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SAVE FELIXSTOWE
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Housing Statistics - The Key To Future Housing Strategy Within Suffolk Coastal
Before deciding how many houses still need to be built on greenfield land up to the year 2021 it is essential to know how many houses have already been built, how many approved planning applications are still in the pipeline, and what brownfield land is available for house building. Since the LDF Task Group first published its six Housing Options in July 2006 STAG have been highly critical of their use of actual housing figures which were seriously out of date, misleading, and which severely overstated the numerical need for more homes.
“Using out of date housing figures is not incompetence”
Lies, Damned Lies - And LDF Task Group Housing Statistics
In July 2006 the LDF Task Group produced six Housing Options which showed that Suffolk Coastal District needed 3620 new houses to be allocated on greenfield land up to the year 2021. However, the figures used for House Completions, Outstanding Planning Permissions and Urban Capacity (brownfield sites) were only up to 1 April 2004. STAG were highly critical of the misuse of such inaccurate housing data to support such an important decision as future housing needs.
In addition, Stephen Brown, SCDC Planning Policy & Implementation Manager, attended a joint Meeting of Trimley St Mary and Trimley St Martin Parish Councils in September 2006 where, once again, the folly of using these out of date housing statistics was stressed.
In February 2007 the LDF Task Group published their Core Strategy Issues And Options Consultation Document, upon which interested parties throughout Suffolk Coastal District were asked to comment on and express a preference for a Housing Option. Surprisingly - or not - the same discredited three year old housing figures were used. In asking stakeholders to express a preference the LDF Task Group omitted to state certain important matters :
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The inherent inaccuracy of the figures presented,
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The fact that they would be updated and significantly altered as at 1 April 2007, and
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The fact that a potential source for many hundreds of homes on infill sites had been totally omitted. (*)
Both STAG and Trimley St Martin Parish Council submitted detailed, and highly critical, consultation responses. It was pointed out that no prudent business would make important, long term decisions based on out of date information. We felt that the LDF Task Group and their professional advisors should aspire to the same high standards and were disappointed that they had not done so.
At a Meeting with STAG in March 2007, neither Councillor Andy Smith nor Stephen Brown saw anything wrong with using these out of date housing figures. Their excuse was that the periodic exercise of updating them was only done every three years and the next periodic update was scheduled for April 2007.
STAG believed then - and still believe now - that this attitude is totally wrong. The decisions to be taken - by stakeholders in expressing their consultation preferences, and by the LDF Task Group in concluding which Housing Option to eventually recommend - will affect the environment, economy, infrastructure and wellbeing of Suffolk Coastal District for generations to come. On this basis it is essential that the best, most accurate, and most up to date information is used at all times. In the real world - the world of business - anyone who used the excuse that the best they could do was three year old statistics would be shown the door. The members of the LDF Task Group and their advisors have been elected to represent our interests, or are paid out of our taxes to do so. STAG seriously questions the integrity, competence and fitness for purpose of anyone who thinks that important decisions can be made or supported on the basis of information that is three years out of date and is known to be seriously inaccurate.
The Freedom Of Information Act
STAG have successfully used this Act several times to prove the inaccuracy of the Six Housing Options, most recently to obtain the results of the updating exercise conducted as at 1 April 2007. As of writing - 28 July 2007 - the Urban Capacity figures are not yet available, but what we have been given is damning.
One : The number of House Completions from April 2004 to April 2007 has increased by 2399 units.
Two : The number of Outstanding Planning Permissions has decreased by 453 units.
Three : However, this still gives a nett increase of 1946 housing units.
Four : The result is that the number of houses which need to be Allocated on greenfield land has decreased from 3620 units to 1674 units!
But That’s Not All - Brownfield Sites
We are still waiting for the Urban Capacity figures - brownfield sites available for house building - to be validated and released to us as part of our FOIA request. As at April 2004 this figure was 2310 units, including 490 in Felixstowe and the Trimley Villages. It is only to be expected that in the intervening three years this total will have been reduced, by an as yet unknown figure, by houses built and planning applications granted. However, brownfield land is a renewable resource, and it is probable that more brownfield sites have become available in the intervening period, or their future availability can be reasonably predicted. Some examples of brownfield sites which have become available in the last three years, or can be predicted with reasonable certainty, include :
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Offices and factories which have become redundant,
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Schools which are surplus to requirements,
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A number of brownfield sites in and around Felixstowe which were identified by David Lock Associates last year.
But That’s Not All - The Curious Case Of The Windfall Or Infill Sites. (*)
Windfall sites - or infills - are small parcels of land within large gardens, gaps between houses, and large houses converted into flats or replaced by smaller units. According to earlier FOIA information received from Stephen Brown, over the past eight years small developments such as these, of less than 5 units each, have averaged almost 120 per annum. In the words of Stephen Brown : “If projected forward at the same rate this might imply a total of 1680 from 2007 to 2021 inclusive. However, the supply is unlikely to continue at such a rate (indeed, it would appear to be falling from a 2004/5 peak) and I am simply unable to predict what the number might be. Reliance on such unplanned, ad hoc development in order to meet housing needs is also undesirable. I would prefer to be more scientific and attempt to quantify the potential numbers through the urban capacity study.”
STAG also agrees that it would be undesirable to rely too much on windfall or infill sites as a future source of new housing. Nevertheless, we believe that it would be both prudent and more accurate to recognise that probably hundreds of new infill or windfall houses will be built in the period to 2021. However, since including Windfalls within the Housing Options would reduce the number of houses to be allocated on greenfield land, that would not suit the ultimate purpose of the LDF Task Group - to build large numbers of houses on greenfield land around the Trimley Villages. (As proof of this intention we will remind you of the LDF Task Group Minutes from July 2006 : “The Task Group considered that Option 6 for the spatial distribution of housing across the District was the right way forward as other Options would be unsustainable.”)
In order to avoid recognising the potential contribution of future Windfall sites within the various Housing Options, the LDF Task Group changed the method for categorising major towns, market towns, villages and so on within the Settlement Hierarchy. If residents of a village or hamlet have to travel by car to shops, schools or employment then that settlement is now deemed to be not sustainable, and infill or windfall housing would therefore be discouraged. In the words of Stephen Brown at the LDF Task Group Meeting on 23 July 2007, infilling in hamlets or clusters of housing would not protect the countryside, would erode the character of that hamlet, and would encourage its inhabitants to travel by car. STAG wholly endorses these sentiments, but only wishes that they were applied on a consistent basis, since large scale house building around the Trimley Villages would destroy the countryside, would erode the characters of Trimley St Mary and Trimley St Martin and would in no way discourage their inhabitants from using their cars.
Is Anyone Out There Listening?
The LDF Task Group are currently in the process of Themed Meetings, where specific aspects of the Core Strategy and the related consultation responses will be discussed and decided upon. The Theme of Housing Options is still to be discussed. STAG awaits this with considerable interest. How will the Housing Statistics be presented? Will they admit that the Housing Options presented for consultation were seriously flawed? Will they wriggle and squirm to ensure that greenfield land around the Trimley Villages is destroyed by thousands of new homes?
We have some hope - or do we?
Although STAG believes that Councillor Smith is predetermined towards large scale house building around the Trimley Villages, the LDF Task Group is a democracy, made up of Councillors elected from all over the District. These hopefully are brave men and women of integrity, who remember why they were elected and who will speak up when they have to - to do their best for the people and the environment, not to keep their mouths shut and do what they are told. Unfortunately, having observed their conduct at previous LDF Task Group Meetings, some will speak hesitantly, others will keep their mouths shut throughout, but they will all be led without protest towards a conclusion they do not necessarily believe to be right.

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Core Strategy Figures
2001 - 2004
FOIA Figures
2005 - 2007
Combined Totals
2001 - 2007
House Completions
1460
+2399
3859
Outstanding Planning Permissions
2810
-453
2357
Urban Capacity
2310
0
2310
Windfall
0
0
0
Allocations To 2021
3620
1674
Total Requirement 2001 - 2021
10200
10200
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Core Strategy Figures
2001 - 2004
FOIA Figures
2005 - 2007
Combined Totals
2001 - 2007
House Completions
1460
x
3850
Outstanding Planning Permissions
2810
x
2160
Urban Capacity
2310
0
1100
Windfall / Small Sites
0
0
1160
Allocations To 2021
3620
1930
Total Requirement 2001 - 2021
10200
10200