Many individuals and groups oppose the building of large scale housing developments on greenfield land around the Trimley Villages, including both Parish Councils and the Suffolk Preservation Society. This page is devoted to things that STAG have done recently in their battle to publicise the cause and influence the Local Development Framework Task Group decision making process.

Next LDF Task Group Meeting 23 July 2007 At 4.30pm

STAG have always believed that the LDF Task Group are determined to do everything possible to make sure that greenfield land around the Trimley Villages is used for large scale housing developments and now we have even more proof.

The background paperwork for the next LDF Task Group Meeting has just been published where the “Themes” to be discussed are “Settlement Hierarchy” and “Employment”.

Proof One : Appendix 3 of the Settlement Hierarchy background papers contains all of the responses received as part of the recent consultation exercise. These responses took the form of answers to specific, and often loaded, questions asked by the LDF Task Group. STAG and Trimley St Martin Parish Council believed it would be more appropriate to submit detailed narrative responses and these have been published in full as Appendix 4. In Appendix 3 every comment from every respondent receives a detailed “SCDC Response”. However, the detailed criticisms from STAG and Trimley St Martin Parish Council have been published without comment and no attempt has been made to counter our detailed criticisms.

Proof Two : Our criticisms have not been ignored entirely, since the many pages of well thought out and convincingly argued narrative responses by STAG and Trimley St Martin Parish Council are summarily dismissed, without argument or justification, as “misinterpretation” in a single sentence in Appendix 1 of the Settlement Hierarchy papers.

“Concern is based on an interpretation of the hierarchy whereby the settlements are subsumed by the larger adjacent town.  Of course, this is not the intention. The settlements are recognised as having individual identities and containing services and facilities to serve the local community and a wider catchment area.”
( The dictionary definition of “subsume”, by the way, is ‘To include or absorb something in something else as part of a larger group’. )
Proof Three : The LDF Task Group seem to have recognised the wish for the Trimley Villages to retain their separate identities from Felixstowe, but are prepared to go to the lengths of inventing a new category within the Settlement Hierarchy - a “super” Key Service Centre - in order to pave the way for their ultimate aim of large scale housing estates on greenfield land around the Trimley Villages.
Would it be stating the obvious to point out that there are also significant environmental - and infrastructure - constraints around the Trimley Villages? Would it be too difficult to ask the obvious question - If environmental constraints are applicable to countryside around Woodbridge why are they not good enough for countryside around the Trimley Villages?

The Trimley Villages are represented by three District Councillors - Richard Kerry, Sherrie Green and Graham Harding. Richard Kerry is a member of the LDF Task Group and he therefore has a duty to speak out loudly and forcefully and vote appropriately in the defence of the Trimley Villages at the next LDF Task Group Meeting - that is why he was elected. Sherrie Green and Graham Harding can attend and speak at LDF Task Group Meetings, but are not members and can not vote. They must attend on our behalf and they also have a duty to speak loudly and forcefully  in the defence of the Trimley Villages - that is why they were elected.

Because of our concerns we asked Stephen Brown, Planning Policy And Implementation Manager a number of questions. These are detailed below, along with his answers. We are grateful to Mr Brown for supplying detailed comments at short notice.

STAG : Every respondent to the consultation process received detailed replies to their comments within Appendix 3. Would you please explain why STAG's detailed and well argued responses are summarily dismissed in one sentence within Appendix 1?

Stephen Brown :  The STAG narrative raised eight issues. The first two, relating to bias, are not for me or the Head of Planning Services to comment on. Those are criticisms of the process of preparing the Local Development Framework rather than the content of the documents themselves. Of the remaining six only one is directly relevant to the subject of the report to the Task Group, namely the position of each of the Trimleys within a settlement hierarchy. The remainder are, in my view, of more relevance to the topic of housing and will be considered at the future, relevant meeting. It may have been more appropriate to defer the reporting of the full narrative to that meeting. However, I was under the impression, perhaps mistakenly, that both STAG and Trimley St Martin Parish Council would have wanted their views reported up front rather than held back.

STAG : This sentence in Appendix 1 dismisses our criticisms as a "misinterpretation" of the Settlement Hierarchy. Would you please explain exactly what it is that we have misinterpreted.

Stephen Brown : Your narrative, as well as that of Trimley St Martin Parish Council, demonstrates how this assumption was made by the continuing use of the word "suburb". There has not been the slightest suggestion that a settlement hierarchy was being put forward, the outcome of which would be the merging of the three communities of Felixstowe, Trimley St Martin and Trimley St Mary into one. The communities on the fringes of Ipswich also took the similar view that being part of the "Ipswich Policy Area" meant the loss of identity and individuality. This has never been the case. Recognition of the need to retain separate identities is considered important and, indeed, you will be aware from the last meeting of the Task Group that this is recognised in the revised Vision. Therefore, the proposal to be put to the Task Group is to remove "bracketing", eg "Felixstowe/Trimleys", "Ipswich fringe" and to classify each community according to its current function. The Trimley villages thus become Key Service Centres (supported by STAG if my interpretation of its comments is correct). However, their physical size (Trimley St Mary is larger than Wickham Market) and proximity to a major employment centre towards which national and regional policy indicate growth should be directed must have a bearing on their future planning.

STAG : Appendix 1 states that the Trimley Villages will not be "subsumed" by Felixstowe. If large numbers of houses are built around the Trimley Villages could you please let us know what word you would use instead of "subsumed"?

Stephen Brown : First of all it depends upon the numbers of houses involved (which is a debate still to come) and where they would be located (which is a further debate). You are starting from the assumption that Felixstowe will expand and the area between the A14 and the railway line is to be filled with houses, thereby "subsuming" the Trimley villages. Your criticism of the Council's approach is based around a theory that that is to be the end product and the Council is working towards it, or as STAG says "the way is now paved for large scale housing developments on greenfield land surrounding the Trimley villages." I, as the professional advisor to the Council, am starting from a position whereby I ask the questions "can housing development be located at the Trimley villages without losing their individual and separate identities (obviously I have to concede that views from individuals' windows may be affected)? If so, how much, where and when? What are the advantages and what are the disadvantages? How will this fit in with the national and regional planning policy framework? What other options are there?"

STAG : Appendix 1 suggests the possibility of a new category within the Settlement Hierarchy above Key Service Centres in order to allow for growth associated with the adjacent major centre. Could you please let us know which respondents to the consultation process suggested this new category.

Stephen Brown : No respondent suggested a new category. This is a suggestion being put to the Task Group by the professional advisors as a means of addressing the issue of where in a settlement hierarchy the Trimley villages and Wickham Market might be located. This would be particularly pertinent were size as well as function to be a criteria for selection given that the smallest Key Service Centre is Eyke with a population under 400 and the largest now proposed is Martlesham with a population over 5500. I would like to stress that the introduction of a new category is only an option.

STAG : At page 18 of Appendix 3 a respondent - Mr John Johnston - suggests that Woodbridge would be a more appropriate location for new homes. This suggestion is dismissed because of "significant environmental constraints". Would you please explain what these "environmental constraints" are and why they apply to Woodbridge and not greenfield land surrounding the Trimley Villages?

Evening Star – Thursday 21st June 2007

Task Group Must get it right

CAMPAIGNERS today re-launched their battle to prevent what they claim are "unnecessary and unwanted" large­ scale housing develop­ments around the twin Trimley villages.

Save Trimley Against Growth (STAG) is worried that proposals to build thousands of' homes on the Felixstowe peninsula will mean most of them going on fields in the two communities.

Suffolk Coastal District Council said no decisions have yet been made about where new homes will be built.

The. council has 389 suggest­ed sites for homes - ranging from plots for one property to land for 3,000 - and will show these to the public early next year when it announces its own preferred option for future development.

However, STAG believes councillors on the' Local Development Framework (LDF) task group- will recom­mend the "going for growth" option which would mean 2,720 new homes will be built on greenfield land around Felixstowe and the Trimleys.

STAG spokeswoman Barbara Shout said: "This is a hugely important issue, not just for the Trimley villages but for the district as -a whole. It is essential the LDF task group gets it right and to get it right they must use accurate housing figures, they must lis­ten to the people who will be most affected by their deci­sions and their deliberations must be fair. and transparent.”

STAG is concerned that housing statistics being used to formulate the plans are at least three years out of date.

The group is also angry that of all the parishes in the dis­trict, only Trimley St Martin and Trimley St Mary have had their status changed.

It claims responses to the recent consultation on hous­ing options from STAG and Trimley St Martin Parish Council were ignored but it has now persuaded planning chiefs to give the detailed responses to every member of the task group.

The group is to attend every task group meeting to ensure the interests of the Trimleys are fairly presented and prop­erly discussed.

It has also re-launched its website and invited village councillors Sherrie Green, Graham Harding and Richard Kerry to make their views known, along with MP John Gummer and task group chair­man, Andy Smith.

STAG attended the Extraordinary Meeting of Felixstowe Town Council on 19 March at which they expressed a preference for Housing Option Six. We were concerned about certain aspects of this Meeting, as explained below in our letter to Hilary Slater, Head of Legal and Democratic Services at SCDC. Barbara Shout’s letter is reproduced below, along with Hilary Slater’s replies in italics.

Dear Ms Slater

Felixstowe Town Council discussed their response to the Local Development Framework Consultation Document at an Extraordinary Meeting of the Council held on 19 March 2007.

One : Councillor MW Stokell is recorded as having declared a prejudicial interest regarding this item because of family interests in land in the areas under discussion. Councillor Stokell is not recorded as having left the room during the relevant discussions. Having such a prejudicial interest, should he have left the room, and has he committed an offence reportable to the Standards Board For England by not having done so?

I have seen the minutes of the meeting of Felixstowe Town Council (“FTC”) on 19th March. I note that Cllr Stokell declared a “prejudicial interest in any parts of item 365 which were site specific in North Felixstowe or Trimley in view of family interests in land in these areas”.  It is not recorded whether he left the meeting.

The Code of Conduct for Members of Town/Parish Councils in force at that time (please note that there is a revised Model Code for members but I will refer to the old Code, throughout this reply) provides that members with a prejudicial interest in any matter must withdraw from the room or chamber where a meeting is being held whenever it becomes apparent that the matter in which they have a prejudicial interest is being considered.

I have not discussed the meeting or the minutes with Cllr Stokell, but I make the assumption that he did not, in fact, leave the meeting.

If the matters in which Cllr Stokell had a prejudicial interest, that is, those “parts of item 365 which were site specific…” were not considered as part of the general discussion, and it appears that they were not, the obligation to withdraw would not have arisen.

Non-compliance with the Code of Conduct is not an “offence” in the criminal sense. Allegations that the Code of Conduct has been breached can be reported in writing to the Standards Board for England, the organisation that currently is responsible for enforcing the Code.  

Two : Councillor AJA Smith is recorded as having declared a personal interest in this matter as a member of Suffolk Coastal District Council. Councillor Smith is also Chairman of The Local Development Framework Task Group with specific responsibility for the implementation of their Core Strategy.
(a) Should this particular interest also have been declared?

Membership of a public authority or body exercising functions of a public nature is an interest which a member must register on their register of interests form. If the matter being considered at a meeting relates to an interest in respect of which notification must be given on the register of interests, then a personal interest arises.The nature and existence of the personal interest needs to be declared, hence, I assume, the declaration of a personal interest by Cllr Smith in relation to his membership of another public authority, i.e. Suffolk Coastal.

It is membership of another public body which needs to be declared, not the fact that a member holds various positions within that authority.

(b) Should Councillor Smith also have declared that at the July 2006 Meeting of the LDF Task Group their preference for Housing Option Six was Minuted?

Again, what needs to be declared is the nature and existence of the interest which in this case was membership of another public body, not what may or may not have been decided at particular meetings of that other authority.

(c) Did chairmanship of the LDF Task Group, and / or the LDF Task Group's Minuted Option preference, make his interest prejudicial instead of merely personal?

It is a matter for each member to decide whether a personal interest is also prejudicial.

(d) If it was prejudicial should he have left the room while discussions were taking place?

The Code of Conduct for Members of Town/Parish Councils provides that members with a prejudicial interest in any matter must withdraw from the room or chamber where a meeting is being held whenever it becomes apparent that the matter in which they have a prejudicial interest is being considered.

(e) If his declarable interest was prejudicial and he did not leave the room, has Councillor Smith committed any offences which render him liable to reporting to the Standards Board For England?

If an allegation of breach of the Code of Conduct is made, and investigated, the person investigating the allegation would apply the test, set out in the Code, as to whether or not the personal interest was also prejudicial. The test for whether a personal interest is also prejudicial is to consider whether a member of the public with knowledge of the relevant facts would reasonably regard an interest as so significant that it would be likely to prejudice the member’s judgement of the public interest.  

Three : If it was wrong for one or both of these two councillors to remain in the room while Felixstowe Town Council's response was discussed, and for them to take part in this discussion, has Councillor A Rodwell, as Chair of the meeting, committed any offences reportable to the Standards Board For England by not requiring them to leave the room?

Where a personal interest is declared, the member can remain in the room and take part in the debate and the vote, as Cllr Smith did. Where a prejudicial interest is declared, the member must withdraw when the matter in which they have a prejudicial interest is being considered. As I have said above, if the specific sites were not being considered, the obligation to withdraw would not have arisen.

I cannot see a reason for the Chairman to require that either of the Councillors should leave the room.

Four : If it was wrong for either of these two Councillors to remain in the room while Felixstowe Town Council's response was discussed, and for them to take part in these discussions, does this invalidate any conclusions reached as a result of this discussion process?

As per the first paragraph in answer three, and if the Councillors were entitled to be in the room for the reasons set out above, the conclusions will not be invalidated.

Regards
Barbara Shout

In mid-June 2007 the paperwork to be presented at the LDF Task Group Meeting on 20 June became available on the SCDC website. The Core Strategies Issues And Options Representations - summaries of opinions received as part of the consultation process - contained almost no mention of the criticisms made by  STAG and Trimley St Martin Parish Council. We wrote to Hilary Slater, Head Of Legal Services and Stephen Brown, Planning Policy And Implementation Manager, and within days got a guarantee that they would be properly presented to the LDF Task Group.

Dear Ms Slater,
I am writing to you as the nominated spokesperson for Save Trimley Against Growth.
On 30 March STAG submitted a detailed narrative response to the LDF Core Strategy Issues And Options Consultation Document.
Our response was narrative because we felt that answering the preprinted Consultation Questions would not do justice to our views.
Our detailed response covered the following major topics :
1. Bias in the decision making process by the LDF Task Group
2. Bias by its chairman, Councillor A Smith
3. The use of inaccurate and out of date statistics in the proposed Housing Options
4. Manipulation of the Settlement Hierarchy to pave the way for large scale housing developments on greenfield land around the Trimley villages
5. Disregard for the facts and practicalities regarding housing numbers, affordable homes, and future employment prospects
6. Disregard for the severely adverse affects more homes will have on all aspects of Felixstowe Peninsula infrastructure
7. Failure to sufficiently prioritise the absolute requirement to use brownfield land first for major housing developments
8. Failure to sufficiently recognise the particular impact large scale housing developments will have on the Trimley Villages or the sacrifices the Trimley villages have already made to satisfy the housing needs of Felixstowe.
The LDF Task Group next meets on 20 June, and I have now downloaded and studied the documents to be submitted to this meeting.
In Document LPTG 05/07 STAG are acknowledged as being one of the 195 Consultation respondents. However, I am very concerned that only 2 documents have been published which summarise the responses received -
a) Appendix 1 - Q2. Does the Vision cover all the issues you think it should?, and
b) Appendix 2 - Q4. Does the Town Vision cover all of the issues you think it should?
I am even more concerned that STAG's well considered and well argued views have not been fairly summarised in either of these documents.
Our views barely get a scant mention on page 15 of the responses to Q2 and none of our other criticisms have even been mentioned.
It is STAG's view that unless responses to all Consultation questions are published, and unless these responses are fairly summarised - including responses which took the form of a narrative - then the consultation process will be neither open, fair nor transparent, and will not comply with the LDF's own Statement Of Community Involvement which was adopted last July.
I would appreciate your views on this matter. I know it is a tall order, but since the next LDF Meeing is 20 June a reply before then would be much appreciated.
Barbara Shout
Save Trimley Against Growth

Dear Mr and Mrs Shout

Thanks for your email of today.

I understand that the response to the recent public consultation exercise is to be reported to the Local Development Framework Task Group over a series of meetings. It will be based around themes - settlement pattern, housing, employment, countryside etc. The first meeting of the series is to take place on June 20th. A report to that meeting gives broad statistics in respect of the numbers of responses and then concentrates on one theme - the "Vision". This was the first, very short, chapter of the consultation document and is strategic and outline in its form. It does not go into detail. Where respondents have specifically referred to the Vision or an element of it, their comments have been reported.

As I understand from your email, the issues which you raise relate primarily to themes to be debated at future meetings, predominantly housing. Your views will be reported then, at those future meetings.

In respect of the manner in which responses are reported, the public had the opportunity to complete forms by hand or electronic means. The Council created a publishing system whereby the entirety of an answer can be incorporated into a report to Councillors. However, where responses have been submitted in often lengthy narrative form the officers will have to summarise where possible or, if they consider that a summary might not convey the full extent of the points being put across, to append the response in full. Such a decision will need to be made in this case when the themes of settlement pattern and housing are to be considered by members and the report is being drafted. However, officers are fully aware of the concerns in the Trimleys in respect of the LDF and it is always been officers' intention to ensure as far as possible that those concerns are reported in full.

Points 1 and 2 do not relate to the proposed content of the LDF but to the process that the Council is following. The Chairman of the Task Group has been made aware of the matters raised and it was not the intention to report them to the Task Group as a whole.

I trust that this is of assistance.

I am sorry that I am not yet in a position to respond to your email of the 6th June. I will endeavour to do so, shortly,

Yours sincerely,

Hilary Slater

Dear Mr Brown,

Re: LDF meeting on 20th June.
STAG appreciates that the LDF consultation responses will be considered over a series of themed meetings. However, we are still concerned that because our detailed consultation response "did not fill the boxes", and is
highly critical, it may not get the consideration it deserves.
It has been stated that STAG's detailed responses will be summarised or appended and considered when the appropriate "Themes" are discussed at future meetings. It would not be proper in this e-mail to argue our case in detail, but perhaps you would care to put our minds at rest with just two examples from our response.
We expressed concerns regarding

(1) the apparent bias of the LDF Committee as a whole and the apparent bias of Councillor Smith in particular, and

(2) the use of historical housing statistics which were - in February - almost three years old.
STAG believes that, notwithstanding the strength of our other arguments, these points strike at the whole core of the LDF decision making process and are especially relevant to the Visionary Questions 2 and 4 to be debated next week. Therefore could you please explain -
1. Why our fundamental concerns regarding bias and the use of 3 year old figures are not relevant to the Vision as a whole, and
2. Which "Theme" within the LDF series of meetings they will be relevant to.
When a timetable for debates, and their topics, is available it would be most useful if you were able to send us a copy of that document.

Regards

Barbara Shout
Save Trimley Against Growth

PS : As an aside, - our information is that "The Chairman of the Task Group has been made aware of the matters raised and it is not the intention to report them to the Task Group as a whole. " - could you please clarify exactly which matters will the Chairman not be reporting to the Task Group?

Dear Mr and Mrs Shout

The Local Development Framework Task Group reconvenes on July 20th for the first time since the elections with a large proportion of new members (including Councillor Richard Kerry). The agenda for the meeting is, therefore, very much centred on introducing the members to the concept of the Local Development Framework and the work done to date.

As you say, the Task Group will consider the recent consultation exercise over a number of meetings and the responses will be grouped around subjects - "themes" as you describe them. The first "theme" is the Vision for the whole document. This is general in its scope and does not require in depth detailed discussion - on housing or job numbers for example. A revised Vision is put forward and there is a statement in paragraph 3.4 of the covering report that this may need to be revisited when the subsequent in-depth discussion takes place.

I would hope that you realise that I appreciate the concern in both Trimleys in respect of the potential contents of the Local Development Framework. I would not want to appear to be diluting such concern by attempting to summarise the responses of the two parish councils and STAG. The Task Group should be informed in its decision making and I will recommend the Head of Planning Services (in whose name reports are published) that, rather than reduce it to one or two paragraphs, to report in full (perhaps as an appendix) the report attached to the STAG letter dated 30 March along with the submissions by the Parish Councils. In this way the Task Group will be made aware of the points that you raise.

Such an appendix is perhaps best attached to the report on the theme of settlement policy or housing as these are most relevant to the majority of the points that are raised. At this point in time I cannot provide you with a programme.

In any event it is the intention to update the housing base date to the 1st April 2007, thus addressing point 2.

Stephen Brown