimised at best, and sensitively designed if done at all.


28. A substantial area to the south or Poplar Lane is either undesignated or designated for commercial use with no plan that guarantees its development as such. This area is entirely sufficient to provide a residential development of 350 homes and would bring residents within walking distance of shops etc. and place the development below the skyline views from Chantry Vale and Chantry Park. The area north of Poplar Lane would then be available for any future commercial development using low aspect buildings to hide them below the skyline.

29. Three storey flats are proposed bordering the A1071, due to the height of the bank these

would appear 5 storeys high with a significant visual impact.

30. 35% of the development should be affordable housing, the first phase consists 20%, later phases would have to have more than 35%, is this financially viable?

31. There does not seem to be provision for older people, there are no bungalows.

32. Swapping the employment with the industrial area would help retain a natural boundary to the

development reducing the possibility of housing jumping to the other side of the A1071 and down to the A14/Church Lane area, thereby retaining the identity of Sproughton as a village.

33. The local style of historic buildings appears to have been ignored e.g. Poplar Farmhouse,

Springvale Cottages, Red House - the development would blend better if the style were taken into account.

34. The surveys appear to be primarily for the avoidance of liability within the site. Local

knowledge reveals the potential for insects, bats, plants and wildlife in and adjacent to this SLA not investigated or considered.

35. Insufficient information available to determine that the proposed development will not have an

adverse impact on designated sites or protected and or UK/Suffolk Priority Species.

36. Welcome mitigation recommendations but concerned surveys inadequate. Concerned that relevant issues including beetles, insects, mammals, flora, fauna etc. do not appear to have been researched. Ask that planning approval rejected until proper surveys are completed, considered and verified.

37. Chantry Vale is not just an SLA but this site is also listed as some of the best and most

versatile agricultural land in the area. Question the wisdom of destroying the best farmland in that area when the sugar beet factory could easily accommodate a mixed development.

38. The landscape survey does not recognise the present border of the SLA with urbanisation is

predominantly the wide buffer of duel carriageway London Road with wide grass central reservations, borders, hedgerows and trees. The Landscape report also appears to have overlooked the raised bank along the A1071. This is about 15 foot high at the points Taylor Wimpey proposed to put in three storey flats. They will be effectively as high as a 5 storey block plus their pitched roofs and therefore a dramatic corruption of the skyline from Chantry Vale.

39. From viewpoint 8 there is a negligible residential impact visually on the vale from urbanisation

and only limited impact from commercial/education premises. But this is considered adequate justification to breach the natural buffer of the London Road with residential development with a greater visual impact.

40. The development should be adequately screened by trees from the remaining SLA of Chantry

Vale. This is proposed but we feel completely inadequate for the scale and design of the proposed development.

41. Loss of special landscape area with creeping coalescence, creeping urbanisation and

progressive destruction of a beautiful valley.


42. Request more consideration is given to how they will conserve or enhance the special landscape adjacent to the site.

43. BDC make reference to Gipping Valley footpath, Chantry Park and Belstead Brook Park, with

no mention of the remaining Chantry Vale itself. Development in this area brings the urbanisation of Ipswich closer to Sproughton which we strongly object to.

44. This appears to be a blunt integration into the landscape to the visual benefit of the

development perhaps, but to the detriment of the adjacent landscape.

45. This farmland is a plateau at the top of rolling hills and a complicated valley. The site may be uninteresting but it impacts on landscape of significant visual value.

46. Disagree with Landscape Report as it relies on conclusions that appear to ignore the natural

border of the London Road and the raised land above the bank along the A1071 and three storey flats proposed for the northern edge of the development.

47. Main concern in respect of Arboricultural Survey is removal of several trees at the junction of

Poplar Lane and the A1071. If they are not to be replaced this would be a further corruption of the visual aspect of the skyline from within the SLA. Also concerned about screening along A1071.

48. Lack of information about site designation, and level of responses not due to lack of concern,

but due to lack of notification. Public response is only just developing and few people have had time to consider this application properly and may not have had time to refine their responses.

49. Taylor Wimpey claim that improvements will mitigate the increased volumes from Wolsey

Grange but have been unwilling to explain how they reached the conclusion. Our objections relating to traffic are:

Adverse impact on the amenity of Sproughton Village and level of service provided by the surrounding transport network.

Deficiencies in the assessment of transport impacts:

Exclusion of traffic generated from committed and future developments

Employment sensitivity tests - transport network performance not tested

Irrational claim that development impact is diminished by growth impact

Incredible performance predicted for the Wild Man junction

Route apportionment for trip distribution belies observations and under estimates impacts

Inadequacy of the transport infrastructure to support the proposed development.

50. Transport Assessment ignores cumulative impact in locations where other committed and planned future developments also have impact. For example, the permitted Great Blakenham Housing, Snoasis and Tomato Greenhouse developments also each require the Beagle and Wild Man junctions to accommodate additional traffic flows individually generated by each development. An assessment of the overall cumulative impact at a particular location can only be robust if the total impact from all developments affecting that location are taken into account.

51. The assessment only tests the employment sensitivity of one junction on the transport

network.

52. The results of operational assessments show that 11 of the 13 junctions have insufficient space capacity to accommodate predicated traffic flows generated by the development. That is without taking sensitivity to employment traffic generated by the planned development into account.


53. Given widespread lack of spare capacity in the network surrounding the proposed development it is essential that all affected junctions are tested for employment sensitivity.

54. The Transport Assessment concludes that the impact of the development traffic will be

insignificant, this is dependent upon a value judgement that if the impact of the development traffic is less than half the impact of predicted growth, the impact of the development will be insignificant.

55. The statements made imply that because growth in traffic is high, the impact from

development traffic is less severe. Both growth traffic and development traffic add to the impact, which is cumulative.

56. Query over errors in measurement of traffic at Wild Man junction.

57. By assuming that the route through Sproughton village only takes a fraction of the traffic to

and from the north-west, the assessment underestimates the impact upon this part of the network.

58. The transport assessment shows that the transport network would not provide a reasonable

level of service, even with the proposed transport schemes in place.

59. Can surgeries cope with the additional demand? Pinewood has fewer GPs than it should and 50% more patients per GP than NHS recommendations.

60. Concern that the school is unlikely to be built as it would be too small to be viable.

Sproughton Primary School is already at capacity.

61. Ultimately Sproughton could be absorbed into Ipswich as the green space is gradually built on.

62. Other developments are either underway or planned which will all increase the loading on existing infrastructure. Although additional facilities can be provided and traffic mitigation measures undertaken, there is no guarantee that these will work and little confidence that they will be provided. If this development goes ahead developers should pay for additional traffic mitigation measures if their traffic model proves to be incorrect.

Pinewood Parish Council

63. Approves in principle the need for building development, the Council remains unconvinced

that the measures suggested by the developers will alleviate the traffic problems caused by the proposed development.

64. The proposal is one of a number of projects being considered for this area now and in the

future which could lead to an even greater increase in the number of houses being built. A review of the infrastructure needs of this area should be undertaken by the highway authorities before this planning application is progressed. We believe it places an unacceptably high burden on the local traffic infrastructure even when suggested road improvements are taken into consideration.

65. The roads in our locality are already suffering from congestion and overload and we question

the over-riding conclusion of the developer that traffic effect will be minimal.

66. Our Council has little confidence in the sustainability of the Travel Plan for this development.

67. Pinewood Parish Council believes it must object to the proposal in its present form.


Hintlesham and Chattisham Parish Council 68. The current proposal places an unacceptable burden on the local transport infrastructure,

even when proposed road improvements are taken into consideration. In short, the scale of this development will have a severe impact on the local area and should be opposed in its present form.

69. The applicant's Transport Assessment summarises criteria for acceptability:

3.4.3 Development proposals are likely to be acceptable if they can be accommodated within the current existing capacity of a section (link or junction) of the strategic road network, or they do not increase demand for use of a section that is already operating at over-capacity levels, taking into account of any travel plan, traffic management and/or capacity enhancement measures that may be agreed. However, development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.

70. The Assessment then bases conclusions about the impact on the assumptions found in standard planning software and recent surveys. The quality of this analysis is undermined by apparent abnormalities. For example, in Section 7 .. Combined Trip Generation the Multi-Modal Traffic Generation graph for the development includes trips on "surface rail or London Underground" and other public transport such as air and ferries [7.4.1].

71. Bold assumptions about the anticipated uptake of cycling and other 'sustainable' forms of

transport are made throughout - e.g. 4.6.8 - and it is concluded traffic congestion will encourage people to use such methods - [10.15.5].

72. This is a significant flaw in the assessment. The assumptions on walking and cycling are not

based on relevant local evidence and will not overcome shortfalls in the wider provision of infrastructure.

73. The report accepts that the traffic plan will simply transfer congestion to the nearest pinch

points, including the key A1214/A1071 (Sainsbury's) junction:

74. [10.5.4] "The above assessments demonstrate that both Junctions 11 and 12 are working above capacity in the Do Minimum Scenario, exacerbated in the Do Something Scenario. As noted above, both junctions will operate over capacity in 2025, where the development impact remains a relatively small proportion of the overall queues and delays at the junctions."

75. If the traffic problem is already 'severe' (above capacity) it cannot be acceptable to exacerbate

it. As stated in the application, the test is that:

"they do not increase demand for use of a section that is already operating at or over capacity levels"

76. The report's conclusions thus highlight the fact that the application fails this test.

77. Assumptions made about the alterations to the Copdock Interchange [4.8.20 and 10.9.4] are

complacent and not in accord with local experience. These concerns are shared by Suffolk Constabulary. The report includes a cumulative impact assessment in section 8 (page 61). This takes account of the proposed Belstead House development but not the expectation of major development at the former sugar beet factory, which will also impact on the Copdock Interchange as well as on secondary routes adopted at peak times. In this regard Sproughton is likely to experience an increase in traffic from the A1071 and from the opposite Ipswich End along a residential road that is already inadequate and frequently congested.

78. Likewise conclusions made in 9.2.5 - 9.2.10 concerning the ways residents would access key

routes ignores the reality of people doubling back through Sproughton to reach the A14 and the stress point at the Wild Man, among others.


79. Increased traffic volumes will likewise aggravate access problems onto the A1071 for private and public roads alike and congestion in Hintlesham. The dangers present on the A1071 from Hintlesham to the London Road are well known, although the number of accidents has been under-reported. Suffolk County Council Highways Dept. accepted the difficulties faced by residents of Valley Farm Drive and Hintlesham Fisheries last year, resulting in extra signage and hedge cutting. This has brought some benefits but serious problems remain and any increase in traffic will cause severe difficulty for residents.

80. Finally: at a strategic planning level there is considerable concern over the use of

commercially productive farmland to extend the Ipswich Fringe, especially when there is a larger (130 acres) brown-field site, with better access that could be used to meet the area's stated housing needs.

Ipswich Borough Council

81. The application site forms part of the wider strategic development area including the former

Sugar Beet factory and Chantry Park. A strategic approach is required to be taken as to how this wider area will be planned and developed. Application site should form part of and contribute to a wider strategic masterplan.

82. Proposed design and specifically the frontage of the development to the A1071 fails to achieve

a level of design quality and architectural response for this important urban edge site. Proposal relies too much on planting as a visual screen and proposes very standardised housing with little or no relationship to a recognisable Suffolk vernacular.

83. Cycle and pedestrian routes lack consideration for connections beyond the site boundary and

fail to include route enhancements to the town centre, Chantry Park, Ipswich Railway Station and former Sugar Beet factory.

84. Provision of an effective bus service and measures to maximise use by occupiers should be

secured and in place for the first phase of development.

85. Signalised traffic junction to A1214 questioned, consideration should be given to whether this new junction is justified on this important route into Ipswich and whether more appropriate alternatives should be pursued.

86. Effectiveness of ecological network has not been maximised. Strong and meaningful

connections for wildlife through and around the proposal should be included. The masterplan should be based on the ecological network with strong connections to Chantry Park, the former Sugar Beet factory, the river, A14 and the wider countryside.

87. SWT raised concerns relating to insufficient information to determine impact on designated

sites or protected and/or UK/Suffolk Priority Species. Concerns are shared by IBC and should be addressed.

88. Site is in proximity of Chantry Park and will benefit future residents. However no consideration

appears to have been given as to the additional pressure. IBC considers this to require mitigation and measures/contributions should be secured.

89. Proposals lack certainty as to the impact on the Orwell and Stour European SPA sites and

how mitigation will be secured or contributed to.

Belstead Parish Council 90. Belstead Parish Council objects to this planning application. This proposal is one of a number

being considered in this area which could amount to an increase in dwellings of possibly 2,000. None of these should be granted planning permission until a full review of the infrastructure needs for the future of this augmented area is undertaken and developer obligations under section 106 can be decided. There is a clear requirement for extra school places, new medical facilities and above all consideration of the highway infrastructure change


needed. The effect on an already problematic area involving the nationally important A12/A14 and all local approach roads to Ipswich without a major survey encompassing the probable future of this area when fully developed would be disastrous.

91. All minor roads through surrounding communities are presently overwhelmed at peak times

when the A12 and A14 cannot cope with traffic volumes at the Copdock interchange. This is likely to become a nightmare gridlock unless a major alteration can be achieved.

Burstall Parish Council

92. The number of houses planned has risen and the Local Plan/Core Strategy does not identify

the need for this number of houses in the area. Increased housing means less land for communal areas.

93. The possibility of pupils from Wolsey Grange taken into Sproughton Primary School will risk

Burstall children being displaced. Therefore building the school must be part of Phase 1 of the development and if consent is granted the construction of this school prior to housing construction should be made a condition.

94. There will have to be a pedestrian crossing over the A1071 to provide access to Sproughton.

There are no footpaths or cycle paths planned. A road crossing will further delay traffic using the A1071.

95. Traffic increase will be such that the A1071 will be more heavily congested. A robust and

extensive traffic survey is required taking into account all proposed local developments in order to produce a new road strategy to cater for these before any further planning permissions are granted.

96. Loss of high value grade 2 agricultural land.

97. The new development will put great strain on the local GP and Dental services.

Environment Agency

98. Proposal falls outside the Development Management Procedure Order 2015 and therefore we

have no objection and no comments to make.

Historic England 99. The application should be determined in accordance with national and local policy guidance,

and on the basis of your specialist conservation advice.

Anglian Water 100. The foul drainage from this development is in the catchment of Chantry Water Recycling

Centre that will have available capacity for these flows. 101. Development will lead to a risk of flooding downstream. A drainage strategy will need to be

prepared in consultation with Anglian Water to determine mitigation measures. We request a condition requiring the drainage strategy and covering the issues to be agreed.

102. From the details submitted the proposed surface water management does not relate to

Anglian Water operated assets.

Natural England 103. The application site is within or in close proximity to a European designated site (also

commonly referred to as Natura 2000 sites), and therefore has the potential to affect its interest features. European sites are afforded protection under the Conservation of Habitats and Species Regulations 2010, as amended (the ‘Habitats Regulations’). The application site


is in close proximity to the Stour and Orwell Estuaries Special Protection Area (SPA) and Ramsar site which are European sites and also notified at a national level as the Orwell Estuary Site of Special Scientific Interest (SSSI). The notification features of the SSSI broadly relate to the features associated with the internationally designated sites and so the following comments are applicable in both an international and national context.

104. In considering the European site interest, Natural England advises that you, as a competent

authority under the provisions of the Habitats Regulations, should have regard for any potential impacts that a plan or project may have. The Conservation objectives for each European site explain how the site should be restored and/or maintained and may be helpful in assessing what, if any, potential impacts a plan or project may have.

105. The consultation documents provided by your authority do not include information to

demonstrate that the requirements of Regulations 61 and 62 of the Habitats Regulations have been considered by your authority, i.e. the consultation does not include a Habitats Regulations Assessment (HRA).

106. In advising your authority on the requirements relating to HRA, it is Natural England’s advice

that the proposal is not necessary for the management of the European site. Your authority should therefore determine whether the proposal is likely to have a significant effect on any European site, proceeding to the Appropriate Assessment (AA) stage where significant effects cannot be ruled out.

107. The Babergh Core Strategy (2014) acknowledges the potential for increased recreational

pressures on internationally designated sites through rises in visitor numbers associated with population growth in the district and the need to implement appropriate measures to avoid degradation to these sites (paragraph 3.3.2.2, pg. 63).

108. Taking into account the distance of the proposed development site from the Stour and Orwell

Estuaries SPA, Natural England advises that potential impacts to this site as a result of the development alone can be ruled out. We note that on-site green infrastructure (GI) has been provided by the applicant which appears to be in accordance with the policies of the Core Strategy (i.e. >10 %) and which provides good links to nearby greenspace such as Chantry Park. In line with Policy HS32 of the Babergh Local Plan (Alteration No 2) Saved Policies (2006), we advise that the management and maintenance of this GI should be appropriately secured to ensure its long-term sustainability.

109. Whilst the provision of high quality on-site GI within individual developments will, to some

extent, minimise the increase in visits made to internationally designated sites through absorbing day-to-day activities such as routine dog walking, it should not be used alone as mitigation for in-combination impacts. The Habitats Regulations Assessment of the Babergh Core Strategy (2011) ruled out in-combination recreational disturbance impacts from the Plan as a result of an increased district population on the basis that your authority is contributing to a wider mitigation strategy

110. Other Advice - We would expect the Local Planning Authority (LPA) to assess and consider

the other possible impacts resulting from this proposal on the following when determining this application:

local sites (biodiversity and geodiversity)

local landscape character

local or national biodiversity priority habitats and species.

111. Protected Species - We have not assessed this application and associated documents for impacts on protected species.

112. Natural England has published Standing Advice on protected species. The Standing Advice

includes a habitat decision tree which provides advice to planners on deciding if there is a ‘reasonable likelihood’ of protected species being present. It also provides detailed advice on the protected species most often affected by development, including flow charts for individual species to enable an assessment to be made of a protected species survey and mitigation strategy.


113. You should apply our Standing Advice to this application as it is a material consideration in the

determination of applications in the same way as any individual response received from Natural England following consultation.

114. Soil and Land Quality - Based on the information provided with the planning application, it

appears that the proposed development comprises more than 20 ha classified as ‘best and most versatile’ (Grades 1, 2 and 3a land in the Agricultural Land Classification (ALC) system).

115. Government policy is set out in Paragraph 112 of the National Planning Policy Framework

which states that:

116. ‘Local planning authorities 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 a higher quality.’

117. It is recognised that a proportion of the agricultural land affected by the development will

remain undeveloped (e.g. public open space etc.). In order to retain the long term potential of this land and to safeguard soil resources as part of the overall sustainability of the whole development, it is important that the soil is able to retain as many of its many important functions and services (ecosystem services) as possible through careful soil management.

118. Consequently, we advise that if the development proceeds, the developer uses an

appropriately experienced soil specialist to advise on, and supervise, soil handling, including identifying when soils are dry enough to be handled and how to make the best use of the different soils on site. Detailed guidance is available in Defra Construction Code of Practice for the Sustainable Use of Soils on Construction Sites (including accompanying Toolbox Talks) and we recommend that this is followed.

119. Biodiversity Enhancements - This application may provide opportunities to incorporate

features into the design which are beneficial to wildlife, such as the incorporation of roosting opportunities for bats or the installation of bird nest boxes. The authority should consider securing measures to enhance the biodiversity of the site from the applicant, if it is minded to grant permission for this application. This is in accordance with Paragraph 118 of the NPPF. Additionally, we would draw your attention to Section 40 of the Natural Environment and Rural Communities Act (2006) which states that ‘Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity’. Section 40(3) of the same Act also states that ‘conserving biodiversity includes, in relation to a living organism or type of habitat, restoring or enhancing a population or habitat’.

Additional Reply Received following HRA submission

120. The HRA screening report concludes that, provided the mitigation proposals described are

implemented in their entirety, this project will not adversely affect the integrity of the Stour and Orwell Estuaries Special Protection Area (SPA). On the basis of the information provided, Natural England concurs with this view.


121. NOTE: Mitigation contributions on basis of HRA confirmed by Suffolk County Ecology as follows:

£450 towards maintenance of Stour and Orwell Forum Database for new residents to

receive information about the SPA from Suffolk Coasts and Heaths AONB and partners.

£5,000 towards the production of SPA information packs for 475 new households £800 towards the provision of SPA footpath way marker discs to be installed on the

footpaths in the vicinity of the car parks to access the SPA. £1,500 for one SPA information board to be installed on the site, near to the footpath to

Chantry Park £7,500 for monitoring of visitor disturbance of birds on the Stour and Orwell Estuaries

SPA. Total £15,250

Suffolk Wildlife Trust

122. Reptiles - The reptile survey recorded a small number of grass snakes in the area of semi-

improved grassland which is the proposed location for part of the SUDS infrastructure. Reptiles are protected from killing and injury under the Wildlife and Countryside Act (1981) (as amended) and as such are a material consideration. A mitigation plan for reptiles is therefore required, in accordance with recommendations’ contained within the reptile survey report. The production and implementation of such a plan should be secured by a suitable planning condition, should permission be granted.

123. Bats - Whilst the application includes a survey of trees with bat roost potential, it does not

include any bat activity surveys. The Ecological Opportunities and Constraints Report states that habitat on site suitable for bat commuting and foraging will be retained and incorporated into the proposed development. However, the indicative masterplan shows a number of hedgerows being broken by access routes. Suggest that further information is required to demonstrate that there will be no adverse impact on bat species as a result of the proposed development.

124. Breeding Birds - Breeding bird surveys at the site have identified that it supports a suite of

species, including four on the Birds of Conservation Concern (BoCC) Red list and four on the BoCC Amber list. Five UK/Suffolk Priority Species were also recorded breeding on the site. The survey report concludes that "a total of 227 birds of 25 species were detected on the 29.7 ha survey site, giving a density of 76.4 birds per 10 ha. The findings at Wolsey Grange tend towards the higher end of population densities in comparison with other farmland areas". The proposed development would result in a loss of habitat suitable for nesting birds, particularly a ground nesting species, along with other impacts resulting from the change of land use.

125. Measures identified go some way towards mitigating the impacts of the proposed development

but we do not consider that they are sufficient to ensure that there will be no net loss of breeding birds from the site. To help mitigate impacts on skylarks next plots could be provided on nearby arable land such as that already under the applicants control to the north of the proposed development site. Also query how the feeding stations proposed in section 5.1 of the report would be implemented?

126. Ecological Enhancements - In accordance with the NPPF the proposed development should

provide net gains in biodiversity. In addition to the measures recommended in the ecological survey reports we recommend following measures, if permission granted:

Hedgehog friendly boundaries

Long term management of existing, retained habitats and newly created spaces and

green infrastructure to maximise value for biodiversity


Habitat Regulations Assessment (HRA)

127. The site is within 4km of the Stour and Orwell Estuaries Special Protection Area (SPA) and the Stour and Orwell Estuaries Ramsar site. These sites are designated for their European nature conservation importance. The proposed development has the potential to result in significant effect on these sites, either alone or in-combination with other developments. We therefore recommend that the application is subject to HRA by the Local Planning Authority under the Conservation of Habitats and Species Regulations (2010) (as amended) in order to assess the likely impacts on these sites and determine whether any additional mitigation measures are required.

Additional Comments Received (following the submission of additional surveys)

128. Surveys of bat activity were undertaken in September 2015 and focussed on the sections of

hedgerows around the site directly affected by the proposed development. Whilst the surveys provide evidence on the use of these features during the autumn season they do not provide information on usage through the spring and summer or across the site.

129. Notwithstanding this limitation, activity from six species was recorded along the hedgerows,

including activity on hedgerows 3,4 and 5, parts of which are proposed to be removed. The plans do not show any measures to compensate for the disruption of commuting and foraging routes.

130. Stag beetles have been recorded in close proximity to the site, the removal of hedgerows

could have an adverse impact on this species, however mitigation can be secured by a suitably worded planning condition, should permission be granted.

NHS England

131. The proposed development is likely to have an impact on the services of 1 GP practice and 1

branch surgery operating in the vicinity of the application site. These practices do not have capacity for the additional growth resulting from this development.

132. A developer contribution will be required to mitigate the impacts of this proposal. NHS

England calculates the level of contribution required to be £149,880.

133. NHS England therefore requests that this sum be secured through a planning obligation linked to any grant of planning permission, in the form of a Section 106 Agreement.

Highways England

134. A holding response to allow time to assess the proposal was received from Highways England

on 3rd September 2015 and on 9th November 2015 the holding response was lifted and a formal recommendation of no objection received.

SCC Highways

135. The Transport Assessment that has been submitted with this application has been thoroughly

reviewed by SCC Consultants AECOM over an extended period of time. During this time a number of issues have been raised, discussed in detail and either resolved by the provision of further explanation of information to clarify assumptions or uncertainties within the original Transport Assessment. In summary, the Transport Assessment review key considerations have been to: review and agree trip generation and distribution including flow diagrams, check junction capacity issues and review predicted capacity based on future growth and relevant committed developments; check the impact of the site on the wider highway network, (considering 13 junctions in total); and check and verify that the proposed mitigation addresses the detrimental impacts identified

136. At this stage it has not been possible to agree the some of the base traffic models and

validation provided in the Transport Assessment. AECOM have focused on the ‘future base’ and ‘future growth with WG’ modelling in order to compare what the network will be like with and without the WG flows (plus mitigation) in the network.


137. There is concern that the highway network surrounding this site is already under pressure during peak hour traffic flows and this only looks to be increased in the future given the committed developments and background growth that is likely to occur in this area. The package of highway works proposed for this development has, in the main part, been able to mitigate the adverse effects of the Wolsey Grange development to an acceptable level. Although there are some junctions where the mitigation provides an overall positive effect on capacity, there are some junctions where the Highway Authority maintains concern where the Transport Assessment predicts capacity & delay problems and where either no mitigation has been proposed (Site 11, 12 & 13), or a predicted negative effect had been identified but not mitigated (Site 5). But the Highway Authority accepts that, although the WG development increases the problems at these locations it is not the primary cause of capacity issues as some are existing issues.

138. In consideration of the likely impact of this development it is the Highway Authority’s view that

the traffic forecasting provided within the TA is somewhat ‘over-robust’ as it makes no deductions for the following positive effects that are reasonable to account for given the location of this site and the local facilities available:

Pass-by trips (e.g. to visit the leisure uses on route home from work);

Shared trips (e.g. to visit Tesco and the proposed leisure uses as part of the same overall trip);

Mode shift due to enhanced public transport, walking & cycling facilities or the Travel Plan.

Internalisation where residents work on or close to the site and therefore don’t travel by car.

139. In addition, the growth factors applied to the base flows do not appear to take account of the

‘alternative assumptions’ facility within TEMPRO, which avoids double counting growth associated with committed developments that are being modelled explicitly: the growth factors were therefore considered robust. It can therefore reasonably be said that the main forecasts are somewhat over-robust because they have not taken account of a number of features which, together, would have reduced the effect of both background growth and traffic generated by this site.

140. The Wolsey Grange site is well located to take advantage of good sustainable transport

options and there are already good cycling facilities which link the site. The site is close to several large shopping outlets, a higher education centre and there is also a large supermarket within walking distance to the site. A new ‘discount supermarket’ has recently obtained planning approval to be located on Scrivener Drive. The applicant has worked with the Highway Authority and Ipswich Buses to agree an extension to a high frequency bus service to connect the site from an early point during the development programme. All of this supports the theory that, although there are some junctions where future ‘theoretical’ capacity assessment has been predicted to be exceeded; it is more likely that this will not occur or be directly caused by the effects of the Wolsey Grange development.

Summary:

141. The Highway Authority’s position at this point in view of determining this application is that we

are satisfied that the impact on the local highway network will be acceptable and consequently we would not recommend that this application is refused on highway grounds, subject to agreement of a satisfactory package of highways mitigation to be agreed in due course and implemented at appropriate timescales. Although some of the details for the highways mitigation are still to be resolved, it is felt that a satisfactory package of mitigation can be agreed and any potential changes to what has already been proposed can be dealt with by way of planning condition or legal agreement.


142. Section 106 Contributions:

£250,000 contingency for unmitigated affects

£20,000 for two shelters on Poplar Lane and an RTPI screen at the collection stop

£15,000 for additional shelter and RTPI screen within the development

£33,916 Public Rights of Way

£250,000 bond for bus calculated at £50,000 per year, and reduced by £50,000 per year

£1,000 per annum Travel Plan support until 5 years post completion

£818,606 Travel Plan Bond

Implementation of Travel Plan

Implementation of Travel Plan Group

Welcome pack

2 x car club vehicles

Electric vehicle charging infrastructure

Smarter Choices scheme to provide for residents and workplaces close to the development

Section 278 and Section 38 Agreements

Conditions:

School Travel Plan

Individual commercial units to comply with site wide travel plan

Agree a scheme for extension of bus service which is to be provided prior to the occupation of the 100th dwelling and maintained for 5 years.

143. Due to the need to amend junctions a condition notwithstanding the details submitted prior to

the commencement of works to each junction details shall be agreed

144. Bus turning details to be agreed, including metalled surface, 12m space to turn in forward gear, lighting and measures to prevent other vehicles using the space

County Archaeologist

145. The site lies in an area of archaeological potential as recorded by information held by the

County Historic Environment Record. The site has been subject to geophysical survey and archaeological evaluation.

146. There is documentary evidence for the 'lost' mediaeval chapel and hamlet of Felchurch is

possibly on or close to the site. The evaluation carried out to date has not identified the site of a chapel or burials, but has identified archaeological remains relating to medieval occupation. It is possible that the chapel site is outside the development area.

147. The proposed works would cause significance ground disturbance and has the potential to

damage any archaeological deposits and below ground heritage assets that exist.

148. Given the reasonable efforts made to identify the chapel site, and the lack of positive evidence that exists, it is my advice that there are no grounds to consider refusal of permission in order to achieve preservation in situ of any important heritage assets. However, there are archaeological remains on site and in accordance with the NPPF any permission granted should be the subject to a planning condition to record and advance understanding of the significance of any heritage asset before it is damaged or destroyed.


Suffolk County Council Section 106 149. Education - We currently forecast to have sufficient surplus places available at the secondary

school level and therefore do not require developer contributions for secondary age pupils arising.

150. The agreed strategy (CS7 and Masterplan) at primary school level is for an on-site land

reservation and contributions towards build costs. As such a contribution of £2,493,333 is required.

151. Depending on the timing of the delivery of this scheme, a mechanism ought to be included to

allow SCC to build the primary school in an alternative location.

152. Pre-School - The agreed strategy is for the on-site early years setting to be integrated with the primary school. The early years contributions required is £276,924

153. Play Space Provision - Issues to consider include:

In every residential area there are a variety of supervised and unsupervised places for

play, free of charge.

Play spaces are attractive, welcoming, engaging and accessible for all local children and young people, including disabled children, and children from minority groups in the community.

Local neighbourhoods are, and feel like, safe, interesting places to play.

Routes to children’s play spaces are safe and accessible for all children and young people.

154. Libraries - Capital contribution towards libraries arising from this scheme is £102,600

155. Waste - A waste minimisation and recycling strategy needs to be agreed and implemented by

planning conditions. Refer to the Waste Planning Policy Statement, the Suffolk Waste Plan and the Joint Municipal Waste Management Strategy in Suffolk.

156. We would request that waste bins and garden composting bins will be provided before

occupation of each dwelling and this will be secured by way of a planning condition. We would also encourage the installation of water butts connected to gutter down-pipes to harvest rainwater for use by occupants in their gardens.

157. Supported Housing - In line with Sections 6 and 8 of the NPPF, homes should be designed to

meet the health needs of a changing demographic population. Following the replacement of the Lifetime Homes standard, designing homes to the new ‘Category M4(2)’ standard offers a useful way of fulfilling this objective, with a proportion of dwellings being built to ‘Category M4(3)’ standard.

Additional Comments Received

158. Policy CS7 and the adopted Masterplan provides for a primary school site reservation of 1.2

ha, which will allow for future expansion of the school beyond 105 places. However as this school site reservation is slightly larger than that which is required to directly mitigate the impact from this scheme a land value credit for the 'extra' school land needs to be made to the applicant.

159. A land value credit of 0.5ha is required to comply with Regulation 122(2) of the Community

Infrastructure Levy Regulations 2010. The capital contribution of £2,493,333 for the school build costs is therefore reduced by £124,000, to £2,369,333.

160. The County Council will be able to serve six months written notice at any time after the

construction of the 150th dwelling has commenced, which will trigger the transfer of the site to SCC. The option notice period will run from the 150th dwelling construction for a period expiring 5 years after the occupation of the last dwelling.


161. Planning Obligation Trigger Points:

Early Years: £276,924 payable in 5 equal stages prior to 100, 175th, 250th and 400th dwelling occupations

Education: £2,369,333 payable in 5 equal stages prior to 100, 175th, 250th and 400th dwelling occupations

Library Contribution: £102,600 payable in 5 equal stages prior to 100, 175th, 250th and 400th dwelling occupations

SCC Rights of Way Officer

162. Public Footpath 16 is recorded through the proposed development area; Public Footpaths 13

and 14 are adjacent.

163. We would recommend the legal diversion of a section of Public Footpath 16 where it currently dogleg's, onto the proposed footway, otherwise we request that the legal alignment of Footpath 16 is indicated on the masterplan to ensure the route is not affected by future plans.

164. No objection in principle. As a result of anticipated increase in use of public rights of way we

would be seeking a contribution towards improvements, which will be submitted with Highways Development Management response.

Police Architectural Liaison Officer - Suffolk Constabulary

165. Consultation provided to Traffic Management, Partnership and Local Policing:

166. Traffic Management Officer - No objection to the application but worth bearing in mind the number of vehicles that will use this area.

167. Vehicle traffic will be affected much further afield and I am particularly concerned about the

Copdock Mill roundabout which can be very busy in all directions.

168. We have no objections but the scale of the development will undoubtedly affect road users further from the proposed development than just the junctions in the immediate area.

Suffolk Fire and Rescue

169. Access to buildings for fire appliances and firefighters must meet with the requirements

specified in Building Regulations Approved Document B (Fire Safety).

170. Suffolk Fire and Rescue Service also requires a minimum carrying capacity for hard standing for pumping/high reach vehicles of 15/26 tonnes, but 12.5 tonnes as details in the Building Regulations Approved Document.

171. Suffolk Fire and Rescue Authority recommend that fire hydrants will be installed within this

development. However, it is not possible at this time, to determine the number required for firefighting. The requirement will be determined at the water planning stage when site plans have been submitted by water companies.

172. If the planning authority is minded to grant approval, the Fire Authority will request that

adequate provision is made for fire hydrants by the imposition of a suitable planning condition at the planning application stage.

Suffolk County Council - Flood and Water

173. SCC is reasonably satisfied that the outline site can be drained without worsening flooding off

the site in accordance with the NPPF paragraph 103 and DEFRAs non-technical standards. However, before the detailed phase 1 can be developed the SW strategy and FRA needs to be revised and agreed.


174. Suffolk County Council Flood and Water Team would suggest a revised FRA and Surface Water Drainage Strategy is sought by means of planning conditions.

Policy

175. With regard to policies CS2 and CS3, the development is located within the Babergh Ipswich

Fringe which is an edge of urban area and an appropriate location for strategic housing and employment development.

176. Policy CS7 is the key policy which allocates the land for development of approximately 350

homes and approximately 6ha of employment uses. The policy also requires the production of a Masterplan to support the proposed development, which has been produced and addresses the key requirements of policy CS7 criteria.

177. The proposed development is for the erection of 475 dwellings which is significantly above the

quantum (approximately 350) set out in policy CS7, and 6ha of employment land. Consequently, the impacts of the overall proposed development will need to be fully tested within the planning application process.

178. The application material submitted addresses the majority of the sustainability criteria

identified in Policy CS15. However, the local planning authority needs to be satisfied that an appropriate level of infrastructure is provided with the scheme and that the relevant requirements of the Conservation of Habitats and Species Regulations 2010, as amended (the ‘Habitats Regulations’) are met.

179. In accordance with Policy CS18, the phase 1 full application provides a mix of dwelling types

and tenures consistent with the proportionately higher need for smaller house types set out in local housing need evidence.

180. The affordable housing contribution for the phase 1 full application falls short of the Policy

CS19 requirement for 35% on-site affordable housing. However, it is yet unknown what the overall on-site contribution to affordable housing will be. Documentary evidence should be provided by the applicant to demonstrate to the Council the scheme viability issues in meeting the policy requirement contribution or alternatively inform why such requirements cannot be met.

181. Policy CS21 requires new development to make appropriate contributions to infrastructure in

order to ensure that development is sustainable and any adverse impact is mitigated against. The area has known infrastructure constraints at present and Policy CS7 has set out a number of specific infrastructure improvements and enhancements which development in this area would be expected to make, notably highways improvements and school provision. However, as the proposed scheme now exceeds the level of growth anticipated in Policy CS7 of the Core Strategy, then the adequacy of infrastructure provision will need to be assessed by service providers on the higher number.

182. In conclusion, the planning policy team is supportive of the principle of the scheme which is

proposed on an allocated strategic site in the Babergh Core Strategy. The development would make a substantial contribution to the identified future housing needs of the District, in a sustainable location within good proximity to existing services, facilities and employment centres which can be enhanced. The key issue is the departure from the development plan with residential development numbers significantly exceeding those set out in Policy CS7. Therefore, the decision maker will need to be satisfied that adequate infrastructure improvements can be made in the locality to satisfactorily mitigation the impact of the development scale. Subject to demonstrating mitigation is satisfactory, the application is supported in principle.


Heritage and Design 183. The proposal would not cause harm or loss of significance to the setting of Poplar Farm, a

designated heritage asset.

184. The proposal accords with the broad design parameters provided by the Strategic Master Plan document that has been prepared to guide the considerations of planning applications submitted for the development of the site.

185. The application site adjoins the curtilage of Poplar Farm, a Grade II Listed Building, which is

within a large curtilage and viewed against a woodland backdrop to the East.

186. The first phase of the development would not impinge upon the immediate setting of Poplar Farm. The property would continue to be experienced as one of a group of dwellings on the northern side of Poplar Lane. No harm or loss of significance to the setting of Poplar Farm within the meaning provided by the NPPF would therefore occur.

187. The planning application also seeks to establish the principle of development the land on the

southern side of Poplar Lane, the Strategic Master Plan makes provision for a specific design response to respect the existing rural character of the land at this point. The intended mitigation arrangements therefore seek to safeguard the setting and significance of Poplar Lane as a designated heritage asset.

188. As originally submitted pedestrians may have been tempted to make use of a private drive

which could have given rise to future difficulties, but the layout plan has subsequently been amended to address this point.

189. In conclusion the detailed aspect proposal would not cause harm or loss of significance to

Poplar Farm and subject to adherence to the intended design response for the development of the land on the southern side of Poplar Lane, the principle of developing the wider area would not conflict with the provisions of the NPPF in relation to designated heritage assets.

Economic Development

190. No objection

191. The site was identified in policy CS7 Strategic Site Allocation as part of the provision of 6ha of

employment land. This application identifies 4ha of that 6ha requirement and the types of employment related uses that could take place there.

192. The Indicative Strategic Masterplan shows access through the employment site to Thompson

and Morgan and the future development land to the south west. This corridor must be provided in any detailed application to ensure that the further 2ha of employment land can be delivered and to provide an improved access for Thompson and Morgan via the new junction with the A1214.

Arboricultural Officer

193. A small number of trees are proposed for removal but they are generally of limited value and

their loss will not have a significant impact on local amenity.

194. All remaining trees scheduled for retention will be afforded adequate protection if undertaken in accordance with the Pegasus Group arboricultural report. An appropriate condition should be used for this purpose also including a detailed method statement and auditable monitoring schedule.


Strategic Housing 195. No objection

196. The Babergh and Mid Suffolk District Strategic Housing Market Assessment confirms a

continuing need for housing across all tenures and a growing need for affordable housing. The most recent update of the Strategic Housing Market Assessment, completed in 2012 confirms a minimum need of 134 affordable homes per annum.

197. The mix of affordable housing offered in this application is acceptable. However, all 27 units of affordable housing are shown in one location within the proposed development. It is considered good practice not to develop this number of affordable dwellings in one location within a scheme and therefore it is recommended that no more than 15 affordable dwellings should be located in any one part of the development. Therefore the affordable housing should be separated into two blocks of affordable housing spread across the site.

198. We also note that Phase 1 includes no single storey bungalow accommodation. The 2011 Census data confirms that Babergh has an ageing population and as a result there is a need for appropriately designed accommodation built to a Lifetime standard.

199. It would also be appropriate for any open market apartments and smaller houses on the site to be designed and developed to Lifetime-Homes standards, making these attractive and appropriate for older people.

Recommended Conditions

Properties must be built to current Homes and Communities Agency Design and Quality Standards and be to Lifetimes Homes standards.

The council is granted 100% nomination rights to all the affordable units in perpetuity.

The Shared Ownership properties must have a 75% staircasing bar, to ensure they are available to successive occupiers as affordable housing in perpetuity

The Council will not support a bid for Homes & Communities Agency grant funding on the affordable homes delivered as part of an open market development. Therefore the affordable units on that part of the site must be delivered grant free.

The affordable units delivered on the local needs part of the site will need further consideration regarding any grant application to the HCA and a support for grant cannot be guaranteed in this instance. It is recommended that RP partners consider this matter carefully.

The location and phasing of the affordable housing units must be agreed with the Council to ensure they are integrated within the proposed development according to current best practice.

On larger sites the affordable housing should not be placed in groups of more than 15 units.

Adequate parking provision is made for the affordable housing units

It is preferred that the affordable units are transferred to one of Babergh’s partner Registered Providers

Public Realm/Open Space

200. There is an adequate provision of open space and green infrastructure, including play space

within these proposals, however the facilities only lend themselves to benefit the community who will eventually live on the development and the immediate area and to this end the Local Authority should not be responsible for the long term governance and maintenance of the facilities. The developer should make provision for a charge to be made to each property that is then used to engage a management company who will maintain the facilities in perpetuity.


Environmental Health - Land Contamination Issues 201. The developer has submitted a very thorough investigation and having reviewed the report I

am happy to agree with the conclusion that the likelihood of contamination adversely impacting on the proposed development is low.

Environmental Health - Sustainability Issues

202. The applicant has incorporated the energy efficiency and sustainability measures as stipulated

in Policies CS12-15 of the Babergh Local Plan 2011-2031 (February 2014) into the design of the proposed development.

203. As a large-scale development, the applicant has proposed the installation of a renewable energy/low carbon system in order to achieve a 10% reduction in predicted carbon dioxide emissions. Further clarification is required to ensure the feasibility of the anticipated carbon dioxide emissions reductions.

204. Post-Code for Sustainable Homes Standards: The applicant has acknowledged that the Code for Sustainable Homes is no longer in force, and has mentioned clarification of the subsequent required standards.

205. The applicant is required to ensure that the residential units achieve a 19% carbon dioxide emissions reduction against a Part L (2013) compliant baseline. This equates to same standards previously required for a Code for Sustainable Homes Level 4 rating.

206. As the dwellings are able to achieve a Level 4 rating, the applicant is strongly encouraged to construct the units in line with the mentioned preliminary-assessment. This will ensure sustainability standards above and beyond the minimum requirements.

BREEAM:

207. The applicant has clarified that the non-residential elements of the proposed development will secure a BREEAM rating of ‘Excellent’. The applicant will be required to demonstrate the feasibility of this standard through the submission of the associated preliminary-assessment and subsequent Design/Post-Construction stage certificates.

208. Building for Life 12: The applicant has provided an initial assessment which details how the development can achieve the highest ‘12-Green’ rating. It is therefore possible to approve this rating and to request that the same standards are secured at the post-construction stage.

Renewable Energy/LZC Technologies

209. In accordance with Policy CS13, the applicant has proposed to include a renewable/low-carbon technology installation which will reduce the predicted carbon dioxide emissions of the development by at least 10%. In order to ensure the feasibility of the associated carbon dioxide emissions reductions, the applicant is asked to submit full technical details of the proposed system.

Environmental Health - Other Issues

210. The Wolsey Grange: Noise and Vibration Impact Assessment (IA) identifies that the noise

climate at the site is dominated by road traffic noise from the A14, A1071 and A1214. There are some additional noise sources from existing commercial/industrial areas (e.g. Thompson and Morgan).


211. The 5 measurement points used to identify the existing noise climate close to existing noise sources all find external noise to be above the 55dB upper BS8233 and WHO guideline levels for serious annoyance.

212. BS8233 states that "it is desirable that the external noise level does not exceed 50dBLAeq,t

with an upper guideline value of 55dBLaeq,t which would be acceptable in noise environments". In addressing the impact of noise in outdoor areas, a design standard of 55dB has been chosen. This is the higher of the WHO/BS8233 values, meaning that design value chosen will find 'moderate annoyance' acceptable - BS8233 states the guideline values should only be exceeded if "a compromise between elevated noise levels and other factors such as the convenience of living in these locations or making efficient use of land resources to ensure development needs can be met, might be warranted". The site is therefore not ideal for residential development and such development would thus only be appropriate if you consider there are significant wider social and economic benefits of the development.

Construction Noise

213. The IA identifies that predicated noise levels from construction noise would have "a significant

adverse effect on the prevailing noise climate at the earliest sensitive receptor on Poplar Lane" during worse case periods whereby plant is within 5m of the site boundary nearest the receptor - in these periods noise can be up to 10dB (up to a doubling of noise levels) above the 70dB threshold identified in the IA. During 'average' periods noise level will be of 'moderate adverse significance'.

214. Section 6.11. identifies that with a 2.4m high standard site hoarding barrier, noise levels at the

ground floors of these dwellings will be below or marginally above the 70dB threshold. This will not, however, protect upper floors during times when construction takes place. Recommend that a condition be attached to the effect that a 2.4m high standard site hoarding barrier must be erected around the construction site perimeter prior to any construction taking place.

215. Table 6.3 of the IA identifies that the vibration level at existing receptors would be negligible

apart from during worst case periods at Poplar Lane which will be of minor adverse effect. 216. Recommend that a condition be attached to the effect that a Construction and Environment

Management Plan be submitted to the LPA for approval prior to construction works beginning on site.

Traffic Noise

217. The impact of the development on future traffic noise is assessed in the IA and predicts that long term traffic noise will increase by less than 1dB, and thus is likely imperceptible.

Noise from Fixed Plant

218. Noise from fixed plant will mainly be dealt with at the detailed design stage. Noise limit of

43dB has been set for the proposed commercial area (equal to typical background noise measured at point closest to Thompson and Morgan). Recommend that this be attached by means of a condition. A further condition should be attached to the effect that once detailed layout is determined a further assessment(s) based on BS:4142:2014 should be made.

219. Due to the shared interface proposed between the employment land and residential dwellings

measures should be taken to increase the separation/shielding between these uses, and a condition attached so that at the detailed design stage a noise assessment based on BS4142:2014 should be carried out, based on the cumulative noise limit.


Residential Development

220. Existing noise levels are above BS8233 upper values and WHO guidance values to avoid serious annoyance in external areas and would also be significantly above BS8233 internal guidance levels.

221. An acoustic barrier of 2m high with a surface density of 15kg/m3 should be installed alongside

the A1071, and the location and specification of this barrier be secured by means of a condition.

222. The barrier will protect the ground floor only and two glazing performance standards would be

needed across the Phase 1 dwellings in order to ensure internal noise levels can be met. If approved recommend that the requirement for the glazing performance standards be attached by condition.

223. Dwellings, particularly at the edge of the development, will be affected by traffic noise of such

an intensity that windows will need to remain shut all of the time in order to achieve a good internal noise standard for habitation, including sleep. If windows were partially left open it is likely that such noise will have a significant and adverse impact on the internal noise climate of those dwellings, causing disturbance and premature wakening and sleep loss. However, you may decide that windows may still be openable for rapid or purge ventilation, or occupants choice.

224. The NPPF and PPG recommend that planning decisions should be avoided where the

perception of noise is noticeable and disruptive and such that it has a significant impact. However, neither NPPF nor the Noise Policy Statement for England (NPSE) expects noise to be considered in isolation to other social, economic and environmental benefits. PPG also states:

225. "The planning process should avoid this (significant adverse effects) occurring, by using appropriate mitigation..." and "such decisions must be made taking into account the economic and social benefit of the activity..."

226. In mitigation the IA recommends a high standard of acoustic double glazing and demonstrates

by calculation that via a high standard of acoustic glazing and alternative acoustic ventilation, internal noise levels will meet acceptable criteria. I would advise you that these mitigation measures can be regarded as appropriate if you consider there are significant wider social and economic benefits of the development.

227. In external areas noise level in phase 1 gardens will meet the noise limit of 55dB. This limit

finds 'moderate annoyance' to be acceptable and therefore some loss of amenity will result. Some plots require 1.8m high garden fences in order for this limit to be met and I would recommend that this requirement be attached by means of a condition.

228. Plots 93, 95 and 24 will have portions of garden where this limit cannot be met. I do not feel

that allowing any external garden areas to be exposed to noise levels likely to cause serious annoyance is acceptable as all garden amenity land should be able to be used as such.

229. In respect of the outline dwellings, post phase 1 it is identified that noise levels are significantly

above BS8233/WHO guidance values. A 4m high acoustic barrier between residential land and the A14 would significantly reduce boundary noise from the A14 and should be subject to a condition if approved. Even with this barrier dwellings most exposed to noise from the A14 may require acoustic ventilation. I would find this totally unacceptable as these areas are clearly unsuitable for residential development. Dwellings further back 'may be able to rely on a natural ventilation solution'. I would recommend refusal of any dwellings which would be reliant on mechanical ventilation.

230. The IA identifies that it may not be possible to achieve the required standard for external

amenity areas in a small number of gardens in the North-West corner of the site adjacent to


the proposed attenuation basin and further south adjacent to Poplar Lane. I object to any plot which does not meet the standard to avoid serious annoyance. School

232 The IA identifies that the noise levels are significantly above the 'serious annoyance' threshold for external noise. Therefore, this is not an ideal location for a school.

233 Internal levels can only be met by the use of acoustic glazing. This package would only be

appropriate for ground floor and would rely on windows remaining shut. I would strongly recommend that a condition be attached to the effect that further noise assessment once the details are determined.

234 The IA states that it would be possible to avoid the need for mechanical ventilation through

careful siting and design. I would again state that it would be totally unacceptable for any of the teaching areas of the school to rely on mechanical ventilation. If the school is to have an upper storey it must be capable of being adequately ventilated by passive means, otherwise I would recommend refusal.

235 External areas of the school are likely to be above the 55dB threshold. It may be possible to

use the school building itself to screen some external teaching areas to below 55dB, with non-sensitive areas (such as the car park) to be located at more exposed areas. I would advise that mitigation measures can be regarded as appropriate if there are significant wider social and economic benefits of the development.

236 Existing commercial/industrial units

237 Loading and warehouse activity may be perceptible in the proposed dwellings at the shared

interface to the east of Thompson and Morgan. This has the potential to result in loss of amenity for residents. Recommend a condition for a noise assessment to be carried out to assess the impact of the operation of both Thompson and Morgan and the Holiday Inn at proposed new dwellings once the detailed design is known.

Lighting

238. Proposed residential development could be at risk from loss of amenity from external lighting at existing and proposed commercial development. Recommend a condition for a lighting assessment prior to development of residential properties.

Play Area

239. Recommend ensure the separation distances as set out in BDC Supplementary Planning Guidance for the provision of outdoor recreation facilities and open space HS32

Additional Comments Received 1st September 2015

240. Suggest conditions be attached to any permission:

Sample of residential properties to be indefinitely tested and certified to demonstrate

that the scheme of glazing has been effectively installed and design values are being met.

In respect of the school condition that details of all extract ventilation, air handling and

other noisy plant along with a scheme of attenuation and Noise Assessment shall be submitted to the LPA prior to construction.

Details of kitchen extract ventilation and odour abatement submitted to the LPA for

approval prior to construction. In respect of the employment land a condition that any employment/commercial units

including a commercial kitchen shall be required to submit details of kitchen extract ventilation and odour abatement to the LPA for approval prior to construction.


Suffolk Preservation Society 241. Residential development on this site to the west of London Road represents a significant

extension to the residential area of Ipswich into previously undeveloped land within the parish boundary of Sproughton. The society therefore concurs with Ipswich Borough Council’s recommendation that the application in its current form should be resisted until a masterplan for the west side of Ipswich is developed. The site forms part of, and has implications to, a wider area which crosses the Babergh District and Ipswich Borough boundary and a strategic approach to its development should be taken.

242. The Society also has the following strong objections to the design and layout of the full

planning consent element of this application for 145 dwellings.

Design and Layout

243. The application Design and Access statement sets out 3 residential character areas (The Gateway, Rural Edge and Neighbourhood Housing) and includes individual characteristics for each area. Nevertheless The Society contends that the resulting layout is largely uniform in its approach to the built form and streetscape. The design of the dwellings is generic, lacking quality and imagination, and the hierarchy between statement gateway dwellings and neighbourhood housing is unclear. Although there is no distinct built character in the immediate vicinity, the Society would like to see greater effort to instill a sense of local character and distinctiveness into this new residential area through its design, detailing and choice of materials.

244. Moreover the proposed layout is devoid of a sense of place due to a lack of a focal point and

public realm space beyond the play area to the far south west of the site. Buildings at the entrance from Poplar Lane are orientated so that they present blank elevations and fencing to the spine road, rather than being designed appropriately for a corner plot.

245. The Society also notes that the affordable element of the development is clustered to the

north edge of the site. This approach to design is contrary to design guidance on developing inclusive sustainable communities (such as Building for Life 12 – CABE 2012) which recommends that dwellings of the same size should not be grouped together and that streets should be tenure blind so that it is not easy to differentiate vbetween private and shared ownership or rental properties. We fail to understand why this approach is not being followed in this instance.

Car Parking

246. On street parking spaces (both visitor and allocated) dominate the street scene to an unacceptable level in some parts of the development compromising the success of the scheme both from within and when viewed from outside. Of particular note is the north edge of the development where the parking for the affordable homes is all to the front of the homes which negatively impacts on dwelling outlooks and safe pedestrian movement and dominates the streetscene when viewed from the A1071 Hadleigh Road.

247. In other places car parking seems to have been designed without consideration for the end

users or the future functionality of the proposed development. As an example the parking courts which serve units 38 to 41 and 104 to 107 are located without passive surveillance and allocate spaces at some distance from the dwelling. Parking that is not well overlooked is unlikely to be well used and will encourage more on street parking.

Conclusion

248. The Society contends that the implications of developing this site on the wider area should be addressed via a masterplan for the area to the west of Ipswich and we therefore urge that this application is resisted at this time. Furthermore we do not consider that the design and layout of the proposed scheme of 145 dwellings is of sufficiently high quality and would recommend this scheme goes before the Suffolk Design Review Panel for an independent and expert analysis.


REPRESENTATIONS

249. One representation supporting the application has been received and the comments are summarised as follows:

Need for new housing

Parking plan sensible

Plan for new play area, school and employment land work together

Benefit many people and bring economic benefits to the area

250. Sixty-one representations objecting to the application have been received and the comments are summarised as follows:

Over development not compliant with the Core Strategy

Creeping coalescence towards Sproughton

Cumulative effects

Need for comprehensive masterplan

Loss of agricultural land

Special Landscape Area

Traffic congestion

Inadequacies in Transport Assessment

Impact on transport infrastructure

Impact on bats and birds

Loss of privacy

Noise pollution from construction and extra vehicle movements

Surface water run-off

Character

Design with three storey properties adjacent to the A1071

Lack of affordable housing

Impact on health services

PLANNING CONSIDERATIONS

251. In light of the representations received, an assessment of national and adopted development

plan policies and having regard to site constraints and other material considerations the main planning considerations are considered to be:

Principle of Development

The National Planning Policy Framework

252. The National Planning Policy Framework (NPPF) was published on 27th March 2012. It provides that the NPPF "does not change the statutory status of the development plan as the starting point for decision making. Proposed development that accords with an up-to-date Local Plan should be approved, and proposed development that conflicts should be refused unless other material considerations indicate otherwise".

253. The NPPF came into full effect on 27th March 2013. Under paragraph 215 the NPPF provides

that “due weight should be given to relevant policies in existing plans according to their degree of consistency with this framework (the closer the policies in the plan to the policies in the Framework, the greater the weight that may be given)”. The relevant Local Plan policies set out above are considered to be consistent with paragraphs 14, 17, 34, 56, 57, 58, 61, 64, 109, 112, 134 and 173 of the NPPF. The policies contained within the NPPF are a material consideration and should be taken into account for decision-making purposes.


Local Plan Policies

254. The NPPF requires Councils to identify and update on an annual basis a supply of specific deliverable sites sufficient to provide for five years’ worth of housing against their identified requirements. Relevant policies for the supply of housing land should not be considered up to date if the Local Planning Authority cannot demonstrate a five year supply of deliverable housing sites. For sites to be considered deliverable they have to be available, suitable, achievable and viable. The June 2015 Annual Monitoring Report confirms that Babergh currently has a calculated 6.3 years supply of deliverable housing sites (including a 5% buffer required by the NPPF).

255. With respect Babergh District Council Core Strategy policies, Policy CS7 allocates the site

and other adjoining land to provide: 256. “approximately 6 hectares of land to create a quality ‘gateway’ business/employment area in

addition to the existing employment uses within the allocated area; and 257. A new community of approximately 350 homes” 258. The June 2015 Annual Monitoring Report confirms that Babergh currently has a calculated

6.3 years supply of deliverable housing sites (including a 5% buffer required by the NPPF). 259. The application proposal exceeds the expected 350 homes, with a total of 475 proposed. As

such, whilst the development of the site is considered to be acceptable in principle, the extent proposed exceeds the policy expectation.

260. In compliance with Policy CS7 the site was subject to a Masterplan, which was presented to

Committee on 22 July 2015 and endorsed with the resolution “That the content of the Strategic Master Plan Document, Babergh Ipswich Fringe, be noted as an informal planning document that will be used with immediate effect to guide the consideration of future planning applications on the site”.

261. During the Masterplanning process, the proposal for the site has evolved, on an iterative

basis, changing land uses, increasing the housing numbers’ and relocating the primary school. These changes related to more detailed assessments of the site being undertaken involving EIA screening and consultations, including with the Design Review Panel. This process included the increase in the numbers of houses proposed to ensure the viability of the proposal. The report to Committee on the Masterplan confirmed that “without a modification to the quantum of development and type of employment uses it will not be possible to address existing traffic problems and achieve a proposal that is capable of implementation”.

262. Whilst the proposal is recognised as exceeding the expected approximate number of

dwellings detailed within Policy CS7, it should also be noted that that the policy recognises that viability is an important factor. The NPPF, inter alia, states at paragraph 173 (Ensuring Viability and Deliverability):

263. “Pursuing sustainable development requires careful attention to viability and costs in plan-

making and decision-taking. Plans should be deliverable. Therefore, the sites and the scale of development identified in the plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened. To ensure viability, the costs of any requirements likely to be applied to development, such as requirements for affordable housing, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable development to be deliverable.”

264. In the light of this clear policy guidance within NPPF, detailed consideration has been given to

the extent of development as part of the viability-informed Masterplan process. The extent of the development as now proposed is considered to be acceptable in principle, subject to compliance with the detailed requirements of Local Plan Policies and other material considerations, with particular regards to the viability of the proposal and its implementation. These specific details are part of the considerations of this application addressed later in this report.


Strategic Approach

265. The context of the site in the wider area of potential and cumulative development is an issue that has been raised in response to consultation, with particular regards to the need for a comprehensive plan covering this area to ensure co-ordinated development of the area.

266. Whilst it is recognised that the site is in an area of potential growth and will form part of a

cumulative impact, subject to the residual impacts not being unacceptable it is considered that this application should be considered on its own merits. When considering the Babergh Local Plan 2011-2031 Core Strategy in January 2014, the Local Plan Inspector considered this issue, with particular regard to the requirement for a comprehensive masterplan for a wider area in advance of the development. The Inspector agreed that whilst a masterplan for the wider area “has much to commend it, it is not clear why development of the Ipswich Fringe site should be delayed to allow this to take place. Moreover there is a good argument that such a masterplan would have been more appropriate before the development of the Suffolk One Scheme, lying between the Ipswich Fringe site and the majority of the urban area. The Suffolk One development, has to a significant extent, linked the Ipswich Fringe site and the main urban area, and increased the suitability of the site for further urban development.”

267. The Inspector further concluded that “Although it is reasonable to consider this site as part of

the wider development of this part of Ipswich, this would include areas of remaining land which have a wider range of constraints and more complex delivery issues. There is no reason to delay the development of the Ipswich Fringe site whilst the deliverability of this wider area is considered. In any event, a more substantial development beyond the allocated site would be in excess of the Council’s requirements for the current plan period”.

268. As such, it is clear that the Inspector did not consider that it would be appropriate to delay the

development of this site to require such a masterplan, and in the light of this decision as a material consideration it is not considered appropriate to refuse the application on this basis.

Environmental Impact Assessment

269. The site falls within the category for urban development as set out in the EIA Regulations but does not reach the indicative thresholds set out in Planning Practice Guidance. A Screening Request was received in this respect which concluded that the proposal “is not considered to constitute development which is of a size or type which would cause significant environmental impact”. As such this does not affect the principle of the proposal, with specific environmental impacts considered accordingly within the application.

Sustainability, Resilience to Climate Change and Sustainable Transport and Construction 270. The NPPF gives significant weight to sustainable development. Specifically, stating at

paragraph 14 that … “At the heart of the National Planning Policy Framework is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-taking.”

271. At paragraph 17 the NPPF further states, inter alia, that planning “… should support the

transition to a low carbon future in a changing climate….and encourage the reuse of existing resources, including conversion of existing buildings, and encourage the use of renewable resources …”

272. Adaption to, and resilience against, climate change is a key consideration in the achievement

of sustainable development in the terms envisaged under the NPPF, as is sustainable transport.

273. This is echoed in the Core Strategy Policy CS13 which states that “All new development will

be required to minimise dependence on fossil fuels and make the fullest contribution to the mitigation of climate change through adopting a sustainable approach to energy use.” The policy also states that “…the Council will support proposals for development that include on-site low and zero carbon technologies including, where appropriate, proposals to retro-fit existing buildings as part of schemes to extend or convert those buildings.”


274. Core Strategy Policy CS15 builds on the requirements of Policy CS13 by setting out more specifically the tests that will be applied in assessing new development proposals in terms of sustainability. Key here are the requirements for new development to “address climate change through design, adaptation, mitigation and by incorporating or producing sources of renewable or low-carbon energy” and to seek to minimise energy demand, minimise the need to travel by car and - where appropriate to the scale of a proposal - to require applications to be supported by Transport/Travel Plans.

275. The ‘sustainability’ of the proposal and its resilience to climate change can be broken down

into a number of key issues, such as the accessibility of the proposed development, the developments resilience to climate change and building performance. Other important aspects of sustainable development such as quality design, ecology, and safeguarding heritage are discussed later in this report.

Location of the Development and Sustainable Transport

276. Local Plan Policies generally direct new residential development to identified settlements to reduce the need to travel. This principle is continued in the Core Strategy, with the site as a Strategic Allocation, these have “been selected as locations that can be aligned with the capacity of existing infrastructure, or can be planned at a scale that is sufficiently viable to include new or improved infrastructure, and planned to include employment land, green infrastructure and access to services including transport.”

277. This is in compliance with the NPPF which states at paragraph 34 that “decisions should

ensure that developments that generate significant movements are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised.” It goes on to state that “development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe”.

278. The application site is situated on the edge of the existing urban area of Ipswich. In the

immediate vicinity of the site are Suffolk One sixth form and a veterinary practice between London Road and Scrivener Drive, also in this location there are extant planning permissions for Fred Olsen headquarters and an Aldi store. To the south-west of the site is ‘The Interchange’ retail park, with Currys, Multiyork, PC World, B&M, Pizza Hut and Costa Coffee, with Tesco, Mothercare, Burger King and Toys R Us further south. At the retail park, from the park and ride, and around the site on the A1214 and A1071 are bus stops which provide access into Ipswich, including the railway station and town centre and also to the wider area, including Hadleigh, Sudbury, Claydon and Colchester.

279. In light of the variety of services which are available within close proximity to the application

site and the availability of alternative forms of transport, a reasonable conclusion can be formed that the site is sustainably located. To further assist sustainable transport, the applicants have prepared a Travel Plan for both residential and commercial properties to promote sustainable modes of transport.

Drainage

280. A key issue when considering ‘resilience’ is whether the development has been designed to adapt to climate change, such as an increased risk of flooding. To this end, the application is accompanied by a flood risk assessment, surface water drainage strategy and a foul water drainage strategy.

281. The application site itself is located outside flood zones 2 and 3, where there is little or no risk

of flooding from rivers. The main issue therefore, is the risk of flooding from surface water, with particular regards to the impact of the development upon flood risk downstream. The application includes a sustainable drainage system to deal with surface water drainage, including infiltration and attenuation basins.


282. Suffolk County Council as Lead Local Flood Authority confirms that the site can drain without worsening flooding off the site, in accordance with the NPPF and proposes conditions to agree the specific details of the strategy for disposal of surface water.

Energy

283. Core Strategy Policies CS12, CS13 and CS15 set out the requirements for sustainable design and construction standards including the use of renewable and low carbon energy.

284. Policy CS12 requires strategic site allocations to achieve the Building for Life Silver Standard and non-residential developments to achieve the BREEAM ‘excellent’ standard or equivalent. However, this standard was based on the previous Building for Life Assessment, which has been replaced by Building for Life 12, which is a traffic light scheme with red, amber and green standards based on 12 questions. Achieving 9 green standards attains ‘Built for Life’ and achieving 12 green standards ‘Outstanding’. The Building for Life 12 clearly states that there is no correlation to the gold and silver standards used previously.

285. The Building for Life 12 assessment provided with the application sets out the approaches

taken in the design of the proposal to meet the criteria, which in combination with conditions are such that the proposal is considered to be capable of achieving 12 green scores. In the light of this the proposal is considered to comply with the updated Building for Life Standard, and therefore comply with Policy CS12 in this respect.

286. For non-residential elements, in compliance with the requirements of Core Strategy Policy

CS12, the proposal is expected to achieve an ‘excellent’ standard. 287. Policy CS13 requires development of Strategic Allocations to use on-site renewable,

decentralised, or low carbon energy sources with the aim of achieving a 10% reduction in the carbon dioxide emissions of the development. The proposal includes a renewable/low carbon installation which will reduce the predicted carbon dioxide emissions of the development by at least 10%, which can be appropriately secured by way of condition.

288. It is considered that conditions are appropriate to secure at least 10% of the energy from

renewable, decentralised or low carbon sources, to achieve an ‘Excellent’ BREEAM standard and to demonstrate Building for Life 12 criteria in order to secure these details given the evidence that this can be achieved.

Conclusion (Sustainability, Resilience to Climate Change and Sustainable Transport

and Construction)

289. In summary, the location of the development is considered to be sustainable and resilient. The development has been designed with climate change in mind, with appropriate drainage and renewable energy considered and secured by means of condition. As such the proposed development is considered to represent sustainable development within the meaning set out by the NPPF and to respond to climate and social change.

Design and Layout

290. Local Plan Policy CN01 requires all new development to be of an appropriate scale, form,

design and finish. Delivering quality design is a core aim of the NPPF stating, in Paragraph 56, that good design is a key aspect of sustainable development and indivisible from good planning, such that Policy CN01 is consistent with the NPPF.

291. The built development in the area around the site is a mixture of estate development and

functional employment buildings. The two buildings with a significant relationship to the site are the Holiday Inn and Suffolk One. In the wider area there is the new veterinary site and the Interchange retail park. These buildings combined with the enclosure of the site by the A14, A1071 and A1214 provide the backdrop for this site.


292. The Design Review Panel (DRP) assessed the Masterplan proposed, including looking at the densities of the site and the design proposed. Indeed, the Panel recommended that 3/4 storey buildings could be appropriate in certain locations, including the entrance to Poplar Lane. With particular regard to the detailed design, the DRP considered that the edges of the site have the opportunity to assist with establishing character for the scheme, there being no overriding character or specific context to the immediately surrounding area. Therefore, the DRP “saw no need in this location to mimic the Suffolk vernacular” and the development “could instead have its own identity”.

293. The Masterplan identifies three character types for housing, Gateway, Low Density to Poplar

Lane and Core Family Housing. This typology is further expanded as part of the application, with Gateway, Neighbourhood Housing and Rural Edge as the identified housing types proposed for the full part of the application. The details of housing in respect of the outline application site would form part of reserved matters details.

294. The Gateway character area is located at the entrance to Phase 1 fronting the SuDS

attenuation basin. These properties are a mix of 2.5 and 3-storey properties with materials proposed to be red brick with slate. The design and character of these properties creates an entrance to the site from both Poplar Lane and the A1071 and is considered to provide an identifiable character to the site at the point of entrance, providing a strong sense of place and character.

295. Neighbourhood Housing character area makes up the main part of the residential areas

proposed. These properties are predominantly 2 storey semi-detached and terraced dwellings. These properties would have a wider mix of materials with a mellow red and buff brick, with red pantiles. Corner three storey properties fronting the A1071 would also be part render, creating landmarks in the development.

296. Rural Edge character properties are located close to the open and green areas within the site.

These properties would predominantly be 2-storey detached dwellings, with 2.5-storey dwellings in key locations. The combination in heights and mix in materials, predominantly in buff brick, interspersed with mellow red and render creates an edge of area character and landmarks to the pedestrian junctions.

297. The overall layout of the outline application site will form part of the reserved matters details;

however, the principles of the land use are as set out in the approved Masterplan. In respect of Phase 1 (to which the full planning application relates), the layout provides an entrance zone to the site, a neighbourhood zone, and a more open edge of development. The layout combined with the different housing types provides for landmark buildings, which join the various routes through the site, for pedestrians, cyclists and vehicles. The indicative layout for the outline application site would further develop this form and character.

298. Concerns have been raised in respect of the three-storey properties fronting the A1071.

However, the three-storey properties are limited to two corner properties at plots 52-57 and 80-85, would be set back over 30m from the edge of the A1071 and would be screened by the landscaping along the embankment. As such the proposal is not considered to have an overbearing impact on the A1071, or skyline and would be in keeping with the overall context of the proposal.

299. With regards to density, the indicative number of dwellings proposed in Policy CS7 would

equate to a density of 37 dwellings per hectare. However, this proposal for 475 dwellings would equate to 42 dwellings per hectare, although this will vary across the site, with a less dense character to the rural edge type dwellings in particular. Phase 1 would have a density of 43 dwellings per hectare. This is in compliance with Local Plan Policy HS27, which requires residential development to be in excess of 30 dwellings per hectare, with paragraph 3.100 of the supporting text to Policy HS27 identifying levels of between 30 and 50 dwellings per hectare as acceptable. Policy HS27 is consistent with the NPPF, with particular regards to paragraph 58 which states, inter alia, that development should “optimise the potential of the site to accommodate development”. The increased number of dwellings proposed has led to an increase in the density of development on the application site, however, given the expectations of the Local Plan the increase in density proposed is not considered to be unacceptable such as to warrant refusal on this basis.


300. The full application provides the details for residential development in Phase 1, creating an individual character for the Phase 1 site. Given the character intended and that this should be retained it is considered appropriate to remove permitted development rights for some alterations and extensions, which can be secured by means of condition. Furthermore, there is the expectation that a Masterplan derived character will be developed across the outline part of the site such that a condition is also considered to be appropriate in this respect.

Amenity Space, Open Space and Recreation

301. Policy HS31 of the Local Plan requires development sites of 1.5ha or more to provide 10% of

the site area as public open space. The Core Strategy does not set a standard but takes the approach that development should address deficiencies and meet adopted local standards. In this case, the standards are set out in the adopted ‘Open Space, Sport and Recreation Strategy’. This is consistent with the NPPF which requires the provision of open space but leaves the setting of standards to Local Authorities.

302. The proposal includes the provision of several areas of green space, providing links across

the site, joining up with the existing woodland on Poplar Lane and providing areas for green infrastructure surrounding the attenuation areas. These also link to the existing public footpaths providing a green corridor for access through the site.

303. Whilst there are no specific details, 2.2ha of the outline application site would provide public

open space and 5.39ha of green infrastructure, not including the attenuation basins. Details can be secured through the reserved matters applications.

304. With regards to the Phase 1 detailed application, the proposal includes 1.14ha for public open

space including 0.063ha for a children’s play area (Local Equipped Area for Play). In addition to this will be green infrastructure, not including the attenuation basins. The combined area amounts to 4.76ha, or 40% of the Phase 1 site area.

305. Given the level of amenity space proposed, including access across the site with ‘trim trail’,

cycling and walking routes, together with access to formal pitches for various sports available at the neighbouring Suffolk One, the site is considered to offer appropriate open space provision.

306. The management of the open space, along with the public realm would be undertaken by a

management company. The section 106 planning obligation can secure the appropriate management of the proposed public open space and ensure public access. An obligation is therefore recommended to achieve this.

Residential Amenity (Noise and Disturbance, Other Amenity Considerations)

307. A core planning principle in the NPPF in paragraph 17 is that Local Planning Authorities

should “always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings”.

308. The development would potentially impact on the amenity of existing residents, and be

impacted upon itself, by a number of environmental impacts that require consideration.

Air Quality

309. An Air Quality Assessment formed part of the application submission. This assessment confirmed that whilst the construction has the potential to risk some harm to air quality, with good site practice and mitigation measures the impact on air quality would be negligible. With regards to the potential impact of development generated traffic the assessment of the development is that it would not cause any exceedance of the air quality objectives. As such subject to conditions the proposal is not considered to risk harm to consider refusal on this basis.


Noise and Disturbance

310. The existing noise environment at the site close to the A14, A1071 and A1214 is above the 55 dB LAeq,T upper BS 8233:2014 and WHO Guideline levels for serious annoyance. However, mitigation measures have been proposed and can be secured by condition, which is regarded as appropriate. Whilst the site in this respect may not be without some compromised amenity nevertheless, there are wider benefits from this proposal in respect of the provision of housing and employment land and the associated economic benefits. It is considered that these merits are of greater weight in the delivery of the Councils Core Strategy and new homes. Furthermore, Environmental Health have confirmed that appropriate mitigation measures are available and can be secured by means of condition, such that the proposal is not considered to be unacceptable to consider refusal in this respect.

Lighting

311. Policy EN22 of the Local Plan relates to lighting. It aims to minimise light spill and pollution to safeguard residential amenity, the character of an area and highway safety. The baseline condition for the site is generally unlit, but enclosed in part by the lit A1071 and A1214, with the Holiday Inn also a source of light. Proposed residential development in the outline area may be at risk of loss of amenity from lighting at the existing and proposed commercial uses. However, Environmental Health recommends a condition for a lighting assessment such that the outline layout can address this issue, such that the proposal is not considered to be unacceptable in this respect.

Land Contamination

312. With regards to land contamination, Environmental Health confirms that the site has been subject to a thorough investigation and the likelihood of contamination adversely impacting on the proposed development is low.

Construction Impacts

313. The impacts from construction upon the locality including dwellings in Poplar Lane require careful consideration given the scale of the project and the long build out programme, Phase 3 being anticipated to come forward from 2023. The applicant would be required to prepare a detailed construction management plan and sign up to a Considerate Contractor Scheme. This would mitigate impacts in terms of construction noise, pollution in terms of materials, dust etc., traffic routes and measures to liaise with the community to address local concerns.

314. Furthermore, to provide additional protection Environmental Health recommends that site

hoarding barriers are erected prior to construction. This will protect ground floors of neighbouring properties, but will not provide any mitigation of construction noise to upper floors. As such a condition to limit the hours of working is proposed to provide additional protection and control in this respect.

Other Issues

315. Officers have not identified any issues with regards to overlooking, loss of light, outlook or overbearing impacts. With regards to existing neighbouring properties Phase 1 proposals do not abut existing residential properties, and in respect of the outline proposal there is sufficient space to ensure that existing residential properties are not unacceptably affected and this would form part of any reserved matters considerations. Furthermore, the play area has been located to safeguard residential amenity, in compliance with Policy HS32.

Highway Safety

316. From assessing the consultation responses received it is clear that the impact on highway

safety is an issue of some concern. 317. Alterations are proposed to the Poplar Lane junction to create new three-way traffic signals, a

new access to the A1071/Hadleigh Road junction creating a cross-roads junction, alterations to the A1071, A1214 junction, a new junction to the A1214 from the site, alterations ‘The Beagle roundabout’ and alterations to the ‘Tesco roundabout’.


318. The applicants have prepared a Transport Assessment (TA) that has considered the impacts of the development on highway safety. This has been assessed in detail by Highways England and Suffolk County Council Highways Authority.

319. Highways England have raised no objection to the proposal, their jurisdiction relating to the

A12/A14 Copdock Interchange, which additional flows from the application site are predicated to only minimally affect.

320. Suffolk County Council has assessed the proposal and various works proposed to increase

highways capacity as necessary in relation to this application. They confirm that the TA is ‘over-robust’, not allowing for trips undertaken on route home, shared trips, change in mode of transport or for residents who work on or close to the site and don’t travel by car. Furthermore this does not take account of ‘alternative assumptions’, which avoids double counting growth associated with committed developments. As such this combined with the package of highway works proposed is such that Suffolk County Council Highways consider that the adverse effects have been mitigated to a level which is not severe.

321. With regards to the various junctions Suffolk County Council Highways consider that there are

some areas which need further consideration. Your Officers consider that these revisions may reasonably be dealt with by means of condition and this is recommended.

322. Concerns have been raised in respect of pedestrian crossings provided in the junction design

at to the A1071/Hadleigh Road junction proposed. Modification required to the hatching on the A1071/B1113 (The Beagle) roundabout and to the lining of the new junction to the A1214. However, given the robustness of the Assessment that has been recognised it is considered that these alterations can be satisfactorily dealt with by means of a condition to agree the final details of the works to the junctions.

323. The remaining outstanding issue raised by Suffolk County Council Highways in regards to this

proposal is the requirement for a continuous footpath both sides of Poplar Lane. The footpath design formed part of the Masterplan and design process for this development. Poplar Lane is a ‘no-through’ country road, and is a rural lane in character and form, which character the Masterplan deliberately wished to be retained as far as possible as part of this proposal. The provision of footpaths on both sides of the road would compromise this rural character, and in the light of this and given that a footpath is provided with appropriate crossing points to a road that would continue to be a ‘no-through’ route is considered to be acceptable.

Impact on Heritage

324. In accordance with Section 66(1) of the Planning (Listed Building and Conservation Areas)

Act 1990 there is a general duty placed upon local planning authorities which requires them to have special regard to the desirability of preserving listed buildings and their settings when considering whether to grant planning permission. With regards to the proposal there are Listed Buildings and archaeological remains which form the relevant heritage assets in this respect, taking each in turn below:

Listed Buildings

325. Excluded from the red line site area, but located centrally within the site, is Poplar Farmhouse, a Grade II property originating from the late 16th or early 17th Century. Elsewhere in the wider locality there are various other Listed Buildings, including Springvale, Red House and its’ associated barn, Prync’s Lodge and The Chantry as well as various Listed Buildings in Washbrook and Copdock. The subsurface remains of a medieval chapel may lie to the south of Poplar Farmhouse.

326. Section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 states that 'in

considering whether to grant planning permission for development which affects a listed building or its setting, the local planning authority … shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses'.


327. Poplar Farmhouse is screened from Poplar Lane by dense planting and from other views by mature trees. The setting of the Listed Building currently includes the neighbouring Poplar Farm Cottages and Thompson and Morgan, whilst the original agricultural setting including field patterns have been eroded and the property separated from its associated land by the A14. Furthermore, the immediate setting of the Listed Building has been affected by the various alterations, including a tennis court and swimming pool in the immediate grounds.

328. The area of woodland adjacent to Poplar Farmhouse is outside the site area and would be

unaffected by the proposal, whilst the landscaping screening on the site would be retained. Given the level of screening the landscaping provides it is considered that the proposal would have a less than substantial impact on the setting of the Listed Building. As such it is considered that the setting and significance would not be unacceptably affected, despite the loss of the wider agricultural setting and residential development in close proximity to the Listed Building. As such the proposal is considered to result in less than substantial harm to this heritage asset.

329. The Listed Buildings outside the application area are well separated from the site, with some

but limited, inter-visibility. This, combined with the infrastructure and adjoining existing development, is such that the proposal is not considered to result in harm in this respect.

330. The proposal as a site providing housing provision and associated infrastructure and

economic benefits is considered to represent a public benefit to overcome the limited and less than substantial harm to the Listed Building.

331. This would be in line with Saved Local Plan Policy CN06 which seeks to protect listed

buildings (statutorily listed and non-statutory) along with paragraph 134 of the National Planning Policy Framework (NPPF) which recognises that less than substantial harm is not unacceptable if this can be weighed against public benefits. The public benefits of delivering the CS7 allocation have been noted above.

Archaeological Remains

332. The site lies within an area of archaeological potential and as such has been subject to

geophysical survey and archaeological evaluation. There is documentary evidence of the ‘lost’ mediaeval chapel on or close to the site, although evaluation to date has not identified this within the application site.

333. The proposed works would cause significant ground disturbance that has the potential to

damage any archaeological deposit and below ground heritage assets that exist. On the basis of work to date Suffolk County Council Archaeology confirm that there are no grounds to consider refusal of permission in order to achieve in situ preservation, subject to conditions to ensure the appropriate recording. Subject to this the principle of what is proposed is acceptable insofar as it would satisfy the tests set under Saved Local Plan Policy SD13.

Landscape Character

334. The application site is within the Special Landscape Area designation, which is recognised

within the strategic allocation of the site within Policy CS7. Policy CS7 in this regard required the Masterplan to be based on and designed around a green infrastructure network linking formal and informal green spaces, wildlife areas and natural landscape settings and features, particularly the Gipping Valley footpath, Chantry Park and Belstead Brook Park. The Masterplan and application proposal provide green links through the site, linking existing landscaping such as the woodland (which falls outside the redline application site) and roadside areas of landscaping with new areas of landscaping, including the attenuation basins and LEAP. As such, whilst the proposal is recognised to alter the character of this site it is considered to comply with the requirements set out in this respect in Policy CS7 and subsequently the expectations of the Masterplan.


Biodiversity 335. The NPPF states (at paragraph 109) that development should “minimise impacts on

biodiversity and providing net gains in biodiversity where possible”. This is supported by Policy CS15 of the Babergh Core Strategy.

336. The application site is located close to a number of important ecology/biodiversity

designations due to its proximity to both the Stour and Orwell estuaries. The estuaries are covered by the following designations:

The Orwell and Stour Ramsar site (A UN designation that relates to internationally important wetlands)

The Orwell and Stour Special Protection Area (SPA) as designated under the Conservation of Habitat and Species Regulations 2010 (EU designations relating to habitats important to birds)

Orwell and Stour Site of Special Scientific Interest

337. None of these designations extend to the site, but notwithstanding this the development has the potential to have an impact on the habitats and species using them, such that Regulations 59 to 62 of the Conservation of Habitats and Species Regulations 2010 ("the Habitats Regulations") apply.

338. Due to the site constraints paragraph 118 of the NPPF is relevant, which states that “when

determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles:

if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;

proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site’s notified special interest features is likely, an exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest;

opportunities to incorporate biodiversity in and around developments should be encouraged;

the following wildlife sites should be given the same protection as European sites: potential Special Protection Areas and possible Special Areas of Conservation; listed or proposed Ramsar sites; and sites identified, or required, as compensatory measures for adverse effects on European sites, potential Special Protection Areas, possible Special Areas of Conservation, and listed or proposed Ramsar sites."

Designated Sites

339. The Core Strategy acknowledges that there is the potential for impact on the Stour and Orwell Estuaries through increased recreational pressures from development in the district. Natural England however confirms that “taking into account the distance of the proposed development site from the Stour and Orwell Estuaries SPA, Natural England advises that potential impacts to this site as a result of the development alone can be ruled out”. The provision of Green Infrastructure on site will, to some extent, minimise the visits to the designated sites but should not be used alone as mitigation for in-combination impacts.


340. As such a Habitats Regulation Assessment has been undertaken and Natural England confirm that subject to the mitigation set out in the report the proposal will not have an unacceptable impact in this respect. Accordingly Suffolk County Council Ecology provided figures for this mitigation, and which are proposed to be secured by means of a Section 106 agreement.

341. To further minimise impacts on the estuaries management and maintenance of the Green

Infrastructure can be appropriately secured to ensure its long term sustainability, in accordance with Natural England’s advice.

Agricultural Land

342. In terms of the site itself, the site comprises more than 20ha of the ‘best and most versatile’ agricultural land. The NPPF (at paragraph 112) states that: “Local planning authorities 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 a higher quality”

343. The proposal would result in the loss of Grade 2 agricultural land. Approximately half of the

agricultural land in Babergh District is Grade 2, such that the proposal is not considered to result in an unacceptable loss of a significant natural resource. Furthermore, the development of the site has significant benefits with regards to the provision of housing and commercial employment land and the associated economic benefits, which are considered to outweigh this.

344. In addition, a condition to safeguard the soil resources of the site and the long term potential of

the site can be imposed to provide a safeguard in this respect. As such the proposal is not considered to have an unacceptable impact to warrant refusal in this respect.

Protected Species

Various species have been identified on the site, taking each in turn below: Reptiles

345. Areas of potential reptile habitat exist on the site, such that proposed works could potentially cause foreseeable harm to reptile species protected under nature conservation legislation. As such specific reptile surveys were undertaken. The surveys identified that the application site is unlikely to support reptiles, although a small number of grass snakes were found in an area of grassland which is proposed for part of the SuDS and green infrastructure.

346. The application does not include any specific mitigation measures as no reptiles were

identified within the development area, and the landscaping proposed would benefit habitats. However, a condition to secure protection in this respect and mitigation measures is proposed, which is agreed by Suffolk Wildlife Trust.

Bats

347. A bat survey was submitted with the application, and following concerns raised by Suffolk Wildlife Trust an additional survey was undertaken. Activity from six species of bats was recorded along the hedgerows of the site, including hedgerows 3 (to the North of Poplar Lane between site entrance and woodland area), 4 (South of Poplar Lane) and 5 (North of A1214, from adjacent to boundary with the Holiday Inn), parts of each of which are proposed for removal (although it is noted that in respect of hedgerows 4 and 5 this is indicative as part of the outline proposal).

348. The removal of parts of these hedgerows is considered to risk disruption to commuting and

foraging routes. New planting will improve the connectivity between the hedgerow and off-site habitats, whilst tree planting will minimise gaps. This will provide mitigation in this respect and subject to this and a scheme of mitigation and enhancement secured through condition the proposal is not considered to have an unacceptable impact in this respect to warrant refusal.


Birds

349. The survey at the site identifies that it supports various breeding birds. The proposal would result in a loss of habitat for nesting birds. However, measures are proposed that Suffolk Wildlife Trust confirm would mitigate the impacts. They suggest additional mitigation for Skylarks along with further enhancements in biodiversity, which could be adequately controlled by means of condition or obligation.

Dormice

350. There is a dormouse population identified in the locality, in particular at Belstead Meadow, however the site has limited connectivity with this area, in particular due to the road network that encompasses the application site. In the light of this and the lack of suitable habitat on site it is not considered that the proposal risks harm to this species and Suffolk Wildlife Trust raise no objection in this respect.

Stag Beetles

351. Stag beetles are a UK and Suffolk Priority Species recorded in the proximity of this site. The proposal includes removal of hedgerows and planting that could have an adverse impact in this respect. However, Suffolk Wildlife Trust proposes a condition to ensure adequate mitigation and protection for this species. In addition the additional planting and green infrastructure would provide additional habitats, such that in combination the proposal is not considered to have an impact to consider refusal in this respect.

352. In assessing this application due regard has been given to the provisions of the Natural

Environment and Rural Communities Act, 2006, is so far as it is applicable to the proposal and the provisions of Conservation of Habitats and Species Regulations, 2010 in relation to protected species.

Cumulative Impact

353. The application site is situated within an area of potential growth such that the impact on the

development is not related solely to the existing situation, but the cumulative result of development in the locality.

354. Highways impacts are the main consideration in this respect and the Transport Assessment is

considered by Suffolk County Council as ‘over-robust’. It does not take into account pass-by trips, shared trips, changes in transport mode or for residents who work in or close to the site. Furthermore, growth factors applied to the traffic flows do not take account of ‘alternative assumptions’, which would avoid double counting growth of committed developments.

355. With regards to the SPA Stour and Orwell Estuaries the cumulative impacts are considered

and have been confirmed within the HRA to be mitigated against, specifically to avoid ‘in combination’ impacts.

356. Furthermore, with Green Infrastructure and a school proposed for the site to provide for future

residents it is considered that the proposal has not only considered cumulative impact, but would not have an unacceptable impact to consider refusal in this respect.

Crime and Disorder

357. The NPPF in paragraph 58 states that developments should “create safe and accessible

environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion”.

358. The proposed layout creates back to back garden layouts, ensuring that rear gardens are not

exposed and do not create blank spaces. The frontages of properties provide natural surveillance to streets, pedestrian routes and public open space, in particular the children’s play space. Areas are well defined, with courtyard parking serving small numbers of properties encouraging ownership and a community.


359. Consideration has been given to the provisions of Section 17 of the Crime and Disorder Act, 1998, in the assessment of this application but the proposal does not raise any significant issues.

Planning Obligations and Viability

360. Core Strategy Policy CS21 requires that social and physical infrastructure is provided in

association with development proposals. Core Strategy Policy CS19 requires all housing development to provide 35% affordable housing on-site, and that tenure types, mixes and sizes should reflect established needs in the district. This is in line with the Community Infrastructure Levy Regulations and the provisions of the NPPF.

361. Set out below are the requests for contributions towards infrastructure:

Health The NHS has requested £149,880 to mitigate the need for extra health care provision to serve the residents of the development.

Education The County Council has requested £2,369,333 for primary school provision and £276,924 for early years provision.

In addition, a site of 1.2ha has been set out for the provision of a school, which is part of the application and can be secured by way of the Section 106 Agreement.

Public Rights of Way Contribution of £33,916

Libraries Contribution of £102,600

Highways Bond of £250,000 contingency for monitoring and addressing unmitigated problems if they occur, returned after 10 years if not used for this purpose.

Phase 1 Bus stop infrastructure £20,000

Phase 2 additional shelter and screen £15,000

Bond to provide bus service of £250,000, reduced by £50,000 per year, limited to 5 years

Travel Plan support contribution of £1,000 per annum until five years post completion of the whole development

Travel Plan implementation bond to cover the full residential element of the development £787,526

Bonds in respect of any parties to the S106 Agreement shall be in the form of Parent Company Guarantees and the monies attributable to these sums will be on a take up basis.

Ecology Mitigation on Stour and Orwell SPA from Habitats Regulation Assessment £30,000 (to include Green Infrastructure and SPA mitigation measures)


Viability

362. National Government PPG states that where the deliverability of the development may be compromised by the scale of planning obligations and other costs, a viability assessment may be necessary. This should be informed by the particular circumstances of the site and proposed development in question. A site is viable if the value generated by its development exceeds the costs of developing it and also provides sufficient incentive for the land to come forward and the development to be undertaken. Where an applicant is able to demonstrate to the satisfaction of the Local Planning Authority that the planning obligation would cause the development to be unviable, the Local Planning Authority should be flexible in seeking planning obligations.

363. The applicant has submitted a viability appraisal with the application which has been

assessed by your Viability Officer and the District Valuer. The site has unusually high infrastructure and costs on account of its location on two key roads into Ipswich, and the need to level and service the site to enable it to be developed. Evidence of all these costs have been supplied to the District Valuer who has assessed them against internal Quantity Surveying estimates and supported the figures. In addition, the site bears the cost of a new school when in effect only half a school is required and land for the school is being provided by the development.

364. It is primarily for these reasons that the original scheme for 350 homes was not viable, even if

the affordable housing provision were to be reduced to very low levels. The revised scheme including a provision of 35% affordable housing and contributions as set out above would still be in deficit and not viable. The revised scheme for 475 homes with 20% affordable housing, including the contributions as set out above, offers a competitive return to the landowners but does not project a reasonable profit for the development. The return is projected at marginally above zero and is also therefore in deficit. However, with growth in the market and design engineering the District Valuer has stated that the proposal would be marginally viable and capable of being delivered such that the developer might recover their reasonable profit. Taylor Wimpey have confirmed that they will accept the development risk for the scheme in regard to loss of profit and they will not seek a viability review for at least 5 years. This protects the 29 affordable homes in the first phase. The scheme is expected to be built out over 15 years and if growth assumptions and the market perform well the overall 20% affordable offer can come forward in the course of future phases.

365. In order to mitigate the risk of loss of profit 1/3 of the 20% provision will be starter homes.

Starter homes fall under the definition of Intermediate Affordable Housing in Annex 2 of the NPPF, which are charged with 6% profit, but the developer also has to bear the risk of selling.

366. The proposal does represent a reduction in the level of affordable housing from that required

by Policy CS19. However, the NPPF is clear at paragraph 173 that development should not be subject to such obligations and policy burdens that their ability to be developed viably is threatened. Developer profit is a key element of scheme viability. Furthermore, at paragraph 176 the NPPF goes on to state that “where safeguards are necessary to make a particular development acceptable in planning terms, the development should not be approved if the measures required cannot be secured through appropriate conditions or agreements”. In the light of this it is considered that the infrastructure requirements are necessary for the development, and although contrary to policy the reduction in affordable housing is necessary to ensure that this strategic site allocation is both viable and capable of delivery.

367. In the light of this and the extent of the detailed assessment of viability at masterplan stage

and during the application period it is considered that the proposal with a reduced level of affordable housing should not be considered unacceptable to warrant refusal in this respect.


Phasing 368. To allow for the development of the site over time, bearing in mind the viability of the proposal

and the incremental impact that would result as the development progresses, a scheme for the phasing of the payments is proposed as set out below. This includes a date at which a pro-rata amount would be payable if the development has not reached the amount of development expected, such that services can be supported appropriate to the level of development.

Trigger Points Amount and Reason

Prior to first occupation £33,916 Public Rights of Way £30,000 for HRA £20,000 for bus shelters and RTPI screen £1,000 First payment of Travel Plan Evaluation and Support Contribution (then to be paid annually until 5 years post completion)

The occupation of 100th dwelling or on a pro rata basis September 2020

£29,976 1st instalment healthcare £20,520 1st instalment library £473,866.60 1st instalment education £55,384.80 1st instalment early years

Prior to first occupation of 2nd phase residential development/ 146th dwelling

£15,000 for additional bus shelter and RTPI screen


£29,976 2nd instalment healthcare £20,520 2nd instalment library £473,866.60 2nd instalment education £55,384.80 2nd instalment early years


£29,976 3rd instalment healthcare £20,520 3rd instalment library £473,866.60 3rd instalment education £55,384.80 3rd instalment early years


£29,976 4th instalment healthcare £20,520 4th instalment of library contribution £473,866.60 4th instalment education £55,384.80 4th instalment early years


£29,976 5th instalment healthcare £20,520 5th instalment library contribution £473,866.60 5th instalment education £55,384.80 5th instalment early years

369. In accordance with the Community Infrastructure Levy Regulations, 2010, the obligations

recommended to be secured by way of a planning obligation deed are (a) necessary to make the Development acceptable in planning terms (b) directly related to the Development and (c) fairly and reasonably relate in scale and kind to the Development.


AFFORDABLE HOUSING AND HOUSING NEED

370. Core Strategy Policy CS19 requires all housing development to provide affordable housing on-site, and that tenure types, mixes and sizes should reflect established needs in the district. This is in line with the Community Infrastructure Levy Regulations and the provisions of the NPPF.

371. Strategic Housing confirms that there is a continuing need for housing across all tenures and

a growing need for affordable housing. With regards to housing need local to the site, the majority of demand is for one and two bedroom properties, with 83% registering for 1 or 2-bedroom dwelling.

372. The details are not confirmed in respect of the outline proposal, which will be expected to consider housing need at the time that the reserved matters come forward in this respect.

373. With regards to Phase 1, a total of 29 units of affordable housing are proposed. Of these

there would be 6 one bedroom properties, and 16 two-bedroom properties, 6 three-bedroom properties and 1 four-bedroom property. This provides 75% smaller properties, which is considered to be an appropriate mix for the housing need recognised in this locality.

CONCLUSION – OVERALL PLANNING BALANCE 374. The NPPF states that there is a presumption in favour of sustainable development.

Therefore, there is a presumption in favour of planning permission being granted for development that adheres to the NPPF, or a development plan which is up to date, and consistent with the NPPF. If a proposal does not accord with the policies within paragraphs 18 to 219 of the NPPF (to the extent they are relevant) it can reasonably be concluded that it is not sustainable development and consequently there is no presumption in favour of granting planning permission. In this case, the proposed development is considered to comply with the definition of sustainable development set out by the NPPF, with particular regards to the economic, social and environmental roles set out at paragraph 7.

375. Although the proposal departs, in turns of the approximate number of properties proposed

within the strategic site allocation (Policy CS7), this was part of the consideration of the Masterplan and forms part of the viability of the site to ensure delivery, a key requirement of the NPPF.

376. The viability work is accepted as demonstrating that the scheme can only fund a reduced

scheme of affordable housing, along with planning obligations as required to make the development acceptable. This is not considered to be unacceptable given the aims of Policy CS7 in order to bring forward the development of this site within the expectations of Policy CS7 strategic site allocation.

377. This proposal is considered to be deliverable and will make a substantial contribution to the

Council’s overall strategic housing requirements and 5-year land supply, in an appropriate sustainable location, on the fringe of Ipswich. The scheme would not result in a hazard or inconvenience to users of the public highway or have a significant impact on the wider highway network. The layout and design of the housing proposal reflects the constraints of the site, having regards to the Masterplan and indeed comments from the Design Review Panel to create an independent character for the site.

378. When taken as a whole, and a matter of planning judgement, the application is considered on

balance to represent a sustainable, viable and deliverable scheme of a strategic site allocation wherein the benefits and mitigation are such that the proposal is considered to be appropriate. Therefore, the application is recommended for approval.


RECOMMENDATION (1) That the Corporate Manager Development Management be authorised to secure a planning

obligation under Section 106 of the Town and Country Planning Act, 1990, to provide:

Phasing to secure implementation of infrastructure and overall phasing of the development

Estate management

Provision of public open space

Affordable housing

Diversion of footpath 16 onto proposed footway

Travel Plan

Transport Management Association or Travel Plan Management Group for coordination of travel plan

Welcome pack for employees and residential dwellings on occupation

Smarter Choices scheme to provide for residents and workplaces close to the development

Section 278 and Section 38 Agreements

Right to transfer of school land at occupation of 150th dwelling

Bond of £250,000 contingency for monitoring and addressing unmitigated problems if they occur, returned after 10 years if not used for this purpose.

Bond to provide bus service of £250,000, reduced by £50,000 per year, limited to 5 years

Travel Plan implementation bond to cover the full residential element of the development £787,526. This was reduced following clarification of requirements from Suffolk County Council Highways Department.

(Bonds in respect of any parties to the S106 Agreement shall be in the form of Parent Company Guarantees and that the monies attributable to these sums will be on a take up basis)

Contributions to Education, Healthcare, Libraries, Public Rights of Way, Highways and Special Protection Area Orwell and Stour Estuaries as below:


Trigger Points Amount and Reason

Prior to first occupation £33,916 Public Rights of Way £30,000 for HRA £20,000 for bus shelters and RTPI screen £1,000 First payment of Travel Plan Evaluation and Support Contribution (then to be paid annually until 5 years post completion)


£29,976 1st instalment healthcare £20,520 1st instalment library £473,866.60 1st instalment education £55,384.80 1st instalment early years

Prior to first occupation of 2nd phase residential development/ 146th dwelling

£15,000 for additional bus shelter and RTPI screen


£29,976 2nd instalment healthcare £20,520 2nd instalment library £473,866.60 2nd instalment education £55,384.80 2nd instalment early years


£29,976 3rd instalment healthcare £20,520 3rd instalment library £473,866.60 3rd instalment education £55,384.80 3rd instalment early years


£29,976 4th instalment healthcare £20,520 4th instalment of library contribution £473,866.60 4th instalment education £55,384.80 4th instalment early years


£29,976 5th instalment healthcare £20,520 5th instalment library contribution £473,866.60 5th instalment education £55,384.80 5th instalment early years

(2) That, subject to the completion of the Planning Obligation in Resolution (1) above to the satisfaction of the Corporate Manager - Development Management be authorised to grant outline planning permission subject to the following conditions including: Outline Application - Up to 475 dwellings, 4ha employment land (A3, A4, A5, D1, D2 and sui generis), 1.2ha primary education, public open space including play areas, associated landscaping, SuDS and highway improvements

Standard time limit

Approved plans

Reserved matters

Archaeological scheme of investigation and recording

Flood Risk Assessment and strategy for disposal of surface water to be agreed


Surface water drainage scheme for each phase

Foul water strategy

Ecological mitigation measures

Reptile mitigation plan to be agreed

Additional skylark mitigation measures to be agreed

Stag beetle protection measures

Bat mitigation and enhancement including early landscaping scheme for bat commuting and foraging

Lighting scheme

Scheme for soil management

Scheme for biodiversity enhancement

Biodiversity management plan for long term management of open spaces for biodiversity

Ecological management plan

Remove permitted development rights for new houses, Schedule 2, Part 1, Class A, B, C, D and E and Part 2 Class A

Remove permitted development rights for employment land, Schedule 2 Part 3 Class A

Employment uses limited to Class A3, A4, A5, D1, D2 and sui generis uses limited to car showrooms, retail warehouse clubs, petrol station and garden centre.

Site hoarding to be erected around construction site perimeter prior to commencement

Construction working hours

Construction Management Plan

Acoustic barrier details to be agreed to A14

Glazing performance standards including scheme for testing

Cumulative noise limit for commercial area

Noise assessment on detailed layout

Details of kitchen extract ventilation and odour abatement for any commercial kitchen

Noise assessment of commercial/residential interface

Noise assessment required for school

School glazing to achieve internal noise levels

Details of all extract ventilation, air handling and noisy plant at the school along with a scheme of attenuation and Noise Assessment

Details of kitchen extract ventilation and odour abatement for the school

Noise assessment required to assess impact of Thompson and Morgan and Holiday Inn on proposed dwellings

Garden areas external noise limit

Fencing

Lighting assessment of existing and proposed commercial premises impact on proposed residential dwellings

Scheme for fire hydrants and hardstanding for fire capacity

Waste minimisation and recycling strategy

Waste bins and garden composting bins to be provided

Water butts

Landscaping scheme and implementation

Tree protection including method statement and monitoring schedule

Commercial buildings to achieve BREEAM excellent standard to be achieved, with scheme submitted prior to first use

Building for Life 12 Standard, evidence to be submitted prior to occupation

Energy Statement to demonstrate renewable energy and carbon dioxide emissions

No commercial building to be occupied until hours of operation are agreed for that user

Materials

Levels

School Travel Plan

Green Travel Plan

Individual commercial units to comply with site wide travel plan

Notwithstanding junction details submitted additional details shall be submitted to and approved in writing


Bus turning details to be agreed, including metalled surface, 12m space to turn in forward gear, lighting and measures to prevent other vehicles using the space

Footpath improvements

Highways mitigation A1071/B1113 and A1071/Hadleigh Road prior to occupation of Phase 2

Highways mitigation Tesco roundabout Prior to 300th occupation

Highways mitigation A1214 prior to works starting on employment land

Notwithstanding details submitted additional details to be submitted and agreed as follows:

o Drg. 5244-SK-22 Rev F – A1214 new signal junction – changes to road

markings and signs. o Drg. 5244-SK-25 Rev C – A1071 / B1113 Roundabout – Additional two lane

entry o Drg. 5244-SK-26 Rev C – A1214 Scrivener Drive / Tesco Roundabout –

additional mitigation may be required or further work to demonstrate not achievable.

o Drg. 5244-SK-11 Rev G – A1071 / Haleigh Road signal – changes to pedestrian / cycle facilities

o Drg. 5244-SK-20 Rev I – Poplar Lane improvements – changes to some details and additional footway

o Drg. 5244-SK-21 Rev E – A1071 improvements

Road layout to be agreed

Provision roads and footpaths prior to occupation

HGV movements subject to Deliveries Management Plan

Areas for loading, unloading, parking and manoeuvring to be agreed

Parking spaces provided and made functionally available prior to first occupation

Details to show means to prevent discharge of surface water onto the highway

Full Application - 145 dwellings, public open space and play areas, green infrastructure, landscaping and boundary treatments, SuDS and pumping station, highway improvements and an electricity substation

Standard time limit

Approved plans

Archaeological scheme of investigation and recording

Surface water drainage scheme for phase

Foul water strategy

Ecological mitigation measures implemented in accordance with reports

Reptile mitigation plan to be agreed

Additional skylark mitigation measures to be agreed

Stag beetle protection measures

Lighting scheme

Bat mitigation and enhancement including early landscaping scheme for bat commuting and foraging

Scheme for soil management

Scheme for biodiversity enhancement

Biodiversity management plan for long term management of open spaces for biodiversity

Ecological management plan

Remove permitted development rights for new houses, Schedule 2, Part 1, Class A, B, C, D and E

Site hoarding to be erected around site perimeter prior to commencement

Construction management plan

Construction working hours

Acoustic barrier details to be agreed to A1071


Glazing performance standards including scheme for testing

Provision of fencing prior to first occupation

Scheme for fire hydrants and hardstanding for fire capacity

Waste minimisation and recycling strategy

Waste bins and garden composting bins to be provided

Water butts

Tree protection including method statement and monitoring schedule

Landscaping scheme and implementation

Materials

Levels

Building for Life 12 standard

Energy Statement to demonstrate renewable energy and carbon dioxide emissions

Agree a scheme for extension of bus service which is to be provided prior to the occupation of the 100th dwelling and maintained for 5 years.

Notwithstanding junction details submitted additional details shall be submitted to and approved in writing

Highways mitigation to Poplar Lane, A1071 prior to first occupation

Provision road and footpaths prior to occupation

Visibility splay for Poplar Lane

Parking spaces provided and made functionally available prior to first occupation

Details to show means to prevent discharge of surface water onto the highway

(3) That, in the event of the Planning Obligation referred to in Resolution (1) above not being

secured by the Corporate Manager - Development Management be authorised to refuse outline planning permission on appropriate grounds.